AuthorTitleCitationSummaryYear
Christopher W. Behan Everybody Talks: Evaluating the Admissibility of Coercively Obtained Evidence in Trials by Military Commission 48 Washburn Law Journal 563 (Spring 2009) We have ways of making men talk. Modern coercive interrogation techniques are devastatingly effective. Skilled interrogators can break even the most hardened subject by engaging in a concerted attack on his psyche. Notorious torture machines such as the rack or the iron maiden have been replaced by an ingenious system that relies on psychological... 2009
Duane H. King, Ph.D. Exhibiting Culture: American Indians and Museums 45 Tulsa Law Review 25 (Fall 2009) As long as museums have been in this country, American Indians have been represented in them. How Native American subjects have been treated by museums over the years has changed considerably. Much of the change I have witnessed firsthand. I entered the museum profession over 40 years ago. My first museum job, as a teenager, was scrubbing potsherds... 2009
Matthew L.M. Fletcher Factbound and Splitless: the Certiorari Process as Barrier to Justice for Indian Tribes 51 Arizona Law Review 933 (Winter 2009) The Supreme Court's certiorari process does more than help the Court parse through thousands of uncertworthy claims--the Court's process creates an affirmative barrier to justice for parties like Indian tribes and individual Indians. The Court has long maintained that the certiorari process is a neutral and objective means of eliminating patently... 2009
Matthew L.M. Fletcher FACTBOUND AND SPLITLESS: THE CERTIORARI PROCESS AS BARRIER TO JUSTICE FOR INDIAN TRIBES 51 Arizona Law Review 933 (Winter 2009) The Supreme Court's certiorari process does more than help the Court parse through thousands of uncertworthy claims--the Court's process creates an affirmative barrier to justice for parties like Indian tribes and individual Indians. The Court has long maintained that the certiorari process is a neutral and objective means of eliminating patently... 2009
Merritt Schnipper Federal Indian Law--ambiguous Abrogation: the First Circuit Strips the Narragansett Indian Tribe of its Sovereign Immunity 31 Western New England Law Review 243 (2009) Chief Sachem Matthew Thomas got up and put on a shirt and tie. The Narragansett tribe leader expected to end the day in federal court, where he would confront the Rhode Island officials who were attempting to shut down the tribe's tax-free smoke shop. But when Tribal Councilman Hiawatha Brown called at one in the afternoon to say that a convoy of... 2009
T. Haller Jackson IV FEE SHIFTING AND SOVEREIGN IMMUNITY AFTER SEMINOLE TRIBE 88 Nebraska Law Review 1 (2009) I. Introduction. 2 II. (Very) Brief Histories. 6 A. 42 U.S.C. § 1983. 6 B. 42 U.S.C. § 1988. 9 C. The States' Eleventh Amendment Sovereign Immunity. 11 III. The Full Contours of the Problem. 16 A. The Practical Context. 16 B. The Doctrinal Background. 19 C. The Near Misses in Precedent. 23 IV. Easy Answers Dismissed. 26 A. Personal Capacity... 2009
Kevin K. Washburn Felix Cohen, Anti-semitism and American Indian Law 33 American Indian Law Review 583 (2008-2009) Architect of Justice: Felix S. Cohen and the Founding of American Legal Pluralism. By Dalia Tsuk Mitchell. Ithaca and London: Cornell Univ. Press. 2007. Pp. xi, 368. On the morning of Wednesday, November 1, 1939, a bright young government lawyer who had been detailed to the United States Department of Justice was summoned to his supervisor's... 2009
Carole Goldberg Finding the Way to Indian Country: Justice Ruth Bader Ginsburg's Decisions in Indian Law Cases 70 Ohio State Law Journal 1003 (2009) Two tax cases notably mark the distance, in Indian law terms, between Justice Ruth Bader Ginsburg's early and later years on the United States Supreme Court. In the first case, decided in her second term on the Court, Justice Ginsburg wrote for a majority, rejecting tribal members' claim of exemption from a state income tax. It was her first Indian... 2009
Alex M. Hagen FROM FORMAL SEPARATION TO FUNCTIONAL EQUIVALENCE: TRIBAL-FEDERAL DUAL SOVEREIGNTY AND THE SIXTH AMENDMENT RIGHT TO COUNSEL 54 South Dakota Law Review 129 (2009) The dual sovereignty doctrine reflects the bifurcated structure of the federal system, but it also incorporates individual Indian tribes as unique third sovereigns within that system. Recently, the doctrine's application to the Sixth Amendment right to counsel has split the federal circuit courts and revealed a conflict between adhering to the dual... 2009
