What Do Supreme Court Precedents Tell Us About Removal of Books from School Libraries?

I often hear arguments that the Supreme Court has held that school boards are limited by the Free Speech Clause in their ability to remove books. A commenter on the first thread in this chain offers an example:

The distinction is that the school library already had the copy and then removed it. While many will debate whether that distinction makes a difference, it does under Supreme Court jurisprudence.
In fact, the U.S. Courts Web site says the same. [UPDATE: I e-mailed the Administrative Office of the U.S. Courts about this, and they removed the erroneous description.]

But this turns out not to be an accurate statement of what the Supreme Court has actually held. This issue was indeed before the court in Board of Ed. v. Pico, and four Justices did take the view that library removal decisions were generally unconstitutional if they were motivated by disapproval of the ideas that the book expresses (though would be permissible if they were motivated by other, supposedly more neutral, factors, such as the book's vulgarity or age-inappropriateness or inaccuracy). And the four Justices were joined by one Justice in affirming the lower court's decision, which refused to grant summary judgment in favor of the school board.

But there were precisely the same number of votes — four — for the view that even viewpoint-based removal decisions were generally constitutional (except in the narrow situation where the disagreement was based on pure partisanship, for instance if a Democrat-run board removed books because they were written by Republicans or because they praised Republicans) as there were for the view that such decisions were generally unconstitutional. The swing vote, Justice White, deliberately did not opine on the question; Pico thus left the issue 4-4.

Why did Justice White agree as to the bottom line action — affirming the court of appeals decision — with those Justices who thought viewpoint-based removals were unconstitutional? Simply because he did not want the issue resolved at that point, and procedurally the way to avoid that was to affirm. Here's what happened, in Justice White's own words (emphasis added):

The District Court found that the books were removed from the school library because the school board believed them "to be, in essence, vulgar." Both Court of Appeals judges in the majority concluded, however, that there was a material issue of fact that precluded summary judgment sought by petitioners. The unresolved factual issue, as I understand it, is the reason or reasons underlying the school board's removal of the books. I am not inclined to disagree with the Court of Appeals on such a fact-bound issue and hence concur in the judgment of affirmance. Presumably this will result in a trial and the making of a full record and findings on the critical issues.

The plurality seems compelled to go further and issue a dissertation on the extent to which the First Amendment limits the discretion of the school board to remove books from the school library. I see no necessity for doing so at this point. When findings of fact and conclusions of law are made by the District Court, that may end the case. If, for example, the District Court concludes after a trial that the books were removed for their vulgarity, there may be no appeal. In any event, if there is an appeal, if there is dissatisfaction with the subsequent Court of Appeals' judgment, and if certiorari is sought and granted, there will be time enough to address the First Amendment issues that may then be presented.

I thus prefer the course taken by the Court in Kennedy v. Silas Mason Co., 334 U.S. 249 (1948), a suit involving overtime compensation under the Fair Labor Standards Act. Summary judgment had been granted by the District Court and affirmed by the Court of Appeals. This Court reversed, holding that summary judgment was improvidently granted, and remanded for trial so that a proper record could be made. The Court expressly abjured issuing its advice on the legal issues involved. Writing for the Court, Justice Jackson stated:

"We consider it the part of good judicial administration to withhold decision of the ultimate questions involved in this case until this or another record shall present a more solid basis of findings based on litigation or on a comprehensive statement of agreed facts. While we might be able, on the present record, to reach a conclusion that would decide the case, it might well be found later to be lacking in the thoroughness that should precede judgment of this importance and which it is the purpose of the judicial process to provide.

"Without intimating any conclusion on the merits, we vacate the judgments below and remand the case to the District Court for reconsideration and amplification of the record in the light of this opinion and of present contentions."

We took a similar course in a unanimous per curiam opinion in Dombrowski v. Eastland, 387 U.S. 82 (1967). There we overturned a summary judgment since it was necessary to resolve a factual dispute about collaboration between one of the respondents and a state legislative committee. We remanded, saying: "In the absence of the factual refinement which can occur only as a result of trial, we need not and, indeed, could not express judgment as to the legal consequences of such collaboration, if it occurred."

