KARL BELANGER: Have we heard from Natalie Chin yet?
ROBYN POWELL: I just texted with her and she's apparently in the wrong room so she's finding her way to this room.
LOU ANN BLAKE: Okay. Thank you, Robyn.
ROBYN POWELL: Yep.
KARL BELANGER: Do we want to go ahead and do the video?
LOU ANN BLAKE: Sure. We have a sponsor video from Burton Blatt Institute. They are one of the sponsors of the 2022 tenBroek Symposium, and Karl will show that video now.
KARL BELANGER: Apologies for the brief issue of it not showing the window I want it to show.
LOU ANN BLAKE: It's always something.
KARL BELANGER: Yes.
Bear with me one moment, please.
ROBYN POWELL: Natalie is on.
LOU ANN BLAKE: Thank you.
KARL BELANGER: Of course it doesn't want to show, so give me one minute while I try to troubleshoot this. Apologies for the delay.
LOU ANN BLAKE: If we have to, I guess we could wait to the end.
KARL BELANGER: While I'm waiting, let me make Natalie a cohost.
I'll try this one more time.
I will troubleshoot and do it later. Apologies.
LOU ANN BLAKE: That's okay. We always have the plenary session tomorrow afternoon as well.
All right. So we'll go ahead and get started.
Good afternoon, everyone. Thank you for joining us for this afternoon's final, final plenary session presentation. Centering -- now I'm having issues. Hold on.
Centering DisCrit and Disability Justice into the Disability Rights Network. We're going to kick that off with an introduction by Zainab Alkebsi, policy counsel at the National Association of the Deaf. Prior to joining NAD, she was deputy director of the Maryland Governor's Office of the Deaf and Hard of Hearing. And Zainab is also a member of our fabulous 2022 tenBroek Disability Law Symposium Steering Committee. So let's welcome to the virtual stage Zainab Alkebsi.
ZAINAB ALKEBSI: Thank you, Lou Ann. I'll begin by giving a visual description. I'm an Arab American woman, light skinned with black curly hair just above my shoulders, wearing glasses, red shirt, black blazer, in my home office. Behind me is a blue background.
My name is Zainab Alkebsi. My pronouns are she/her/hers. I am the policy counsel at the National Association of the Deaf, as Lou Ann has already said, and it is really my honor to be here to introduce today's panel for this final panel of the day.
I'm going to keep my introduction quite brief. But this panel will discuss -- if we could go ahead and make sure the speaker is in the spotlight rather than the interpreter.
This panel will discuss the need for a recalibration of the disability rights single issue framework. We need a more holistic approach rather than the singular focus on disability that unpacks the role of the various isms that Black, indigenous, people of color are facing in the fight against injustice.
It is my honor to introduce today's panelists. We have with us today Natalie Chin, associate professor of Law, City University of New York School of Law, and co-director of the Disability and Aging Justice Clinic. We have as well with us Jamelia Morgan, assistant professor of law at the University of California, Irvine, School of Law. And Robyn Powell, Bruce R. Jacob visiting assistant professor at Stetson University College of Law.
And with that, I would like to welcome the three of you. The floor is now yours. I look forward to our discussion and learning from you. Thank you.
NATALIE CHIN: Hello. It's really great to be here. I just want to thank tenBroek for accepting my proposal.
I thought it would be a workshop, but here we are in a plenary session for all to see.
I want to share my screen real quick.
I thought it would be helpful to provide a roadmap. This is a PowerPoint slide that says centering DisCrit and disability justice in a disability rights framework. This will be myself and Jamelia Morgan and Robyn Powell. We hope to cover these topics in the hour and a half that we have. I'll start on giving a brief background on disability justice and its principles and then we'll move in to talking about DisCrit and disability justice. And then we'll move forward and talk about where the ADA falls short in terms of reproductive justice, and then policing under disability law. And then we'll discuss where the ADA falls short in community integration and hopefully provide some suggestions and solutions. It's a packed 90 minutes, so let's get started.
I think it's impossible to talk about a disability future without first talking about race. And more specifically anti-Black racism. So the question is, is it possible to imagine a future that centers disability theory and disability justice into the disability rights framework. So here I have a slide. At the top it says "Racism, ableism and disability. To understand the present, you must know the past, the history." And there are three photos. On the left side it says 1787: Moseley, a treatise on tropical diseases and on the climate of the West Indies. I took out a sentence from this book about why Black people are essentially inferior. Fascinating doing this research and seeing all the trail of things written in past medical journals. And this highlighted line says "They bear operations much better than white people and what would be the cause of inoperable pain to a white man, a Negro would almost disregard." I was thinking about this issue. During COVID when a lot of the conversations really centered on race and the impacts of race on COVID, but there was a disconnect between the intersection of race and disability with COVID. And then the story of Michael Hickson happened, a Black man, early 50s, with several children. He was quadriplegic, in a nursing home, he ended up in the hospital after getting COVID in the nursing home and he was denied life-sustaining treatment. This was the first time we had seen blackness and COVID in the news, and the issue was why was he denied treatment. There were all these conversations about it.
When you look back at the history, looking at Black people and the historical treatment, and this is just one example of this false truth, pseudoscience that says that Black people can bear more pain. So the idea of social construction of disability goes back to the time of slavery. So you can look at Michael Hickson and the history of race and COVID and look at this language that has built this foundation for ableism, which I'll talk about in a minute.
And the second photo in this slide is "to be sold, a cargo, 94 prime healthy Negroes." It has two photos of what appears to be Black men.
And the last picture here is of Thomas Jefferson, our former President. "I consider a woman who brings a child every 2 years as more profitable than the best man on the farm." And I look at this slide to think about the idea of the Black body, the worth, the commodification of the Black body. And essentially looking at the idea of attributing disability to the Black body, attributing to the fact of its worth. It comes from somewhere. And when we think about disability rights and disability future -- I'm sorry, I'm just looking at the chat -- it's important to really understand the history of where this is all coming from.
And so I talk about ableism. This is my next slide. But I want to say a few words first. When we think about reimagining a disability rights future, restructuring or reimagining a disability rights framework, what are we talking about? When we say disability rights framework, and again, I'm speaking for myself. I'm not speaking on behalf of the panelists. This is my own definition. It's really the focus on the ADA and Section 504 as a single issue focus of disability rights through litigation and advocacy which emphasizes individualism, self-sufficiency, with the goal of assimilation with nondisabled people through community integration. That's the idea of the framework. Individualism. Self-sufficiency. Assimilation. Working along nondisabled people. So the idea of this value system, this work, self-sufficiency, individualism, is linked through the ideas of ableism which is linked to anti-Black racism which I will also talk about.