Larry Cata Backer From Hatuey to Che: Indigenous Cuba Without Indians and the U.n. Declaration on the Rights of Indigenous Peoples 33 American Indian Law Review 201 (2008-2009) Indigenous peoples have been quite useful to political elites in Latin America almost since the time of the conquests by Spanish and Portuguese adventurers in the fifteenth and sixteenth centuries. In the nineteenth and early twentieth centuries, indigenous people supplied the foundations for a trope, both literary and political, essential for the... 2009
Brooke Delores Swier Gaming Goldmines Grow Green: Limited Gaming, Good Faith Negotiations, and the Economic Impact of the Indian Gaming Regulatory Act in South Dakota 54 South Dakota Law Review 493 (2009) During the late 1980s, South Dakota gradually began to legalize various types of gaming, most notably casino-style gaming in Deadwood. In 1988, Congress enacted the Indian Gaming Regulatory Act (IGRA) which provided Indian tribes with the ability to conduct gaming operations on tribal land if that state offered gaming. At the same time the IGRA... 2009
Kirsty Gover GENEALOGY AS CONTINUITY: EXPLAINING THE GROWING TRIBAL PREFERENCE FOR DESCENT RULES IN MEMBERSHIP GOVERNANCE IN THE UNITED STATES 33 American Indian Law Review 243 (2008-2009) Tribal membership rules constitute the self that is to self-govern, by defining the class of persons entitled to share in tribal resources and participate in tribal politics. Increasingly, tribal membership rules also define the class of persons who are the ultimate beneficiaries of United States federal Indian policy. In the modern era of... 2009
Travis Thompson Getting over the Hump: Establishing a Right to Environmental Protection for Indigenous Peoples in the Inter-american Human Rights System 19 Journal of Transnational Law & Policy 179 (Fall, 2009) Climate change is threatening the traditional way of life for indigenous peoples and the Inter-American Human Rights System declines to combat this growing problem by refusing to acknowledge a right to environmental protection for indigenous peoples. The Inter-American Human Rights System has thus effectively cut off the possibility of remedying... 2009
Jason Scott Zenor Gilbert V. Flandreau Santee Sioux Tribe: the South Dakota Supreme Court Assumes Jurisdiction, Overlooks Federal Indian Law, and Misapplies Constitutional Principles to a Tribal Nation 54 South Dakota Law Review 333 (2009) Longstanding United States Supreme Court precedent recognizes that American Indian tribes are pre-constitutional sovereign nations, and thus, are outside the dictates of federal and state constitutional principles. Similarly, the United States Supreme Court has held that internal tribal matters fall within a tribe's exclusive jurisdiction. However,... 2009
Jason Scott Zenor GILBERT V. FLANDREAU SANTEE SIOUX TRIBE: THE SOUTH DAKOTA SUPREME COURT ASSUMES JURISDICTION, OVERLOOKS FEDERAL INDIAN LAW, AND MISAPPLIES CONSTITUTIONAL PRINCIPLES TO A TRIBAL NATION 54 South Dakota Law Review 333 (2009) Longstanding United States Supreme Court precedent recognizes that American Indian tribes are pre-constitutional sovereign nations, and thus, are outside the dictates of federal and state constitutional principles. Similarly, the United States Supreme Court has held that internal tribal matters fall within a tribe's exclusive jurisdiction. However,... 2009
Christopher Kelty, Rice University Global "Body Shopping": an Indian Labor System in the Information Technology Industry Biao Xiang (Princeton: Princeton University Press, 2007) Virtual Migration: the Programming of Globalization A. Aneesh (Durham: Duke University Press, 2006) 32 PoLAR: Political and Legal Anthropology Review 156 (May, 2009) In April of 2001, I sat on the roof of an office building in Bangalore listening to Metallica covers sung by a band made up of IT (Information Technology) professionals in their twenties. My new friends regaled me with stories of their success, boasting of their enormous salaries and summer homes under construction in the countryside. To them, this... 2009