The Silas Mason case turned on issues of statutory construction. It is even more important that we take a similar course in cases like Dombrowski, which involved Speech or Debate Clause immunity, and in this one, which poses difficult First Amendment issues in a largely uncharted field. We should not decide constitutional questions until it is necessary to do so, or at least until there is better reason to address them than are evident here. I therefore concur in the judgment of affirmance.

So that's why Pico has no precedential value on this question. The Court's fractured decision in United States v. American Library Ass'n — where there was also no majority opinion — doesn't resolve the issue, either. And no other decisions outside the library context dictate, or in my view strongly suggest, a result. If the library were treated as a "designated public forum" that's generally open for a nearly limitless variety of speech, then the library wouldn't be able to set up viewpoint-based restrictions on such speech. But library shelving decisions have never been treated as such a forum, because the choice of what books to select in the first place inherently involves some content-based and often some viewpoint-based judgment. There's no caselaw that squarely tells us whether there are nonetheless constitutional constraints on such judgment, or whether removal decisions are constitutionally different from selection decisions.

In some ways, NEA v. Finley is somewhat on point, because it too involves government action that aims to impose some quality judgments, and that is inherently content-based. And Finley does suggest that "invidious viewpoint discrimination" in such judgments may be unconstitutional, though presumably non-invidious viewpoint discrimination would be permissible.

But Finley's point is just a suggestion — the Court specifically stresses that "we have no occasion here to address an as-applied challenge in a situation where the denial of a grant may be shown to be the product of invidious viewpoint discrimination," and while there's also wording there that suggests such invidious viewpoint discrimination would be impermissible, there's no square holding. There is also no definition of when viewpoint discrimination becomes "invidious," and it's not clear to what extent the Finley case, involving arts grants, would carry over to the public library context (and especially public library books aimed at children).

(Note that Pico was a school library case, and one could certainly argue that decisions as to other public libraries, and especially the adult-aimed collections of those libraries, are constitutionally different from decisions as to school libraries or as to the children's collections of other public libraries. But while this isn't an implausible argument, it is again not one that is firmly supported by existing precedent.)

So all this should make clear, I think, that there's no answer from the Supreme Court on the subject; nor to my knowledge is there a broad and firm consensus of lower courts. My sense is that, when it comes to shelving and removal decisions, then-Justice Rehnquist's argument in Pico is the more persuasive one, at least as to the decisions in the inherently content-based field and often viewpoint-based field of what is to be on public school library shelves (though not necessarily as to Internet access decisions, which could be content-neutral and especially viewpoint-neutral). (I also think it's quite proper for people to fault certain kinds of book removal decisions on the grounds that those decisions show narrow-mindedness, or deny library patrons — including children — valuable information, and are thus improper even though they aren't unconstitutional or even more broadly rights-violating. Of course, as with many ethical judgments, such a judgment will turn considerably on the details of each case.)

Related Posts (on one page):

  1. What Do Supreme Court Precedents Tell Us About Removal of Books from School Libraries?
  2. What May a School Board Do When It Concludes an Elementary School Library Book Omits Important Information?
Tracy Johnson (www):
It seems that school boards are apparently stupid. If they were that concerned about the contents of their libraries, then the oversight should be which books are being added to begin with.

They've already messed it up if they have to go through a board process to remove a book.

(Note I'm content neutral here, I could care less about this case. I'm trying to show what I think is a technical point.)
2.6.2009 5:15pm
A Law Dawg:
Prof. Volokh,

As the quoted commenter I think it is important to note the context of my statement. I was distinguishing a scenario under which a person seeks mandamus to compel a librarian to stock a certain book.

I can't think of any Supreme Court jurisprudence that would support a grant of mandamus for such purposes; however Pico at least leaves the door open for the judiciary to forbid the removal of a book already put out on the shelf.
2.6.2009 5:16pm
A Law Dawg:
It seems that school boards are apparently stupid.

Believe me when I say you have no idea.
2.6.2009 5:17pm
A Law Dawg:
I also completely agree that Rehnquist's dissent is far more persuasive. People try to say that school boards are banning books when they plainly are not; the same books are almost always available two blocks away in the public library.
2.6.2009 5:19pm
John (mail):
I think the key part of Rehnquist's opinion in Pico is this:

" It does not follow, however, that a school board must affirmatively aid the speaker in his communication with the recipient. In short the plurality suggests today that if a writer has something to say, the government through its schools must be the courier. None of the cases cited by the plurality establish this broad-based proposition."