So I brought this slide up to introduce some language of ableism and how it intertwines with anti-Black racism and slavery. And I pulled this slave petition from 1838 to get a better sense of the language. So in this slave petition, somebody who owned slave people thought I want to return them because of their vices and defects. And what were those vices and defects? In this petition, they described by the slave holder as eating dirt, rheumatism, epilepsy, running away, infirmity following miscarriage or botched childbirth, and very poor eyesight. So you can identify the idea of equating disability to lack of worth and this rootedness. And this is in 1838. It's important to think about epilepsy, poor eyesight. Black enslaved women were raped by their shave holders and had botched childbirth and miscarriages and would be returned. You can see this theme when we talk about justice, which Professor Powell will talk about today. So I don't have a lot of time, but talking about disability rights, we have to confront our ableist, racist history and also eugenics and all of the vices and defects, the ideas that Black people can endure insurmountable pain, it's a lot of the challenges we fight now as disability rights advocates in our work, and it's rooted here.
There's a really great article by Jennifer Barclay called The Greatest Degree of Perfect. She wrote, by the mid-19th century, the perceived links between race and disability in the legal realm were so naturalized that they appeared to have always existed, though they had been forged through statute and case law that went back to the colonial era. So I thought it was important.
Looking at this individualized self-sufficiency framework to focus on community integration, advocates for a long time said the rights focus approach disproportionately benefited a relatively advantaged class of disabled people. And that is an intro into where disability justice really came from. So there's this sense among disability advocates scholars that the ability of the ADA to achieve greater inclusion, access, and equality for people with disabilities requires more. And what that "more" is is up for debate. But there has to be a way to strengthen the force of the ADA so we can address, and we all want to deeply address the deeply rooted structural obstacles of disability equality.
And I think in terms of I alluded to ableism as we continue in our work the framework for this conversation is how do we center DisCrit and disability justice? We have to have a kind of working definition of ableism because it runs through the vein of disability rights. And I won't read this. I encourage everybody -- I think I'll make these slides available. This is a definition by TL Lewis and others. It's "A system of assigning value to people's bodies and minds based on societal constructed ideas of normalcy, productivity, desirability, intelligence, excellence, and fitness. These constructed ideas are deeply rooted in eugenics, anti-Blackness, misogyny, colonialism, imperialism, and capitalism." The idea is ableism is rooted in these ideas of anti-Blackness and that it really focuses on your language, your appearance, whether you can excel and behave, whether you can reproduce, whether you're healthy. And all of these things we've just touched upon were really the tenets and the backbones and roots of slavery.
So when we're talking about disability rights, it's important to think about the roots of disability, the roots of ableism, and the roots of anti-Black faces and the idea of productivity and health and independence and the body as being healthy. And capitalism and colonialism. It's all intertwined.
So the idea of disability rights was just articulated. It's a single issue focused on disability, community integration, access, disabled people to work, live alongside people without disabilities. That is our goal. That is our focus.
However, what happened is that around 2015 a group of queer and gender nonconforming folks of color who felt they were left out of this mainstream single issue focus of disability converged and really got together. So I have this other slide that I wanted to just break down. Ableism, the focus on the binary, able bodied, disabled. This conversation wasn't happening in the disability rights framework. The idea of ableism, anti-Blackness, this diversity, looking on the single issue of disability. It wasn't there. And so this group got together and said, you know, disability justice, we're not fitting in to this main idea of single issue. We need to center the lives and needs for disabled queer, trans, and or Black and brown people who are marginalized from this mainstream disability rights organizing white-dominated single issue focus and really, that was the core, those are the folks who started disability justice as I wouldn't say a movement but like a development energy, right. And so disability rights is the idea of litigation and advocacy and this rights-based strategy. And disability justice is more, we have to step back from that, recognize that this rights-based strategy is not impacting all of us in the same way. So the disability justice framework lays connections of heterosexism, eugenics, colonialism, capitalism, white supremacy, to ableism and challenges all these interconnected systems that are rooted in disability oppression. So I'm seeing all this and thinking this is very theoretical, how could we possibly bring this in to our work. So there are 10 principles that we have. I have like 2 more minutes. There's 10 principles of disability justice. As we continue this conversation, the idea is what principles can we center in our disability rights work. So just very briefly, the evolving 10 principles of disability justice embrace the complexity of the intersectional identity, centers the leadership of disability justice on those most impacted by the systems of oppression, it resists the productivity driven conceptions of capitalism to recognize that one's value and worth is not dependent on normative levels of productivity. Further, cross movement solidarity, recognizing the wholeness that is found in the history and life experience of disabled people, recognizing the necessity of individual and collective sustainability and fighting for justice and liberation and valuing the participation of all disability identities. Lastly, the principle emphasizes interdependence, collective access, and a move toward collective liberation that leaves no body, mind behind. So the slide here is a longer version of what I just said. So I recognize that was a 50-minute quick and dirty background for disability justice.
I will now pass it along to my colleague Professor Morgan to talk about the interplay between DisCrit and disability justice.
JAMELIA MORGAN: Thank you so much, Professor Chin. Professor Powell, it's an honor to be on the panel with you both. I am delighted to be here at this terrific conference with so many incredible advocates.
My name is Jamelia Morgan. She/her. I am an assistant professor at the University of California Irvine. I am a Black woman wearing a button down striped blue and white shirt with my gold hoop earrings. Just got my hair braided yesterday. And I'm looking forward to the discussion.
All right. So I want to pick up where Professor Chin left off. On the slide is a photo of three people. The first is Dr. Subini Annamma, associate professor at Stanford. The second is Dr. David Connor at Hunter College. The third is Dr. Beth Ferri at Syracuse University School of Education.
These three scholars wrote a terrific article in 2013 titled: Dis/ability Critical Race Studies (DisCrit): Theorizing at the Intersections of Race and Dis/ability. I am going to talk about the article. Candidly, this article has been very influential in my thinking about how to assist courts, advocates, and litigants in thinking through how to frame legal injuries that impact the lives of disabled people, but as Professor Chin said, to do so in an inclusive and intersectional way. The work of DisCrit I think is about responding to the problem of underinclusive approaches to disability, laws, policies, and practices. And so the argument is that the lack of an intersectional lens will fail to fully appreciate the scope of harms facing all people with disabilities, whether it's healthcare discrimination, institutionalization, or where my work is housed, policing and punishment systems.
