Showing posts with label rule of law. Show all posts
Showing posts with label rule of law. Show all posts

Saturday, February 21, 2026

DoJ cases against protesters keep collapsing as officers’ lies are exposed in court; The Guardian, February 21, 2026

, The Guardian; DoJ cases against protesters keep collapsing as officers’ lies are exposed in court

"Department of Justice prosecutors across the US have suffered a string of embarrassing defeats in their aggressive pursuit of criminal cases against people accused of “assaulting” and “impeding” federal officers.

In recent months, the federal government has relentlessly prosecuted protesters, government critics, immigrants and others arrested during immigration operations, often accusing them of physically attacking officers or interfering with their duties.

But many of those cases have recently been dismissed or ended in not guilty verdicts.

In several high-profile cases, the prosecutions fell apart because they relied on statements by Department of Homeland Security (DHS) officers that had no supporting evidence or in some instances were proven by video footage to be blatantly false. Criminal defense lawyers said it was unusual for federal prosecutors to pursue a high volume of charges over minor clashes with law enforcement, and that it was extraordinary to see the DoJ lose case after case across jurisdictions.

Still, the costs for defendants, even if ultimately exonerated, have been enormous, with many having their mugshots blasted by the government and some forced to languish in jail or have criminal charges hang over them for weeks and months."

Saturday, February 14, 2026

Homeland Security Wants Social Media Sites to Expose Anti-ICE Accounts; The New York Times, February 13, 2026

Sheera Frenkel and  , The New York Times; Homeland Security Wants Social Media Sites to Expose Anti-ICE Accounts

The department has sent Google, Meta and other companies hundreds of subpoenas for information on accounts that track or comment on Immigration and Customs Enforcement, officials and tech workers said.

"The Department of Homeland Security is expanding its efforts to identify Americans who oppose Immigration and Customs Enforcement by sending tech companies legal requests for the names, email addresses, telephone numbers and other identifying data behind social media accounts that track or criticize the agency.

In recent months, Google, Reddit, Discord and Meta, which owns Facebook and Instagram, have received hundreds of administrative subpoenas from the Department of Homeland Security, according to four government officials and tech employees privy to the requests. They spoke on the condition of anonymity because they were not authorized to speak publicly.

Google, Meta and Reddit complied with some of the requests, the government officials said. In the subpoenas, the department asked the companies for identifying details of accounts that do not have a real person’s name attached and that have criticized ICE or pointed to the locations of ICE agents. The New York Times saw two subpoenas that were sent to Meta over the last six months.

The tech companies, which can choose whether or not to provide the information, have said they review government requests before complying. Some of the companies notified the people whom the government had requested data on and gave them 10 to 14 days to fight the subpoena in court."

Friday, February 13, 2026

Meet Aliya Rahman, Disabled U.S. Citizen Assaulted, Jailed & Traumatized by ICE in Minneapolis; Democracy Now, February 9, 2026

Democracy Now; Meet Aliya Rahman, Disabled U.S. Citizen Assaulted, Jailed & Traumatized by ICE in Minneapolis

"We speak with Aliya Rahman, a U.S. citizen who was violently dragged from her car by federal immigration officers in Minneapolis last month and detained at the Whipple Federal Building, which has become the epicenter of the government’s immigration crackdown in the city. Rahman says she repeatedly told agents she was disabled and had a brain injury, but they ignored her pleas for medical attention or other accommodation. “I was taken out of that place unconscious,” says Rahman, who describes lasting injuries and trauma from her detention. Rahman was not charged with any crime. “What I saw in that detention center was truly horrific.”

We also speak with attorney Alexa Van Brunt, director of the Illinois office of the MacArthur Justice Center, who says victims of ICE violence like Rahman can sue the federal government for violating their rights, “but they cannot sue the officers in their individual capacity.”"

Sunday, February 1, 2026

Judge Orders Release of 5-Year-Old, Whose Detention Drew Outrage; The New York Times, January 31, 2026

Mattathias Schwartz and , The New York Times ; Judge Orders Release of 5-Year-Old, Whose Detention Drew Outrage

The image of Liam Conejo Ramos, wearing a blue winter hat and Spider-Man backpack while in the custody of immigration agents, fueled outrage across the country.

"A federal judge on Saturday ordered the release of a 5-year-old boy and his father from immigration custody, condemning their removal from their suburban Minneapolis neighborhood as unconstitutional.