But this problem, like so many in modern Constitutional jurisprudence, arises from a deep need on the part of judges to graft their own ideas onto the Constitution.

In this case, there is of course nothing in the Constitution about regulating the contents of government-run libraries. Yet, the courts have so stretched the meaning of "Congress shall make no law...abridging the freedom of speech..." that we now find that, under some circumstances, this means that a public library may not decide what books it may keep on its shelves.

One might reasonably ask, who's freedom is being abridged with such a doctrine? The courts say it is some student's, who wants to read some book and wants his library to keep it for him. But what of the librarian's freedom to display books of her choosing? Which freedom is more like a freedom of "speech"? The freedom to provide books for reading, or the "freedom" to compel another to provide books for you?

Well, like all Constitutional battles of this sort, the game is lost. We lawyers can stretch any grievance to Constitutional proportions, and plenty of judges will agree if the result comports with their beliefs in what is good for us.
2.6.2009 5:27pm
pete (mail) (www):
Librarians remove and add books all the time, with innacuracy from being out of date being one of the main reasons for removing them. With any controversial topic you will get disagreement over what is accurate. Most public libraries try to resolve this dilemma by setting up policies that try to be as content neutral as reasonably possible.

One of the main issues is that most librarians buy most books fairly ignorant of what is actually in them. If you are ordering a couple of hundred different titles a week that you have never actually read or even seen in person before, you just have to make a good guess based on reviews if you can find them, what other libraries own, what people ask for, and what publishers try to sell you. Most months I consider about 400 titles (books and media) and order about 175 of those. I have never seen the vast majority of these before and if I am lucky I can find reviews for about half of the titles I consider.

School libraries are a bit different policy wise since you are dealing with kids that parents and society in general have entrusted to the state to educate. You have a captive audience of minors, a lot more so than a public library where everyone is there voluntarily.

I am not too familiar with the supreme court rulings on this, but I spend 10-20 hours most weeks deciding what gets to be our public library collection. If I was a school board member in the other case about Cuba below this post, I would have kept the book in the collection and just made sure they bought more books that taught about the other side. Maybe also set up a display about how in the US you can now read whatever book you want, but in countries like Cuba they put you in jail for reading certain books and private citizens can not have their own libraries and make sure to mention Cuba's jailed librarians. Libraies already do banned books displays all the time so I would also include some books that have been banned in countries like Cuba.
2.6.2009 5:44pm
I can't think of any Supreme Court jurisprudence that would support a grant of mandamus for such purposes; however Pico at least leaves the door open for the judiciary to forbid the removal of a book already put out on the shelf.

That doesn't sound like a distinction. The door is open in either case, but no decisions exist to actually support the desired outcome.
2.6.2009 5:50pm
A Law Dawg:
That doesn't sound like a distinction. The door is open in either case, but no decisions exist to actually support the desired outcome.

There are numerous cases which cite Pico for the proposition discussed; I cant think of any Supreme Court case cited for the proposition that a librarian can be compelled to purchase a particular book.

Like it or not, it is the distinction between "thou shalt not remove" and "thou shalt purchase" that made a difference in Pico. I agree that the distinction is odious, but because it makes a difference to the Supreme Court, it makes a difference in libraries.
2.6.2009 5:56pm

I take issue with your implication that the people who wrote the Constitution would have categorically rejected these kinds of appeals to the first amendment because there's nothing written about government-run libraries.

In the Miami Dade case, you could say a book was plucked off a public library shelf because it did not teach children that Cuba was run by a bad, oppressive man. That's obviously worth thinking about in the context of the first amendment. If it were replaced only by books that did talk about oppression and Castro in very negative terms and as the most important fact about contemporary Cuba, well, that's another issue that implicates freedom of speech.
2.6.2009 6:03pm
John (mail):

While implementing the Constitution's prohibitions requires us to interpret words and phrases to apply to subjects that are not explicitly mentioned in the Constitution (e.g., before we protect speech, we have to know what "speech" means (or meant...)). However, there is no principled way to call a student's desire to read something speech, in my view. And while we may never know for sure, it would stun me if our forefathers would EVER say the people who maintain a public library should be required by the Constitution to decide on books in one way or another.
2.6.2009 6:46pm
David Schwartz (mail):
John: The Librarian is an employee of the government, her job is to do the government's bidding. They can do their own speaking on their own time. If the question is whose freedom takes precedence, clearly it's the user of the library whose tax dollars pay the librarian's salary.