So what I want to discuss in my remarks today is how a DisCrit approach to American law can build on to existing disability law frameworks, and indeed critical accounts of law, to deepen our analysis of the social harms that impact disabled people and illuminate pathways to more robust protections. So again, it's going to be a summary of this terrific article from the doctors listed on the screen. And I'm just going to provide a birds' eye view of some of the things they say.
One of the foundations of critical race theory is legal support for the notion that racism is endemic in American society. So as professor Adrien Wing puts it, a central premise of CRT is that racism is normal and an ordinary part of our society, not an aberration. A second central idea in CRT is this idea that race is a social construction, that law helped to construct racial categories, largely by defining the boundaries between those persons labeled as white and those persons racialized as nonwhite. So in the process, what we see according to critical race theorists is that laws and legal doctrine worked not only to construct definitions of race, so see, for example, Professor Ian Haney Lopez' famous book "White by Law," but white supremacy, systems with advantages and disadvantages based on racial classifications.
So disability law scholars have applied key insights from critical disability theory to demonstrate in part that disability is, in part, a social construction and for the most part disability law scholars reject a pure medical model of disability. Now, of course the social model has itself been critiqued. We shouldn't ignore the body experiences, the pain in our analysis, but a key intervention from disability studies, and indeed I should note disability legal studies and Professor Arlene Kanter's work in that area, these insights have been brought in to understand disability as a category beyond biological constructions, medicalized understanding of disability as I'm sure we are well aware.
So DisCrit founders believed that the insights both from critical race theory and disability studies bear an important relationship and should be analyzed intersectionally, collectively, in understanding racism and ableism. And I say this because their argument is that racism and ableism, ableism and racism, are mutually enforcing. They explain, and I'm quoting, racism and ableism are normalizing processes that are interconnective and collusive. Racism validates and reinforces ableism, and ableism validates and reinforces racism. Indeed, racism and ableism are so enmeshed in the fabric of our social order, they appear both normal and natural, just to allude to something Professor Chin referred to earlier I think in drawing from the work of Professor Barclay.
So the description that they provide, what it offers us or suggests is that DisCrit can provide an important analytical tool to examine ableism and how it intersects with racism. It allows us to understand how race might inform social meanings and ways of thinking about disability today, and of course that's informed by a historical context, and, in turn, how disability in turn informs meanings and ways of thinking about race, which Professor Chin alluded to earlier. So again, this is what I think is a core fundamental insight of the DisCrit intersectional approach.
So I will talk about some of the central principles of DisCrit and try my best to apply them to current legal problems or social problems that may in part be responded to using law, just to be clear.
So DisCrit's first tenet or first principle focuses on the interdependent ways that racism and ableism shape notions of normalcy. So I've just alluded to that. That's the fundamental and first tenet of disability critical race theory. It refers to much of what Professor Chin noted and so I won't repeat it again, but thinking about how within the period of chattel slavery, ableist understandings of disability were a part of the ways that chattel slavery was justified as a system, right, which is important I think to consider in understanding some of the prevalence of ableism in today's society, not just as applied to negatively racialized persons but to all people with disabilities. Those insights I think are important, and I would refer you all to the work of Jennifer Barclay and Professor Deboster for some of these arguments.
Something I'm looking at in my own work, beyond chattel slavery, ableism functioned as part of a way of thinking through how to dispossess indigenous communities of their land in the period known as conquest. And I think we are familiar with Johnson versus McIntosh, and in my current work I'm looking not only at the racist underpinnings of that decision, which refused to recognize the property interests and lands held by Native Americans, and, indeed, labeled those lands as uninhabited, but also how those logics reinforced ableism. And in thinking about this, I think it's important, consistent with disability justice, to center settler colonialism in, again, an understanding of how both racism and ableism constructed property law doctrine.
So I think one thing to note is with DisCrit, we're not strictly talking about just disability law or just the ADA. But the category of disability across these areas of law. Hence the expansive approach. Hence the approach to American law more broadly.
The second tenet of DisCrit acknowledges multidimensional identities. Instead of singular notions of identity, such as race, disability, social class, or gender in isolation. This again might start to look like disability justice, that the principle emphasizes the importance of intersectional approaches that include disability as a relevant category -- (audio cutting out) -- coordination or social harms, and we have to also build in disability in our analysis. So for example -- sorry, it looks like my connection is a little unstable.
All right. So for example, Professor Kat Perez applies a disability race studies DisCrit to examine policy to shed light on the experiences of disabled people of color and center these experiences in the immigration reform debate. So again, another cite of that piece is in the UCLA Law Review.
As Perez writes, her work aims to present the work of the National Coalition for Latinx People with Disabilities as an exemplar of how grassroots disability justice movements are complicated our understanding of disability and prescribing more complex solutions to the immigration debate. Again, disability justice and DisCrit as a way of surfacing progressive immigration reforms.
The third principle of DisCrit is that it rejects the understanding of both race and disability as primarily biological facts and recognizes the two as social constructions of society's response to differences from the norm. And I've referred to this earlier in my remarks.
I have used that particular insight, and I know others of us have in our work as well. But to really think about how legal doctrine in particular legal doctrine dealing with social meanings of race and disability, the failure to engage with that construction, that coconstruction, contributes to the failure to adequately protect disabled people of color. And I found this to be particularly true in looking at fourth amendment case law. And so in my work in a recent paper disabilities fourth amendment -- there actually are no other slides; it's just this one. So the particular focus on the fourth amendment I think is important as the constitutional protection against policing or violations of the sort of privacy and security interests of all of us, and also given the concerns around police violence and its impacts on disabled people. And so in my assessment, if we think about both race and disability in discussions about the problem of policing, we can better understand how the fourth amendment is limited in regulating police officers and also think through more expansive protections to respond to those harms. So it's an approach that, again, reframes the nature of the injury and offers a pathway for more expansive remedies to respond to the unique vulnerabilities of individuals at the margins, as we say in intersectional theory or disabled people of color in this particular case.