Dean B. Suagee Going "Code Green" in Indian Country 23-SPG Natural Resources & Environment 55 (Spring, 2009) Fundamental changes are coming as we move toward a post-fossil-fuels economy. Global climate change is a compelling reason why we need to shift to an economic order that uses energy efficiently and meets most of our needs for energy services with renewable resources. Meeting our energy demands through efficiency and renewables will also reduce our... 2009
Barbara McDonald How a Nineteenth Century Indian Treaty Stopped a Twenty-first Century Megabomb 9 Nevada Law Journal 749 (Spring 2009) The U.S. Defense Threat Reduction Agency (DTRA) created controversy beginning in 2006 when it announced its intention to detonate Divine Strake, a 700-ton fuel oil and fertilizer bomb at the Nevada Test Site (NTS). The DTRA maintained the purpose of the bomb was to advance conventional weapons, even though government documents had described the... 2009
  Indian Cigarette Sales Enjoined 15 CITYLAW 134 (November/December, 2009) Reservation smoke shops sold millions of untaxed cigarettes to bootleggers. Golden Feather Smoke Shop and other smoke shops located on the Poospatuck Indian Reservation in Mastic, New York, purchased millions of untaxed cigarettes from wholesalers and sold them at significantly reduced prices to nonmembers of the Unkechauge Indian Nation.... 2009
Alan P. Meister, Ph.D. , Kathryn R.L. Rand , Steven Andrew Light Indian Gaming and Beyond: Tribal Economic Development and Diversification 54 South Dakota Law Review 375 (2009) The timing of the South Dakota Law Review symposium on Economic Development in Indian Country coincides with the 20th anniversary of the Indian Gaming Regulatory Act of 1988 (IGRA), 25 U.S.C. §§ 2701-2721, the federal law that established the legal and regulatory framework for tribal government gaming. When Congress enacted IGRA, it codified... 2009
Brian Lewis, Raymond Campbell Indian Law a Needed Addition to the Arizona Bar Exam 45-MAY Arizona Attorney 34 (May, 2009) Bar examinations evolve over time, adding or omitting topics that wax or wane in relevance to law practice. Is it time for a new topic--Indian law--to be added to that test? We are currently in a comment period until May 20 for a proposed Supreme Court rule change. To understand the proposal better, we asked rule-change proponents to explain the... 2009
Johanna Sheehe Indian Patent Law: Walking the Line? 29 Northwestern Journal of International Law and Business 577 (Spring 2009) Every day countless lives are saved by drugs produced by pharmaceutical companies. These life-saving drugs demonstrate the incredible medical advances that can be achieved through research and development. These drugs, however, do not come cheaply. Pharmaceutical companies expect high returns from their successful drugs and rely on profits... 2009
Charles Carvell Indian Reserved Water Rights: Impending Conflict or Coming Rapprochement Between the State of North Dakota and North Dakota Indian Tribes 85 North Dakota Law Review Rev. 1 (2009) I. INTRODUCTION. 2 II. PRIOR APPROPRIATION: THE FOUNDATION OF NORTH DAKOTA WATER LAW. 4 A. Development of Prior Appropriation and its Adoption by North Dakota. 4 B. Application of Prior Appropriation on North Dakota Indian Reservations. 7 III. REJECTION OF STATE WATER LAW AND ASSERTIONS OF SOVEREIGNTY BY NORTH DAKOTA INDIAN TRIBES. 15 IV. WINTERS... 2009
Michael C. Blumm , Jane G. Steadman Indian Treaty Fishing Rights and Habitat Protection: the Martinez Decision Supplies a Resounding Judicial Reaffirmation 49 Natural Resources Journal 653 (Summer-Fall, 2009) In the nineteenth century, the federal government convinced many Pacific Northwest tribes to enter into treaties that would facilitate white settlement. These treaties resulted in tribes ceding millions of acres of homeland in exchange for the right to take fish from all the usual and accustomed places. Although it was assumed that the salmon... 2009
David H. House , Thomas Weathers Indian Tribes and Casinos 35-NOV Montana Lawyer Law. 5 (November, 2009) Some believe there is a judicial trend of restricting Indian law tax immunities. If so, this trend may be an offshoot of recent U.S. Supreme Court decisions chipping away at tribal sovereignty, or it may be influenced by a narrow and inaccurate view of tribes as rich casinos. As Montanans know, thinking of tribes as rich casinos ignores the... 2009