If you honestly think the librarian's freedom to stock the books they wish has some standing, you get some really absurd consequences. What about the President's Press Secretary's right to speak on the subjects they wish during a press conference?
2.6.2009 8:08pm
J. Aldridge:
Who cares what might be Supreme Court Precedent. I will always enjoy non-fiction over Supreme Court works of fiction.
2.6.2009 8:10pm
John (mail):
David Schwartz:

I was just saying if you are looking to what is more analogous to speech, the librarian stocking her shelves is more speechlike than a student's wish to read, which is not so much akin to speech as it is to listening to some one else's speech.

It is true that when the government is an employer its employees may forfeit some of their rights, as they would in private employment. I was only making the point that the student's rights were less speechlike than the librarian's.

My own view is that the remedy a community should have for bad book choices in the library is firing the librarian, not individuals bringing suits against the library. But of course firing a librarian because of her book choices would only result in a suit by the librarian that her Constitutional rights were being infringed...
2.6.2009 8:30pm
Soronel Haetir (mail):

It seems that school boards are apparently stupid. If they were that concerned about the contents of their libraries, then the oversight should be which
books are being added to begin with.

The problem with this statement is that school boards are replaceable, in many places in short order. While I wouldn't think Miami-Dade would be suseptible to an issue this trivial causing complete turnover I have lived in small towns where issues of the same importance have caused the ouster of long sitting board members.

Or look at the intelligent design debate in (Kansas was it?) where the state curricula board has been replaced a couple times as ID and evolution proponents felt more motivated to get out the vote.

So to say that school boards should consider what they bring in more carefully misses the point that the decisions a board will make can vary wildly in very short time periods because the people comprising the board change.
2.6.2009 9:54pm

I think it's quite principled to say, for example, that a book is speech. Further, removing books from public libraries based on what the government deems idealogically harmful rises to the level of abridging free speech. I understand that it's not the same as censoring a book outright, but it is still a conscious decision by the government to, let's say, stop investing public funds in maintaining the book, based purely on its content not being politically pleasing. Shall we keep paying for its upkeep? No, we don't like what it has to say about politics and who oppresses whom.

I do think that action conceivably triggers questions of the first amendment, and I do not think it requires a living Constitution, even, to get us there.
2.6.2009 11:10pm
Sergei Zhulik (mail) (www):
One quick observation:

The Pico Court was able to muster a majority supporting the following position:

It was possible for a resolution of the facts in dispute to demonstrate a constitutional violation.

After all, if this weren't true, there would have been no reason to affirm the Appellate Court's remand order.


Of course, the implication of the parsimonious 5-justice decision is that there exists some constitutional restraint on school boards' discretion in libary book-removal decisions. Maybe the showing of facts requisite to trigger a violation tracks the contours of Brennan's 4-justice opinion. Maybe a violation is determined by a different standard. But I don't think it unreasonable for the Court to attempt to provide some guidance, even if technically unnecessary.

The practical result of implying constitutional constraints on school boards' relevant conduct--without providing more--risks uncertainty in the law (and all its attendant consequences). Think about it: in the absence of some judicial guidance, school boards may be unduly bound by fears of litigation. And their fears would be well warranted: potential litigants might be unduly encouraged to contitutionalize otherwise political issues.
2.6.2009 11:28pm
John (mail):

Of course I understand your argument, but I disagree with it. To say to an author, "your book can't stay in my library," does not affect his speech in any way, so long as he is free to publish and sell or give away his book to anybody he wants. Besides, the suits are not by authors, whose free speech rights you are advancing, but by students or potential readers; and their wishes to have the library furnish books to them, I am arguing, have nothing to do with their speech.
2.7.2009 12:22am

I agree that it's dubious, upon first reading, for students to suggest that their freedom of speech has been abridged so as to obtain standing to sue under the 1st amendment. For that to succeed, you have to describe "speech" as including an act like reading a book. Sounds perhaps without principle, as you said, but is it? In fact, the Pico plurality argued quite persuasively that a student's standing to sue is informed by the "corollary" of the right to speak, which is the right to listen when others speak ("receive discussion and debate"). They point out that protecting the right to speak but preventing people from hearing you is an end-run around the Constitution, and that the first amendment exists to protect speech by protecting discourse from contraction based on content. But I'm sure you understand this reasoning, as you said, and I understand your point that this corollary naturally isn't as explicit as the right to speech itself. And I would say of course it isn't as explicit; it's the implicit but necessary corollary.