So the last two, and I'll turn it over because I've been going through this, just to walk us through the main principles and offer some applications, tenet 4, again, all of these are in the article, but principle 4 of DisCrit is to disrupt the tradition of ignoring the voices of traditionally marginalized groups. I think this is consistent with disability rights movements and focusing in on including the voices of people with disabilities and centering that in our discussions of law. I've brought in those insights into thinking about 8th amendment conditions of confinement jurisprudence, where we see advocates very likely unintentionally decentering the voices of disabled people, but I think more to the critique, reinforcing medicalizing of disability in a way that reinforces ableism. And I'll talk about that more, but I have an article that's discussing the ways in which advocates might not only obscure the voices of people with disabilities, experiencing the harms of imprisonment, but reify ableism by focusing in on individual deficiency models of disability that root the person's inability to reside safely within the prison walls in that person's own limitations rather than the harmful systems and policies and practices of that carceral space that are contributing to those harms.
The last two principles of DisCrit, again, I think are perhaps familiar to many of us who are educate and rooted in disability practicing in disability rights movements, principle 5 considers legal ideological and historical aspects of disability and race to see how both have been used separately to deny the rights of certain citizens. I mean, we can think about the eugenics period most notably as an example of that, that disability and race history or history of racism is familiar perhaps to many of us.
And I think the other tenet which talks about how, as those that are supporting DisCrit as an analysis in law, we should make sure that we're operating in tandem with or led by movements. So activism and diverse forms of resistance are part of the DisCrit approach. Movement-based activism led by disabled people should inform the legal remedies that we seek but also the way that we talk about these particular forms of disability-based discrimination and subordination.
And just kind of in the last few minutes, I do have, again, some specifics with respect to how this critical analysis can inform how we think about legal injuries and also remedies in the policing context. And I'll save those comments for the subsequent discussion. But I'll stop there. Thank you.
ROBYN POWELL: I want to first thank Professor Chin and Morgan for inviting me and everyone here on a Thursday afternoon for the last session. Thank you.
I am a white woman in a wheelchair. I have shoulder length brown hair. And I am in my office. Behind me is a poster of Ruth Bader Ginsburg and a poster of Angela Davis. So I want to, again, really thank you all for coming. I think this is an important conversation and one in which I have only more recently started to think about. So I of course went to law school like a lot of you to become a disability rights lawyer and I thought that the ADA alone could fix everything. I have come to appreciate that we really, while the ADA is wonderful in many ways, it has left behind several people and it just can't address all of the issues that we do experience. And I think that that is why we need to really reimagine how we pursue equity for all people with disabilities, particularly those who have been left behind, whether it's people of color, whether it's LGBTQ people with disabilities, whether it is people with intellectual or psychiatric disabilities who we have really left behind in a lot of ways. So I really encourage us to think broadly about this.
So I am going to talk about ensuring reproductive justice for people with disabilities.
Next slide, please.
On this slide, I have three photos that I want to briefly describe for accessibility purposes. The first one is a photo of Carrie Buck and Emma Buck. Of course Carrie Buck is well-known, the Buck v Bell case, we all know about her, I hope. The second picture, more recently, is from a protest outside of the Supreme Court during the Dobbs hearing in December. And the third one is Britney Spears. And you may be wondering what the heck they have to do with each other but they're very much connected which I will establish.
On the slide it lists several ways, five ways really that I think really demonstrate the ways that people with disabilities continue to experience contemporary reproductive oppression. And I'm going to go through all of those in a moment. But I just wanted to explain that.
Really I think it's not shocking to anyone that's here that the fragility of reproductive rights in the United States has really never been so clear from this really rapidly growing number of states passing these really antiquated laws that are limiting and banning abortion access altogether to a Supreme Court really opposed to overturning Roe vs. Wade in the spring. I think we've seen reproductive freedom is under siege at every turn, which has led to an enlightened conversation I think around reproductive rights and it's come to a lot of people's forefront. But I think at the same time it's important to understand that the reproductive rights movement has always been narrowly focused and really failed to recognize the scope of reproductive decision making beyond abortion. And the second is really that this movement has overlooked the myriad other ways that marginalized populations, including people with disabilities and other historically marginalized groups, experience reproductive oppression. And when we think about abortion rights or other reproductive rights, we almost always are brought into these conversations about fetuses with disability diagnoses and we don't think about actual people with disabilities needing reproductive rights and healthcare. So I want us to actually think about the disabled people for now.
So I'm going to describe some of the examples of ways that reproduction is weaponized to really subjugate disabled people, especially those who live at the intersection of disability and other historically marginalized communities. But before I do so, I want to build off of Professor Morgan and Chin's description of disability justice and demonstrate why it's so important to look at the issues around reproductive oppression through these lenses.
Disability justice is really essential. I think it's essential for dismantling the reproductive oppression that marginalized populations such as disabled people have endured for centuries. Reproductive justice is justice. They have to go hand in hand. Ableism is a deeply rooted cause of disability injustice. Disability activists have explained that disability justice recognizes that access to information, quality healthcare, and autonomy and decision making are essential for the well-being of all. To ensure that disabled people are truly afforded choice, they have to have access to comprehensive and accessible sexual and reproductive health services and information, and they also need to be provided opportunities to make decisions about their bodies. Ultimately disability justice is essential because our existing laws and policies are just not effective at ensuring reproductive freedom for people with disabilities, particularly those who are multiply marginalized. It really is important to understand that our current disability laws are just not enough to ensure that people with disabilities enjoy reproductive freedom.
So in sum, I would say that disability justice provides this important roadmap for all of us to finally confront the reproductive oppression that people with disabilities have endured for centuries. And in addition to disability justice, I want us to also understand that we need to bring in reproductive justice when we're discussing these issues. This is something that was first conceived in 1994 by a group of feminists of color who really had conceptualized reproductive rights struggles were embedded in social justice issues, and you had to be able to challenge racism and classism and other types of oppression in order to ensure reproductive freedom for all. And reproductive justice goes beyond our traditional understanding of reproductive rights in two notable ways. First, reproductive justice acknowledges the importance of choice while also recognizing the broader social, legal, and institutional structures that affect people's reproductive decision making. And second and importantly, reproductive justice applies to all aspects of reproductive freedom, not just abortion rights. So it encompasses not only the right to have a child but also to not have a child, or to raise a child with dignity and safety and in a supportive community. So like disability justice, reproductive justice really does move us beyond a focus solely on reproductive rights and really encompasses this integrated approach. So you can see that it really does complement disability justice in so many ways.