The image of Liam Conejo Ramos, wearing a Spider-Man backpack and an oversize fluffy blue winter hat as he was detained by officers earlier this month, spurred outrage at a moment when many were already incensed by the Trump administration’s immigration tactics in Minnesota and elsewhere across the country. The flood of immigration enforcement officers into Minneapolis, known as Operation Metro Surge, has led to mass demonstrations as well as the shooting deaths of two protesters, Renee Good and Alex Pretti, at the hands of federal agents.

In a blistering opinion ordering Liam’s release, Judge Fred Biery of the Federal District Court for the Western District of Texas condemned “the perfidious lust for unbridled power” and “the imposition of cruelty.” The boy’s father, Adrian Conejo Arias, was also arrested and the pair were taken to an immigration detention center outside San Antonio. A lawyer for the family previously said in court filings that Mr. Conejo Arias, who is from Ecuador, had legally entered the country under American guidelines for asylum. The Department of Homeland Security had charged that Mr. Conejo Arias had entered the country illegally in December 2024.

In a statement, Jennifer Scarborough and four other attorneys who represent Liam and his father praised the ruling. They said they were now working to quickly reunite the family. “We are pleased that the family will now be able to focus on being together and finding some peace after this traumatic ordeal,” they wrote."

Friday, January 30, 2026

Federal Agents Arrest Don Lemon Over Minnesota Church Protest; The New York Times, January 30, 2026

Hamed AleazizDevlin Barrett and , The New York Times ; Federal Agents Arrest Don Lemon Over Minnesota Church Protest

The former CNN anchor has said he was not demonstrating, but reporting as a journalist, during the interruption of a service inside a St. Paul church earlier this month.

"The former CNN anchor Don Lemon was arrested late Thursday night on charges that he violated federal law during a protest at a church in St. Paul, Minn., his lawyer said, in a case rejected last week by a magistrate judge.

Mr. Lemon has said he was simply reporting as a journalist when he entered the Cities Church on Jan. 18 to observe a demonstration against the immigration crackdown in the area.

The protesters interrupted a service at the church, where an Immigration and Customs Enforcement official serves as a pastor, and chanted “ICE out.” Afterward, the Trump administration sought to charge eight people over the episode, including Mr. Lemon, citing a law that protects people seeking to participate in a service in a house of worship.

But the magistrate judge who reviewed the evidence approved charges against only three of the people, rejecting the evidence against Mr. Lemon and the others as insufficient. The Justice Department then petitioned a federal appeals court to force the judge to issue the additional warrants, only to be denied."

Thursday, January 29, 2026

Democrats Call for Release of 5-Year-Old Detained by ICE; The New York Times, January 29, 2026

Aaron Boxerman and  , The New York Times; Democrats Call for Release of 5-Year-Old Detained by ICE

Representative Joaquin Castro said Liam Conejo Ramos appeared lethargic during a visit by lawmakers to the facility where he and his father are being held. The pair was detained in Minnesota.

"Democratic lawmakers called Wednesday for the immediate release of Liam Conejo Ramos, a 5-year-old detained by federal agents in Minnesota, after visiting him and his father in an immigration holding facility.

The detention of the boy — seized while wearing a Spider-Man backpack — has become a flashpoint, as anger has continued to grow over the Trump administration’s immigration crackdown and deportation efforts. Critics called his detention emblematic of the callousness of the administration’s policies, while the Department of Homeland Security said the boy had not been targeted or arrested.

U.S. Immigration and Customs Enforcement agents detained the pair in Columbia Heights, Minn., shortly after Adrian Conejo Arias, Liam’s father, collected him from school, according to local officials. They were then taken to an immigration detention center in Dilley, Texas, about 70 miles south of San Antonio."

Tuesday, January 27, 2026

Judge Temporarily Blocks Deportation of 5-Year-Old Detained in Minneapolis Suburb; The New York Times, January 27, 2026

 , The New York Times; Judge Temporarily Blocks Deportation of 5-Year-Old Detained in Minneapolis Suburb

An image of the boy, wearing a Spider-Man backpack as he was detained by federal agents, became a symbol of the immigration crackdown in Minnesota.

"A federal judge on Monday temporarily blocked the deportation of a 5-year-old boy and his father who were arrested in a Minneapolis suburb in an operation that further stirred the outrage over the Trump administration’s deportation efforts.