Danielle M. Conway Indigenizing Intellectual Property Law: Customary Law, Legal Pluralism, and the Protection of Indigenous Peoples' Rights, Identity, and Resources 15 Texas Wesleyan Law Review 207 (Spring 2009) Cultures live and cultures die. Cultures live by the transmission of law, knowledge, land, and resources from one generation to the next. Cultures die, in large measure, because of exploitation of peoples and the knowledge they possess. In reality, cultures are constantly under attack from politically-oriented societies bent on exterminating,... 2009
E. Rania Rampersad Indigenous Adaptation to Climate Change: Preserving Sustainable Relationships Through an Environmental Stewardship Claim & Trust Fund Remedy 21 Georgetown International Environmental Law Review 591 (Spring, 2009) C1-2Contents Introduction. 592 I. The Problem: Climate Change Harms to Indigenous Peoples. 593 A. Indigenous Adaptation to Climate Change. 593 1. Introduction to the Problem. 593 2. Recognition of Need for Special Protections for Indigenous Peoples. 595 B. Achieving Preservation & Restoration Through Litigation: Current Inadequacies. 597 1. Case... 2009
Jason Gray Indigenous Communities and Biodiversity Conservation: Protected Areas and the Right to Consultation 12 Gonzaga Journal of International Law L. 3 (2008-2009) I. Introduction . II. The Importance of Biodiversity to Communities in Gabon and Panama . A. Two of Gabon's Rural Communities Have Long Depended on Biodiversity for Their Culture and Livelihoods i. The Balumbu of the Ndougou Lagoon . ii. The Bavili of Loango . B. Two Communities in Panama Traditionally and Currently Rely on Their Environment . i.... 2009
Jeff Corntassel Indigenous Governance Amidst the Forced Federalism Era 19-FALL Kansas Journal of Law & Public Policy 47 (Fall 2009) Whether the general public realizes it or not, Indigenous peoples in the United States today are living in a new policy era--one that I call forced federalism (1988- present). As a result of the 1988 Indian Gaming and Regulatory Act (IGRA) and the subsequent transfer of federal powers to state governments, Indigenous nations have been forced into... 2009
Daniel Austin Green Indigenous Intellect: Problems of Calling Knowledge Property and Assigning it Rights 15 Texas Wesleyan Law Review 335 (Spring 2009) Prelude: On Making Javanese Tobacco in a Japanese POW Camp:. 335 Introduction. 336 The Nature of Rights. 342 The Nature of Property. 343 Forms of Remedies. 352 Conclusion. 355 2009
Debra Harry Indigenous Peoples and Gene Disputes 84 Chicago-Kent Law Review 147 (2009) Wary from decades of exploitation in the name of science, Indigenous peoples typically approach any externally generated research agenda with caution, and for good reason. Indigenous peoples have been on the receiving end of research carried out in insensitive, and sometimes harmful, ways. Research has historically been a top-down, outside-in... 2009
Siegfried Wiessner, St. Thomas University School of Law Indigenous Rights and United Nations Standards. By Alexandra Xanthaki. Cambridge: Cambridge University Press. 2007. Pp. Xxxix, 314. Index. $110, £58 103 American Journal of International Law 188 (January, 2009) Indigenous Rights and United Nations Standards aims high: Alexandra Xanthaki, says the book's dust jacket, refuses to shy away from difficult questions and challenging issues and offers a comprehensive discussion of indigenous rights and their contribution to international law. In her introduction, Xanthaki-- who teaches at London's Brunel... 2009
Peter J. Chalk , Alexander Dunlop Indigenous Trade Marks and Human Rights: an Australian and New Zealand Perspective 99 The Trademark Reporter 956 (July-August, 2009) Article 17 of the Universal Declaration of Human Rights (UDHR) provides that (1) everyone has the right to own property alone as well as in association with others and that (2) no one shall be arbitrarily deprived of his property. In considering Article 17 of the UDHR, it is instructive to refer to interpretations of Article 1 of Protocol No. 1... 2009
Jo M. Pasqualucci International Indigenous Land Rights: a Critique of the Jurisprudence of the Inter-american Court of Human Rights in Light of the United Nations Declaration on the Rights of Indigenous Peoples 27 Wisconsin International Law Journal 51 (Spring 2009) Recognizing the urgent need to respect and promote the inherent rights of indigenous peoples which derive from their political, economic and social structures and from their cultures, spiritual traditions, histories and philosophies, especially their rights to their lands, territories and resources . . . - Preamble, United Nations Declaration on... 2009