So why did I put a picture of Britney Spears there? Well, I think her battle to end conservatorship actually illustrate a common way that reproductive autonomy is denied to disabled people and reinforces why we need to take this comprehensive approach. I'm sure everyone knows, but in her case, in 2008 she experienced a mental health crisis and subsequently was put under a conservatorship or guardianship. And during that time, several years later, she had no control over her life. She didn't get to decide what she did, who she saw, how she spent her money, much like everyone else that's put under these legal mechanisms of control. And finally in June of 2021, Britney Spears stunned the world, although I would say not disabled people, when she delivered this heart breaking statement where she really pleaded for the judge to end her conservatorship. She lists these many egregious acts that she had experienced. And among all of these injustices, one that was particularly important to note and I think especially egregious was that she wanted to get married and have more children but she was not able to do so because her conservators would not authorize the removal of her IUD, her contraception. And luckily because she's Britney Spears and she has a huge amount of resources and a platform, she was successful in finally having her conservatorship terminated in November. While this is great, I think it really still calls upon us to really not forget these issues and we really need to recognize that these issues affect lots of disabled people.
So as I said, there are many ways in which people with disabilities experience reproductive oppression today. And I will briefly mention a few examples.
The first one is really this idea of sexual and reproductive health disparities. Disabled people experience a range of unmet sexual and reproductive health needs. They don't get access to sexual education. They have low rates of access to contraception. They do not get screened adequately for sexual reproductive health needs. They experience a number of barriers when seeking reproductive healthcare. And we know that because of all of this, disabled people experience poor outcomes particularly related to maternal and child health. And all of these disparities are even worse for multiply marginalized disabled people, and that's particularly relevant because we know that there's a real crisis in our country where Black people are dying when giving birth. And so we have to recognize that and how that intersects with disabled people.
The second thing is really the scarcity of comprehensive and accessible sexual education. And really people with disabilities don't have access to adequate special education, schools omit it often from the special education curriculum. And this is really especially important I would say for LGBTQ+ people with disabilities who are often denied just necessary information. They're not provided sex ed. And when they are, it's very heteronormative and we don't talk about different sexual orientations. So the other thing I would say about our approach to sex ed right now, it's really reactive rather than proactive. When it's provided, it's very much based on abuse prevention, it's usually the result of some sort of incident, and it's not really being proactive and really allowing people with disabilities to understand all of their rights and experiences and what they can experience.
The third thing I would say is just this denial of reproductive decision making. I think that the Britney Spears example just catapults that and really shows exactly what happens. And I will say that there are so many cases in which courts and guardians are seeking to force sterilization or contraception on people with disabilities based on their, quote/unquote, best interest. And/or for their safety. There's this myth out there that people with intellectual disabilities need to be sterilized because it will prevent sexual abuse. That makes absolutely no sense. But that's a real justification that's used in the courtroom.
Next one I want to mention again is barriers to contraception and abortion. I will say for people with disabilities, this conversation invokes this complicated history because I think it brings into focus these deep and really enduring assumptions that people with disabilities don't belong in these conversations, that they're rarely seen as sexual beings or as potential parents. We could have a whole day just about these tensions that exist, but I will say that we need to ensure that all people with disabilities have choice. So what we see now is on the one hand, a lot of disabled people are forced to terminate pregnancies or to use contraception, and on the other hand, we know that some disabled people don't have access to contraception and abortion care. What brings those two groups together is that both groups don't have choice or access. We know again that for people of color and for people who are very low income, which is a lot of people with disabilities, abortion care and contraception is becoming less and less accessible. This is going to deeply affect people with disabilities.
Next is just restrictions on sexuality. People with disabilities are often denied opportunities to be sexual beings. They're seen as either sexually unwilling or unable or seen as hyper sexual, and all of these beliefs have led to a lot of people with disabilities, particularly those who live in congregate settings from being denied opportunities just to explore their sexuality. As professor Chin wrote, she talked in an article about group homes denying people with disabilities to engage in intimate relationships, to get married, to have a family. And for LGBTQ+ disabled these issues can be amplified and these people have been denied opportunities. In group homes they're seen as sexually deviant if they suggest that they are LGBTQ+. So we really need to ensure that these issues are addressed.
And lastly, threats to parenthood. Right before this, there was a wonderful workshop on parents with disabilities and the child welfare system which I really am adopting Dorothy Roberts' term the family policing system because that really is what it is. It is a system that has surveilled, policed, and controlled marginalized communities including disabled people. We know that parents with disabilities are more likely than other parents to be referred to the family policing system, and once involved, they experience strikingly high rates of termination of parental rights, they're more likely to have their children removed and placed in foster care. And all of these barriers are especially amplified for Black mothers and their children. Black mothers are more likely to be monitored, regulated, and punished by the family policing system and more likely to lose custody of their children. So when looking at these issues, I would call on us to understand the role of ableism, the role of racism, and the role of other types of oppression in how these reproductive oppressions can't be challenged and finally confronted until we take this intersectional approach.
And with that, I am turning it over.
NATALIE CHIN: I think it's your turn to talk about policing, Professor Morgan.
JAMELIA MORGAN: Sure. Maybe just to build on some of what I said earlier, because I think Professor Chin, as you noted, much of this can sound very theoretical. And it is. We're talking about theories. Disability justice is central to what we're talking about today. DisCrit. Both of those theories I think can be used to inform a critique.
In my work I've looked at both the limitations and possibilities of the ADA and the policing context. I think as disability rights lawyers, disability justice, lawyers, attorneys, advocates, etc., we can see those two framings, right, the possibilities and the limitations.
In terms of the possibilities, in my work I found that the kind of medical understanding of disability undercuts the potential of the ADA to build upon the very low constitutional floor of the fourth amendment. So the Fourth Amendment is a terrible tool at regulating the police. That's well established within fourth amendment scholarship. The Americans with Disabilities Act offers a way of using the category of disability as a way to respond to the problem of placing, which is to say more specifically the reasonable accommodation requirement, this notion of individualized consideration, I guess I'm arguing that those are offering expansive possibilities for how we think about namely reducing the violence, the police violence, that we've seen inflicted on people with disabilities.
But again, the insights from DisCrit and disability studies in particular have shown me that not only are courts limiting that potential in how they think about disability as a medicalized understanding, to be cured, something that's problematized, even in the sort of circumstance or situation where police mistake an individual as engaging in criminal activity when they are in many cases acting in accordance with disability. And so for instance, you see the targeting of Deaf people who are not responding to police commands, the targeting of individuals who are in mental crisis for violence as opposed to treatment. So that's a complex set of topics, and I unpack that in the policing under disability law paper, but again, I think what we get from a DisCrit analysis to policing is sort of problematizing the linkages between disability danger, violence, and criminality, a way to unpack that, push back against those stereotypes, and yet respond to the problem.