The boy, Liam Conejo Ramos, and his father, Adrian Conejo Arias, were arrested last week in Columbia Heights, Minn., shortly after the father had picked the boy up from school, according to school district officials. They were quickly taken to an immigration detention center outside San Antonio, where they remain.

In his order, Judge Fred Biery of the U.S. District Court for the Western District of Texas told the federal government that it could not move the boy or his father out of his court’s jurisdiction while they challenged their detention.

The detention of the boy and his father by U.S. Immigration and Customs Enforcement agents became a flashpoint in the Twin Cities, where anger has continued to grow over the surge of federal agents in the region. The image of Liam, wearing a Spider-Man backpack and a large winter hat as he was detained by federal agents, quickly became emblematic of the harsh effects of the government’s tactics in Minnesota."

Friday, January 23, 2026

What images of a detained five-year-old boy reveal about Trump’s draconian ICE crackdown; The Guardian, January 22, 2026

Robert Tait, The Guardian; What images of a detained five-year-old boy reveal about Trump’s draconian ICE crackdown

"One recent image shows the innocent figure of Liam Ramos, a five-year-old preschooler wearing a blue bobbled winter hat, standing next to a black vehicle with a dark-clad adult figure standing behind him, whose hand is proprietorially placed on his backpack.

A second picture depicts the same child at the door of a house, with what appears to be a masked Immigration and Customs Enforcement (ICE) agent standing behind him.

The exact circumstances of the photos – or their provenance – remains unclear. The homeland security department has insisted that Liam was being held for protective purposes after his father absconded when agents tried to detain him.

Yet officials from the Columbia Heights public school district, which circulated both pictures, say the latter conjures a dark and disturbing reality – of an unsuspecting Liam being exploited as bait to lure adults in his family home to open the door so ICE agents can arrest them."

ICE Detained a 5-Year-Old Minnesota Boy and Used Him As “Bait”; Mother Jones, January 22, 2026

 , Mother Jones; ICE Detained a 5-Year-Old Minnesota Boy and Used Him As “Bait”

"Immigration and Customs Enforcement agents detained a 5-year-old on his way home from school on Tuesday and used him as “bait” to knock on his front door to see if anyone was home, according to school officials in Minnesota. 

Liam Conejo Ramos, a preschooler, is one of at least four children from the Columbia Heights Public Schools district in suburban Minneapolis who have been detained this month, Zena Stenvik, the superintendent for the district, said in a press conference Wednesday."

Saturday, January 10, 2026

Is the Law Still King?; The Bulwark, January 9, 2026

William Kristol, The Bulwark; Is the Law Still King?

Two-hundred fifty years ago tomorrow, on January 10, 1776, in Philadelphia, Thomas Paine published his pamphlet Common Sense. Six months before the Declaration, Paine made the argument for independence directly to the people. The pamphlet was a sensation, and seems to have been read and discussed almost immediately and everywhere. The numbers are a bit fuzzy (there was no New York Times best seller list then!), but Common Sense seems to have sold something like 100,000 copies in a few months. In proportion to the population at that time, it may have had the largest sale and circulation of any book in American history.

As a key part of his argument, Paine makes the general case against hereditary or absolute monarchy, and for popular government and the rule of law. Here’s the famous paragraph:

But where, say some, is the King of America? I’ll tell you, friend, he reigns above, and doth not make havoc of mankind like the Royal Brute of Great Britain. . . . [T]he world may know, that so far as we approve of monarchy, that in America the law is king. For as in absolute governments the King is law, so in free countries the law ought to be king; and there ought to be no other.

From the beginning, the rule of law has been central to the American experiment in self-government. Obviously in both theory and practice the concept brings with it complications and controversies. But the rule of law has always been seen as a necessary corollary, a central feature, of popular self-government. From Paine on, No Kings has meant that the law is king.

Is the law king in America today? We’re seeing a sustained and conscious effort to undermine the rule of law. From Minneapolis to Caracas, from the White House to the Department of Justice to the Department of Homeland Security, the Trump administration has engaged in what the Declaration called “a long train of abuses . . . pursuing invariably the same Object”—the object of eviscerating the rule of law and reducing us to mere subjects rather than self-governing citizens.