Also, I think banning books does injure the author, because it hardly holds to say "well, we've silenced him here -- in a place especially made to foster discussion and debate -- but there are so many other places where we haven't gagged him. We merely, you know, pick the places where we're afraid he'll be found most persuasive, like schools inhabited by children." To me, That simply cuts against the letter and spirit of the 1st amendment.
2.7.2009 2:12am
Pypefalay (mail) (www):
2.7.2009 2:32am
David Schwartz (mail):
John: I think you can make the point I think you're trying to make by putting it thusly: one who complains about the government removing books from its own shelves is complaining that the government won't say what he wants it to say, not that anybody speaker is being suppressed or impeded.
2.7.2009 3:55am
Larry Fafarman (mail) (www):
The original post says,
So all this should make clear, I think, that there's no answer from the Supreme Court on the subject; nor to my knowledge is there a broad and firm consensus of lower courts.

There is often no consensus on interpretations of Supreme Court decisions where there is no majority opinion. Interpretation of such decisions is supposed to be governed by the "Marks rule." In Marks v. United States, 430 U.S. 188, 193 (1977), the Supreme Court said, "When a fragmented Court decides a case and no single rationale explaining the result enjoys the assent of [the majority], the holding of the Court may be viewed as that position taken by those Members who concurred in the judgments on the narrowest grounds." However, there is often no consensus on how or whether to apply the Marks rule in specific instances -- for example, in Nichols v. United States, 511 U. S. 738, 745-746 (1994), the Supreme Court said,

This test is more easily stated than applied to the various opinions supporting the result in Baldasar. A number of Courts of Appeals have decided that there is no lowest common denominator or "narrowest grounds" that represents the Court's holding . . . .

We think it not useful to pursue the Marks inquiry to the utmost logical possibility when it has so obviously baffled and divided the lower courts which have considered it.

Details are in this post on my blog.

BTW, this is not just a "freedom of speech" issue -- it is also a "freedom of the press" issue. Also, maybe the "Miller test" ("utterly without redeeming social value") could be applied.
2.7.2009 8:41am
D Kosloff (mail):
The "Miller test" should be applied to books allowed in school libraries only if we want a society that has as its goal only to rise barely above being "utterly without redeeming social value".
2.7.2009 10:16am
John (mail):
David Schwartz,

Nicely put!


Ah, the Constitutional "corollary"! I agree with you that this is how modern Constitutional analysts look at things, and that such readings are therefore fair game. I disagree with that mode of analysis (which was the point of my original comment), but I do recognize that the game, as I said, is lost. I just think that's a bad thing, and that our lives would be simpler by the courts' reading the damn thing as it's written, and suggesting it be amended if it doesn't do what they think is fair, and leaving it up to the people to do what they want.
2.7.2009 11:30am
Randy R. (mail):

"It seems that school boards are apparently stupid."

Mark Twain once said that God first created idiots. but that was just for practice. Then he created school boards.

School librarians are my heros. My friend Alex Sanchez has written a series of fictional books about (and for) gay teenagers. They are fun, but they deal with the angst of coming out, dealing with bullies, unsympathetic parents, friends who actually like you, etc. They have been a real hit, and fits a niche market, since there are really no novels written for teens like this. (Alex was a high school counselor for a while, so he knows what teens are looking for).

His book is bought for school libraries all across the country, and are eagerly read by the students. Oddly enough, the ones who read his books most are first, gay male teenagers, and then straight teen females.

Anyway, his books are highly recommended by all the standard book clubs, reviews, etc, and so they get picked by the librarians, who know they are popular because they are checked out so often. Alex tells me that these librarians are the ones who stand up to bullying by people who want to ban his books, and so have become his heros.
2.7.2009 1:00pm
Larry Fafarman (mail) (www):
D Kosloff said,
The "Miller test" should be applied to books allowed in school libraries only if we want a society that has as its goal only to rise barely above being "utterly without redeeming social value".