I have another example I was going to offer to this in the prison context, but I want to cede my time since I was chatty in the beginning.
NATALIE CHIN: Actually, we're fine on time.
JAMELIA MORGAN: Okay. I'm arguing that for me this has been helpful in unpacking both the limits and possibilities and ADA of the policing context. I had a slide I was going to show.
NATALIE CHIN: Let me pull those up.
JAMELIA MORGAN: So what does DisCrit get us? I think what I've been really concerned with in my work in recent years is, again, how as advocates we can resist stigma and resist stigmatizing disability even when we're advocating for clients with disabilities who are becoming disabled on account of these harsh prison conditions? There's a tension that I recognize in that concept. How do we avoid stigmatizing disability when our advocacy is identifying one basis or one outcome to be production of disabilities. That's a tension. And I think that because of that tension, within this area of law, advocates have to be careful about how they discuss the disabilities that might be produced from these systems, these harmful jails and prisons that many have written about. I think it's a similar set of issues if we think back to the period of chattel slavery. If we surface disability, it has to be understood that we're not surfacing disability to stigmatize it. It's just to identify the contours of racism and ableism. So I'll be concrete because I'm prone to thinking conceptually a little too much.
So this is an example. I spend much time going through complaints. It's never to embarrass any advocate I know. The work is hard. I change the names and alter the facts. But to show you what I mean, when we think about, again, the ways that disability can be stigmatized even in this particular context, I'm going to point to an example. Okay. So here's actually taken from a paragraph of a complaint, 1983 complaint against a jail.
So I won't surface sort of the particular legal claims in this complaint. It's an 8th amendment complaint. It's also raising due process violations given the loss of good time credits. But I want to note again the deficiency framing. Disability is a part of or the implied cause for some of the problems that we can say Jack is facing while incarcerated. What can be implied is that Jack's disability starts and is exacerbated by the prison's failure to provide him with adequate mental health treatment or by the harsh conditions of imprisonment itself. Right? That's a part of the claim. That is a part of the legal injury, which will need to be alleged in the complaint, and then also pointing to the remedy.
The next slide, I've tried to reframe that to move it away from a deficiency framing into one that, again, recognizes that what is identified in this particular complaint or problem, or the institution's responses to the person with a disability. So what would it look like to now shift to the structures, again, the social aspect of disability, that is leading to the discrimination and subordination alleged? One way of reframing it would be:
So it's just, again, taking the facts as given, a way of focusing in on the structures, the policies and practices contributing to the alleged legal injuries as opposed to the individualized deficiencies of the litigant at issue in this case. And I do want to also shout out the work of Lydia Brown who has helped me think through the concept of ableism in our language. I do think that the sort of disability frame could be helpful here, again, in identifying the nature of the injury, but there has to be a sensitivity to how we employ sort of that frame in describing in particular harsh conditions as producing disability because we don't want to stigmatize disability in our kind of quest to identify the particular injury that our clients are facing.
Yes, thank you. One other thing I want to announce as well. As a result of the prison failure to provide reasonable accommodations to Jack while in prison, he received disciplinary tickets. So that would be a framing that comes in through the ADA if that's kind of alleged in this particular complaint as well.
I think that's it.
NATALIE CHIN: Great. Thank you, Professor Morgan. My 3-year-old here.
What I wanted to talk about next were some of the shortcomings of the ADA. So this really, what I'm about to talk about comes from an article I wrote called Centering Disability Justice. I wrote this during COVID when I was frustrated with the conversations around COVID not being centered around disability or race. So I just wanted to do a preliminary look at the way that certain issues seem to have this revolving door and that the way that how the ADA is either addressing or not addressing those issues. And think about not having answers per se but trying to identify to what extent is race discussed as part of the disability framework. So here I looked at four different issues when I was writing this paper. And the first I looked at, I know some people here on this call -- one second. I'm so sorry.
And so when I was looking at this (child screaming in background) -- you know what we're going to do? Robyn, I'm going to hand it to you and I'm going to come back. I'm so sorry.
ROBYN POWELL: No worries.
All right. So thank you. I want to talk about now what do we do. I've just given you lots of bad news, so I want to really make it tangible what we can do about this. And I want to revisit, again, the definition of reproductive justice because it is different than reproductive rights and I want everyone to understand that. Reproductive justice does not just mean that people have the right to not have a child. Meaning abortion or contraception. It also means that people have the right to have children and that they have the right to parent those children safely and with dignity and support. And those concepts are particularly important. And there's a saying in the disability community that disabled people are particularly fighting for the right to have children. That is why I think disability justice and reproductive justice really work hand in hand. So I really want to emphasize that reproductive justice and what I'm talking about is not just the right to not have a child but also the right to have children, often denied to people with disabilities.
So I think we need to embrace this in order to make transformative change. And I want to identify five areas in which I think we can do such a thing. And that's what's on my slide right now. There's an image of different cartoon images of people and they're holding signs about disability justice now and reproductive justice. And so I think the first way we can achieve reproductive justice through legal and policy solutions is that by making sure they're aimed at disrupting the intersecting oppressions experienced by multiply marginalized people with disabilities. And while all disabled people do experience a range of threats to their reproductive freedom, whether to have a child or not or to parent one's children, these injustices are amplified for disabled people of color and for LGBTQ people with disabilities. And therefore consistent with this, we need to ensure that all of our efforts are centered on disrupting intersecting oppressions. We need to ensure that we are working towards ensuring that everyone, particularly those who are the most marginalized, have access to their necessary supports and more importantly to their freedom.
The second way, and something we've mentioned a few times, is by actively engaging people with disabilities. Again, especially those who have been excluded from these conversations. We know that in order to come up with actual solutions that can help, we need to listen to, engage, and develop affected communities. And that is consistent with both reproductive justice and disability justice. And as I mentioned earlier, there are really known tensions, things that have gone wrong in these conversations. And I think that there is some movement here. We're starting to see if these communities are coming together and we need to ensure that we're not only centering disabled people as the leaders and actively engaging them, but also really moving towards cross-movement solidarity. We need to work with other communities to ensure that we are fighting for reproductive justice for everyone.