This has been obvious for the past year to all who have eyes to see, or who are willing to let their eyes do any seeing. But the last few days have provided especially clear instances of the assault on the rule of law. Just yesterday, for example, in the wake of the killing of Renee Good, Donald Trump’s FBI told Minnesota’s criminal investigative agency, the Bureau of Criminal Apprehension (BCA) that they were to be excluded from the investigation into Good’s death. The BCA reported that Trump’s FBI would not allow the BCA to “have access to the case materials, scene evidence or investigative interviews necessary to complete a thorough and independent investigation” of this killing in their jurisdiction. That’s because Trump’s FBI isn’t interested in trying to discover the truth. Their orders are clearly to cover up the lawless behavior of federal agents.

Meanwhile Trump confirmed on Wednesday in an interview with the New York Times that in international matters, he respects no legal limits on his power. The only limits he acknowledges are “My own morality. My own mind. It’s the only thing that can stop me.” I suppose we should thank Trump for providing a kind of living illustration, a kind of tableau vivant, of the claims of absolute monarchy that Thomas Paine ridiculed and denounced. But Trump’s not a faraway king from whom we’re about to separate ourselves. He’s our president.

And all this while Trump’s Justice Department is routinely ignoring the law that required the full release of the Epstein files by December 19, 2025. Yesterday, Reps. Ro Khanna (D-Calif.) and Thomas Massie (R-Ky.), the lead sponsors of the Epstein Files Transparency Act, asked a federal court to appoint “a Special Master and an Independent Monitor to compel” the the Justice Department to produce the Epstein files as the law requires. “Put simply,” they wrote, “the DOJ cannot be trusted with making mandatory disclosures under the Act.” Or put even more simply, Trump’s Department of Justice cannot be trusted to follow the law.

Earlier this week, political scientist Jeffrey Isaac addressed the apparent paradox that people who allegedly believe in “America First” have rallied to support Trump’s attack on another country. But as Isaac puts it, at its heart Trumpism is neither isolationist nor interventionist. It’s about authoritarianism: “contempt for the very idea of law” and “an embrace of the power politics of domination and conquest.” It’s a repudiation of democracy and the rule of law, both at home and abroad.

So which is it to be? A stand for liberty in the spirit of Thomas Paine, or acquiescence to the depredations of our own mad King George? The rule of law or the rule of Trump?"

No Amazon, No Gmail: Trump Sanctions Upend the Lives of I.C.C. Judges; The New York Times, January 10, 2026

, The New York Times; No Amazon, No Gmail: Trump Sanctions Upend the Lives of I.C.C. Judges

"To be elected a judge at the International Criminal Court was long considered an honor. For Luz del Carmen Ibáñez Carranza, the distinction has become an ordeal.

Ms. Ibáñez was a prosecutor in her native Peru, where she oversaw trials of Shining Path terrorists, of military officers accused of human rights abuses and of government officials charged with corruption. Death threats were common.

But since the Trump administration imposed sanctions on her and on some of her colleagues in retaliation for the court’s decision to investigate U.S. personnel in Afghanistan, she has faced different kinds of challenges, she said. The penalties effectively cut the judges off from all American funds, goods and credit cards, and prohibit individuals and business in the United States from working with them.

“We’re treated like pariahs, we are on a list with terrorists and drug dealers,” Ms. Ibáñez said...

In response to the hostility, the court is overhauling its American-dominated tech and financial systems. The court’s records and other data storage have been backed up at different sites, and finance and communications systems are being shifted to European platforms, according to several experts familiar with the court’s work who spoke on condition of anonymity to discuss sensitive matters...

In September, the court announced that it would transfer its office software from Microsoft to an open-source platform developed by a German government-owned company."

Tuesday, January 6, 2026

White House Posts False Jan. 6 Narrative on Riot’s 5th Anniversary; The New York Times, January 6, 2026

Luke Broadwater and , The New York Times; White House Posts False Jan. 6 Narrative on Riot’s 5th Anniversary

"On the fifth anniversary of the pro-Trump mob attack on the Capitol, the Trump administration created a new page on the official White House website that represented the president’s most brazen bid yet to rewrite the history of the Jan. 6 riot with false claims aimed at absolving him of responsibility.

The site blames Capitol Police officers, who defended lawmakers that day, for starting the assault; Democrats, who were the rioters’ main targets, for failing to prevent it; and former Vice President Mike Pence, who rejected falsehoods about the 2020 election, for allowing the results to be certified.