Surya Mani Tripathi , Anshu Pratap Singh , Dipa Dube Internet Governance: a Developing Nation's Call for Administrative Legal Reform 37 International Journal of Legal Information 368 (Winter 2009) Cyberspace presents something new for those who think about regulation and freedom. It demands a new understanding of how regulation works and what regulates life there. It compels us to look beyond the traditional lawyer's scope-beyond laws, regulations, and norms. It requires an account of a newly salient regulator [- Computer Code] . In real... 2009
NNALSA Introduction to the National Native American Law Students Association 8 Annual Writing Competition 26 Arizona Journal of International & Comparative Law 505 (Summer, 2009) The National Native American Law Students Association (NNALSA) was founded in 1970 to promote the study of federal Indian law, tribal law and traditional forms of governance, in addition to providing support to Native Americans in law school and to expose the general public to issues faced by Native Americans and tribal governments. You can learn... 2009
Guadalupe Gutierrez, Ph.D. Jurisdictional Ambiguities among Sovereigns: the Impact of the Indian Gaming Regulatory Act on Criminal Jurisdiction on Tribal Lands 26 Arizona Journal of International & Comparative Law 229 (Spring, 2009) At first blush, it seems the Indian Gaming Regulatory Act (IGRA) succeeded in providing enormous economic opportunities for tribal governments to further their aspirations as self-governing, self-sufficient autonomous bodies. Closer inspection, however, reveals that IGRA was a reactionary response by Congress that did little to carry forward ideals... 2009
Guadalupe Gutierrez, Ph.D. JURISDICTIONAL AMBIGUITIES AMONG SOVEREIGNS: THE IMPACT OF THE INDIAN GAMING REGULATORY ACT ON CRIMINAL JURISDICTION ON TRIBAL LANDS 26 Arizona Journal of International & Comparative Law 229 (Spring, 2009) At first blush, it seems the Indian Gaming Regulatory Act (IGRA) succeeded in providing enormous economic opportunities for tribal governments to further their aspirations as self-governing, self-sufficient autonomous bodies. Closer inspection, however, reveals that IGRA was a reactionary response by Congress that did little to carry forward ideals... 2009
John T Cross Justifying Property Rights in Native American Traditional Knowledge 15 Texas Wesleyan Law Review 257 (Spring 2009) I. Introduction. 257 II. Native American Traditional Knowledge and Intellectual Property Rights. 262 III. Reconciling Traditional Knowledge Rights with Intellectual Property Law Theory. 264 A. The Reward for Creativity Theory of Intellectual Property. 265 B. Other Justifications for Property Rights in Knowledge. 267 C. Constitutional... 2009
Michelle Smith , Janet C. Neuman Keeping Indian Claims Commission Decisions in Their Place: Assessing the Preclusive Effect of Icc Decisions in Litigation over Off-reservation Treaty Fishing Rights 31 University of Hawaii Law Review 475 (Summer, 2009) Congress established the Indian Claims Commission (ICC) in 1946 as a forum to adjudicate claims by Native American tribes against the United States. Between 1946 and its termination in 1978, the Commission decided 610 tribal claims and awarded over 800 million dollars in compensation to 170 tribes. Although the ICC's remedial authority was limited... 2009
Christopher A. Schnell Lincoln and the Kentuckians: Placing Abraham Lincoln in Context with Lawyers and Clients from His Native State 36 Northern Kentucky Law Review 263 (2009) Abraham Lincoln was born in and spent the first seven years of his life in Kentucky. In 1816, his father, Thomas Lincoln, moved his family north across the Ohio River from what was then Hardin County, Kentucky and settled on a wooded, 160-acre claim in what was then Perry County, in southern Indiana. Lincoln later attributed his father's move north... 2009
Aliza Gail Organick Listening to Indigenous Voices: What the Un Declaration on the Rights of Indigenous Peoples Means for U.s. Tribes 16 U.C. Davis Journal of International Law and Policy 171 (Fall 2009) Introduction. 173 I. History of the Declaration - The Long and Winding Road. 177 A. The International Indigenous Peoples' Movement. 177 B. The First Decade and Draft Declaration. 180 1. The Draft Declaration. 182 2. Lessons Learned from the First Decade and Developing Strategies for the Second. 184 3. The Declaration. 186 II. The Declaration and... 2009