The third way is focusing on making sure people with disabilities are guaranteed the right to autonomy and self-determination. And really we have to remember that these concepts around autonomy are really what drive our constitutional doctrine concerning reproductive rights. Yet like the Britney Spears example shows, people with disabilities are not experiencing autonomy reproductively, which talks around questions of consent and whether people with disabilities have the capacity to explore their sexuality and all of these other things. So we really need to work towards developing and implementing legal and policy responses that can ensure that people with disabilities have their right to autonomy and self-determination and we can do so through supported decision making, making sure that it's widely available, and also making sure that people with disabilities are really just granted all of these rights. And also I would say we have to end the school to guardianship pipeline. We have to stop this process where people with disabilities become 18 and the schools are encouraging their parents and saying, this is the next thing you have to do. It has to stop becoming a rite of passage.
Fourth, we have to make sure that all sexual and reproductive health services and information are accessible, not only complaint with the ADA but accessible as far as transportation. We need to ensure that people with disabilities access financially to services, we need to ensure they have access to comprehensive sexual education, information on sexual violence, pregnancy prevention, STDs, everything needed to be able to make a decision for themselves.
And the other thing I will say is this will also require some policy making changes. I'm not sure how many are familiar, but we have the Hyde Amendment right now which prohibits federal money going towards abortion care meaning folks on Medicaid do not have access to abortion care if they cannot pay for it themselves. That needs to be addressed.
We also need to recognize the effect of this. If you don't have access to transportation, if you are poor, you don't have access to reproductive autonomy. And one of the interesting ways that we've actually seen some movement as of late because of COVID is this shift towards telehealth. And that is one example but not the only example in which we need to really ensure that we're opening up opportunities.
And finally, disabled people must be ensured rights, justice, and wellness for themselves and their families. It's impossible to effectively respond to the reproductive oppression experienced by people with disabilities without considering how our current laws and policies undermine reproductive justice and what I'm talking about is the ways in which we have these antiquated laws and policies that force people with disabilities into poverty, they force people to not be able to get married, we also have what I mentioned earlier, which is this child welfare system, this family policing system, which is really just surveilling and punishing people with disabilities and other parents. And it's not necessary. And while I think the ADA is really important when you're involved with the family policing system, my goal in life and I hope everyone else's is to not have that involvement. And the ADA can't stop that involvement. With have to change our policies so that families are supported.
So while it's a challenging time for reproductive rights in the United States, I think it's also a time of immense possibility. I think using disability justice to ensure reproductive freedom for people with disabilities is the answer forward.
With that, I am turning it over.
NATALIE CHIN: Thank you, professor Powell. I want to leave time for questions but I want to maybe spend 5 minutes to go back to what I wanted to talk about in terms some of the shortcomings of the ADA. So during COVID I did this preliminary look at anti-Black racism and disability and parse out a few cases that developments happened that particular year. So here at the Judge Rotenberg Center, many of you may know this is a psychoeducational school in Massachusetts and enrolls over hundreds of students who have behavioral issues or are on the autism spectrum. It's one of the few schools that uses electric shock to control behavior. The year I wrote this, in 2020, the FDA had decided that they were no longer going to allow this center to use electric shock but shortly thereafter, the FDA had that overturned by the court and they can use electric shock. But I looked into this because I wanted to understand the school that had been around for years and had this horrible reputation, like why is it so hard to shut this place down. And I did an analysis of the population and started to crunch the numbers and learned from 2002-2018 students of color identified by the school as Indian, Alaskan native, Asian, and Black, made up 80% of the population. The increase was up from 60% years before. So this is a disability rights issue but also a racial justice issue. I went back to look at some of the pleadings, the news articles, all these different analyses of JRC, and there was very little mention of race. There was only mention of disability. I think when we're talking about disability justice, intersectional analysis has to come in because we cannot get the remedies that we seek or we're going to have this revolving door if we just stale in the lane of disability rights. You know, Lydia Brown has done a ton of work on JRC. There's a particular blend of ableist targeting at JRC, she writes, calling into question how and why so many activists working publicly against JRC have no understanding of the racial implications of JRC's population and overt ties to the criminal punishment system. They recruit students from Rikers and these pipelines of the prison pipeline. I thought, we have to think more broadly. And then I also looked at the GNETS case, the Georgia Network for Education and Therapeutic Support. Very similar to JRC. It's a psychoeducational school. There's two lawsuits going on now. This network serves about 5,000 students between the ages of 3-21. And the Department of Justice spent 5 years investigating GNETS. You can see a young Black boy on the slide in the middle receiving electric shock and another slide on the top. That says at the JRC you can be painfully shocked for rubbing your nose. GNETS houses a similar demographic as JRC. Students are put on dog leashes sometimes. They don't do that anymore. Students are housed in aging buildings that were once Jim Crow era buildings. They are physically restrained 10,000 times more. And there's so much more to it. So then I was like, well, let me crunch the numbers here and look at this. GNETS, majority of students are Black and brown. So when the DOJ did a 5-year investigation, I looked through their very long investigative findings that GNETS violated Title II of the ADA, and there was no mention of race whatsoever. The discussions of the intersections of race and class showed very little in the pleadings. As was just mentioned, we need to think about how are we perpetuating ableism in our advocacy? The intersectional impact of systemic racism and classism, how are we encouraging that with our clients? There's a necessity to really expand our disability rights lane and think of these issues as racial justice issues, as poverty rights issues because these are the same inequities happening I think primarily to disabled folks with disabilities who are Black and brown.
And last 2 minutes, in terms of a way forward, I don't want to repeat a lot of what Professor Powell said, but the three tenets that I talked about, the three principles of disability justice I think we can yank out and try to focus more intentionally in disability rights, one is examining how intersectionality interlaces with our advocacy approach. So thinking about our strategic planning and litigation and how this intersectionality plays into our framing, into our decisions of centering the voice which is the second principle of disability justice. Centering the leadership and voices of the disabled community most impacted by the harm.
And lastly, emphasizing the intentionality needed to build and sustain cross-movement solidarity as an essential tool to penetrate through the oppression. The importance of cross-movement building. I know Professor Morgan gave you a bad complaint. I want to give you a good one. This is the Kemp case which was filed I think in 2020. And this is the voting rights case. This exemplifies this in a way, I mean, you can think of this as reformist reform, the status quo working within the system. What this complaint did well is it reflected, it foregrounded intersectionality with the different voices brought into multiple page complaint, engaging deeply with the past history when it presented its legal claims and really engaged with the community's voices in the complaint, which is 87 pages. So you could tell that this complaint was an education tool. It brought in so many different factions of the community. African women, Muslims, disabled people of color. It brought in this historical relevance of voting rights all in this really compelling narrative. And I think oftentimes as practitioners and advocates, we shy away from bringing in that intersectionality or centering the voices of those most impacted because perhaps it doesn't support our primary claim. But we can build upon that. We can build upon that to support our primary claims and also to educate the court when we're working within the confines of the ADA or the limitations of a rights-based framework which is disability rights. But lifting that up with disability justice principles is an example of pushing the way forward and becoming more and more sort of radical in how they want to do this.