If you don't like the Miller test, then what test do you propose using instead?
2.7.2009 4:37pm
ambrose (mail):
It would seem that the fundamental problem is attempting to appear to apply a document a 3 centuries old to solve current problems. In matters that are serious to them strong judges are not likely to be bound by the document if they disagree strongly with the result. They seem to distort the meaning of the words to reason to the conclusion they desire or to ignore the words completely. As much as we would like to tie their hands, experience shows that we cannot do so. To any one who has studied logic to say that speech includes books is simply illogical. To say that a school board, or a librarian is Congress is also illogical. However, destroying books or keeping them for school children because they contain ideas the government or it's agents don't like is also really bad. How would the court rule if a school board ordered the removal of all books that mention the reference to slavery in the original Constitution. Is there really any difference in vulgar speech and ok speech in the words of the Constitution. No, but there is a difference in speech "we" consider important and vulgar speech is not in that class. Therefore, vulgar speech is out and political speech in in. There are times when I think that some political speech is worse that the most profane vulgar language. Advocating killing of people who are not of the same skin color, religion or sexual orientation or holding them as slaves is worse than "bad" language.
The Constitution means what the Supreme Court says it means and much as we may dislike it, it changes with the men who sit on that court. You can parse the language of the cases as much as you like, but if you want to make decisions based on what they think the law is study the background, training, family background and expressions of the judges opinions, what they had for breakfast on the morning they make the decision or the race of the people in the case if it happens that their distant relatives attacked this country.
2.7.2009 5:47pm
Larry Fafarman (mail) (www):
ambrose said,
As much as we would like to tie their hands, experience shows that we cannot do so.

Congress has made attempts to tie the hands of federal courts -- this is called "jurisdiction stripping".

To any one who has studied logic to say that speech includes books is simply illogical.

It is even more illogical to say that "speech" includes "symbolic" speech -- but the courts have so held.

Also, IMO this is more of a "freedom of the press" issue than a "freedom of speech" issue.
2.7.2009 9:05pm
I've never met anyone who actually opposes censorship in education. Nobody says you can't teach Spanish unless you also teach French, Swahili, and Ugaritic. Nobody says you can't eliminate the abacus course or the quill pen maintenance course to accommodate computers. Nobody thinks we should continue to teach the phlostigon or the aether theories. Everybody seems to agrees that school boards should select the material they think most useful for children and eliminate material that they don't think useful.

The only problem comes when people disagree with the school board's decisions. When people disagree, they sue the school board on grounds that unless the school board is willing to use exactly the criteria they do and the decisions the same way they want to, the school board is engaging in "censorship." What's really rediculous about it is that these same people regularly sue to force the school board to remove art object that they don't like. When the school board DOESN'T remove things they want removed, that seems to be censorship too.

There's concept of censorship being an English word that has some sort of actual meaning. It's through the looking glass all the way. Things mean whatever people want them to mean. There's not even any problem with religious art; it's only religious art associated with religions that plaintiffs happen not to like.

It's a bit like the Lafontaine story of the lions getting together and ridding themselves of the lamb for abuse of power and whatnot. At least the grounds ought to have some sort of credibility, something people outside the charmed circle could actually take seriously. But of course when believes only those in the charmed circle are right, it's easy to convince oneself that making decisions based on any criteria other than those in the charmed circle use is evil. So of course it must be censorship. Isn't that censorship is -- teaching children the wrong things and not teaching them the right ones?
2.8.2009 11:48am
Richard Aubrey (mail):
Rf yr. last sentence. No.

Problem with adding to the prescribed education of the kids.
Was talking with a couple of sixth-graders about Columbus, their study subject for the week. He apparently proved the world wasn't flat.
I got out a map and we talked about distances and sailing ship endurance and that an old guy named Eratosthenes had figured it all out a a long time before.
"Should we tell her [the teacher]?", asked Sarah. "No," said Martin, "you know how mad she gets when somebody corrects her."
So, the suggestion that a better book be put side by side with this one is likely to run into resistance from those who thought this was just dandy. You think they thought it was dandy without looking at it, or do you think they thought it painted the picture they wanted the kids to get? If the latter, what if a book with a more complete picture is chosen to supplement the first one?
BTW, something cyrillic seems to have happened to the other thread on this subject.
2.10.2009 2:55pm

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