Lahela Hiapola'ela'e Farrington Hite Maka'ala Ke Kanaka Kahea Manu: Examining a Potential Adjustment of Kamehameha Schools' Tuition Policy 32 University of Hawaii Law Review 237 (Winter 2009) In 1893, a group of civilians, supported by the full power of the United States Navy and the United States Minister to the Kingdom of Hawai'i, successfully overthrew the Hawaiian monarchy. This coup d'etat ushered in over a century of hardship and deprivation for the Native Hawaiians. Kamehameha Schools is one of the few remaining institutions... 2009
Andrew R. Carl Method Is Irrelevant: Allowing Native Hawaiian Traditional and Customary Subsistence Fishing to Thrive 32 University of Hawaii Law Review 203 (Winter 2009) In 2002, the Circuit Court of the Third Circuit of the State of Hawai'i, in Kelly v. 1250 Oceanside Partners, concluded as a matter of law that: Method is relevant to claimed traditional and customary rights. Fishing and gathering practices lose their traditional and customary nature when performed with modern technology that: (a) substantially... 2009
Lisa M. Slepnikoff More Questions than Answers: Plains Commerce Bank V. Long Family Land and Cattle Company, Inc. and the U.s. Supreme Court's Failure to Define the Extent of Tribal Civil Authority over Nonmembers on Non-indian Land 54 South Dakota Law Review 460 (2009) In a 5-4 decision, the United States Supreme Court held in Plains Commerce Bank v. Long Family Land and Cattle Co. that tribal courts lack the civil authority to adjudicate claims arising from the non-Indian sale of fee land to another non-Indian. This case represents the next step in a long history of judicial activism which has steadily chipped... 2009
Lisa M. Slepnikoff MORE QUESTIONS THAN ANSWERS: PLAINS COMMERCE BANK V. LONG FAMILY LAND AND CATTLE COMPANY, INC. AND THE U.S. SUPREME COURT'S FAILURE TO DEFINE THE EXTENT OF TRIBAL CIVIL AUTHORITY OVER NONMEMBERS ON NON-INDIAN LAND 54 South Dakota Law Review 460 (2009) In a 5-4 decision, the United States Supreme Court held in Plains Commerce Bank v. Long Family Land and Cattle Co. that tribal courts lack the civil authority to adjudicate claims arising from the non-Indian sale of fee land to another non-Indian. This case represents the next step in a long history of judicial activism which has steadily chipped... 2009
Janine Robben Myths, History and Destiny 69-JUN Oregon State Bar Bulletin 17 (June, 2009) Walk a mile under my skies Try to see it once the way I do If you look out through my eyes You'll find a different point of view. Everything changes, Every fact wears some disguise . --Canadian singer and songwriter James Keelaghan I'm writing this at the cabin my husband built on our property between the Winema National Forest and the Klamath... 2009
Marie Quasius Native American Rape Victims: Desperately Seeking an Oliphant-fix 93 Minnesota Law Review 1902 (May, 2009) Leslie Ironroad lay dying in her hospital bed. She scribbled a statement to a police officer and identified the men who raped her, beat her, and locked her in the bathroom where she attempted to overdose on prescription medicine to escape further harm. No charges were filed. Members of the Standing Rock Sioux Reservation indicate that the police... 2009
  Native American Resources 2009 ABA Environment, Energy, and Resources Law: The Year in Review 250 (2009) We have attempted to include in our report federal legislation broadly applicable to Indians or Indian tribes and their resources. Acts relating to one or more specific tribes are not included in this report. The American Recovery and Reinvestment Act of 2009 contains provisions affecting American Indian tribes' ability to finance energy and... 2009
Robert O. Saunooke Native Americans and the Federal Bench: the Time Has Come 48 No.4 Judges' Journal 25 (Fall, 2009) As a Native American attorney, I am personally hopeful about the new federal administration and the possibilities it presents for change throughout the United States. One aspect of this change should occur as President Barack Obama has the opportunity to appoint judges to the federal bench. The possibility for significant change in the demographics... 2009
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