So I want to end there and encourage folks to please, we have 8 minutes. And I don't know if the moderator is there if folks want to ask some questions. So thank you everybody for being so wonderful during this time.
LOU ANN BLAKE: Thank you very much for this really important discussion. Wonderful way to end our first day.
Folks, if you have questions, please put them in the chat or feel free to unmute yourself and ask your question.
ARLENE KANTER: This is Arlene Kanter. I'll ask a question. I don't have a camera. I just want to say that this was one of the best panels I've heard in a long, long time. It was fabulous. And I really appreciate the creativity and originality of the speakers.
I wanted to follow up on something that Jamelia raised: How to identify disability. An example you gave of Jack in prison without stigmatizing disability. How to use disability as an asset without stigmatizing disability. And how to recognize the importance of disability as a contribution to diversity without stigmatizing disability.
And I have no answer to provide. I only have the recognition that this is such an important question, that I don't think we've adequately tackled in both the disability rights movement, the disability justice movement, among people who have disabilities or allies. And I hope that we can continue this conversation of how to incorporate a disability justice and DisCrit perspective to the question. So I just -- that's what I've been thinking as I've been listening, and I want to thank all of you for just a fabulous, fabulous session.
NATALIE CHIN: I see one question in the chat.
I think that the heart of the question actually is moving outside the legal framework to get to the intersectionality of these issues and build upon building that narrative, for example, to center your client and bring in the systemic issues that are perhaps a part of the underlying claims that you're bringing. And so I want to -- I don't know if that's clear, but I think that this complaint that I mentioned actually does a pretty decent job, and I want to just put it in here. I do think we get really focused on, okay, how can I use this law to highlight the intersectional aspects, but that creativity and looking at these principles of disability justice is forcing us to reimagine that and look outside of that. But I'll ask Professor Morgan and Powell their thoughts.
JAMELIA MORGAN: So I'll jump in really quickly. I think, and just to echo something that Arlene just said as well, which is a lot of these questions I think need to be worked through collectively as a movement, as attorneys, advocates kind of focused in on ending social oppression against disabled people. And so I echo what you said, Professor Chin, the creativity comes in ignoring some of the silos, or resisting them, at least in how we think about disability across areas of law. And so in the community that I'm in and practice in, prisoner rights, you know, I read complaints, we read them collectively, we focus in on language. We're very well aware of the legal standard in our showing, at least in surviving a motion to dismiss or depending on as we progress through in the litigation. But I think that especially as trained lawyers, we are wordsmiths with language. Like there's a way that we can tell the story in a particular way that doesn't reinforce stigma, but then the complexities of what are stigma-enforcing sort of languages or even thinking about how to paint the overall social context in a way that doesn't stigmatize is a part of the theorizing I think we have to do as a movement.
And just to put a plug in for the PENWA edition looking at disability frame, Jasmine Harris and Karen Tawny pulled a number of disability law scholars together to talk about this very question. Like what are the productive and stigmatizing uses of the disability frame across all these areas of law. So there's some thinking happening there and those are very much informed by movements on the ground and how they tell their stories and how they're pushing for change in coordination with namely abolitionist movements, if I think of the prison and policing work that disability justice advocates are doing, Professor Powell, could you probably speak to reproductive justice and the organizing there. So these are things we have to sort through. I don't feel comfortable saying this is what we have to do, but just it's a framework for analysis, but there's tension still.
ROBYN POWELL: Yeah, I would agree. Two things I was thinking about, first of all, what Professor Kanter said reminds me of my legal aid days and the way disabled people were described when they were trying to get social security was very ableist. And I think it's something we all have to struggle with. It comes up in my disability law class a lot.
But first I would say, there was a great case a few years ago and I cannot remember the name. And I'm not even sure of the outcome. But it was in New York and it involved several mothers with intellectual disabilities who were also women of color. And Professor Chin might know the case better than I do because she's actually in New York but it was brought against the child welfare system, ACS. And what I liked about it -- I don't like the case, but I liked there were a lot of amicus briefs that came in from Sister Song and other reproductive organizations who framed this as this is just another example of the oppression we have really inflicted on people of color, disabled people, etc. And how the family policing system is just an extension of a history in which we've always assumed that those individuals, whether disabled people, people of color, especially disabled people of color, are socially unfit and should not be reproducing. And they really contextualized the issues in such an important way.
And my second point, I have a paper coming out soon in the Yale Journal of Law and Feminism and it actually calls for the abolition of the child welfare system through a disability justice lens. And in it I go through in one area sort of how you can use this in your litigation. So when you're dealing with elimination of parental rights legal cases. Contextualizing the cases. So when you're defending a parent, really showing how the child welfare system is just an extension of systems that have policed and surveilled and oppressed. And you can emphasize that in your litigation. I go through it in much more depth than I am right now because it's 5:30 but I think it's just something we have to call it what it is. This is surveillance. This is policing. This is racist. And this is ableist. And I think we have to start calling things for what they are more.
NATALIE CHIN: That's why I think it's important when it's relevant to bring in that history and tie that in to exactly what Professor Powell is saying because it's not superfluous. It's a different way of lawyering.
LOU ANN BLAKE: All right. Thank you all so much for a fabulous panel. I'm sure we could keep going quite a bit longer if we had the time.
Karl, were you able to troubleshoot the issue with the video?
KARL BELANGER: Yeah, I have a way we can do it.
LOU ANN BLAKE: Okay. We have a very short one minute sponsor video from Burton Blatt Institute. So thank you to Burton Blatt. And if you can hang on for one minute, we'll show you the video.
[Video - captioned]
KARL BELANGER: And there we go.
LOU ANN BLAKE: Thank you, Karl.
And thank you all. It's been a fantastic day. We'll be starting back tomorrow for Day 2 at 11:00 a.m. Eastern with workshops. Please take a look at your agendas for the workshops and the Zoom links, and we will see you all then. Thank you so much.