Mr. Trump has long sought to whitewash the violence and vandalism committed on Jan. 6, 2021, and reject responsibility for having instigated it. But the webpage, promoted on government social media accounts, put the official imprimatur of the White House on an astonishingly misleading account of the Capitol attack."

Donald Trump poses a threat to civilization; The Guardian, January 6, 2025

 , The Guardian; Donald Trump poses a threat to civilization

"Trump’s domestic and foreign policies – ranging from his attempted coup against the United States five years ago, to his incursion into Venezuela last weekend, to his current threats against Cuba, Colombia, and Greenland – undermine domestic and international law. But that’s not all.

They threaten what we mean by civilization.

The moral purpose of civilized society is to prevent the stronger from attacking and exploiting the weaker. Otherwise, we’d be permanently immersed in a brutish war in which only the fittest and most powerful could survive.

This principle lies at the center of America’s founding documents – the Declaration of Independence, the constitution and the Bill of Rights. It’s also the core of the postwar international order championed by the United States, including the UN charter – emphasizing multilateralism, democracy, human rights, and the rule of law...

A direct line connects Trump’s attempted coup five years ago to his capture of Nicolás Maduro last weekend. Both were lawless. Both were premised on the hubris of omnipotence.

That same line connects to Trump’s current threats against Cuba, Colombia, and Greenland.

You see much the same in Putin’s war on Ukraine. In Xi’s threats against Taiwan. In global depredation and monopolization by big tech and big oil. In Russian, Chinese, and American oligarchs who have fused public power with their personal wealth.

But unfettered might does not make right. It makes for instability, upheaval, and war.

History shows that laws and norms designed to constrain the powerful also protect them. Without such constraints, their insatiable demands for more power and wealth eventually bring them down – along with their corporations, nations, or empires. And threaten world war.

Trump’s blatant lawlessness will haunt America and the world – and civilization – for years to come."

Saturday, January 3, 2026

Trump Is the Jan. 6 President; The New York Times, December 31, 2025

 THE EDITORIAL BOARD, The New York Times; Trump Is the Jan. 6 President

"It was a day that should live in infamy. Instead, it was the day President Trump’s second term began to take shape.

Five years ago, on Jan. 6, 2021, a pro-Trump mob stormed the Capitol, hoping to overturn the result of the 2020 presidential election. After the sun set that day, Congress reconvened to certify Joe Biden’s victory. The rioters lost, and so did Mr. Trump, who had summoned them to Washington and urged them to march to the Capitol. The Trump era seemed to have ended in one of the most disgracefully anti-American acts in the nation’s history.

That day was indeed a turning point, but not the one it first seemed to be. It was a turning point toward a version of Mr. Trump who is even more lawless than the one who governed the country in his first term. It heralded a culture of political unaccountability, in which people who violently attacked Congress and beat police officers escaped without lasting consequence. The politicians and pundits who had egged on the attack with their lies escaped, as well. The aftermath of Jan. 6 made the Republican Party even more feckless, beholden to one man and willing to pervert reality to serve his interests. Once Mr. Trump won election again in 2024, despite his role in encouraging the riot and his many distortions about it, it emboldened him to govern in defiance of the Constitution, without regard for the truth and with malice toward those who stand up to his abuses.

Tragically, America is still living in a political era that began on Jan. 6, 2021. Recognizing as much is necessary to bring this era to an end before it has many more anniversaries."

Sunday, December 14, 2025

Colorado Officials Reject Trump’s ‘Pardon’ of a Convicted Election Denier; The New York Times, December 13, 2025

 , The New York Times; Colorado Officials Reject Trump’s ‘Pardon’ of a Convicted Election Denier

"President Trump’s pledge to pardon Tina Peters, a former Colorado county clerk convicted of tampering with voting machines, touched off a new battle on Friday over the fate of perhaps the last high-profile 2020 election denier still behind bars.

Democratic leaders in Colorado dismissed the pardon as an empty attempt to bully a Democratic state into freeing one of the president’s political allies. They argued that Mr. Trump had no legal power to overturn Ms. Peters’s conviction in state court...

Legal scholars and Colorado officials were incredulous. They said the notion that the president could intervene in state courts clashed with the plain language of the Constitution, as well as its fundamental principles of federalism and states’ rights."

Thursday, December 11, 2025

Kilmar Abrego Garcia released after judge rules Trump admin lacked valid removal order; Fox News, December 11, 2025

Louis Casiano , Fox News; Kilmar Abrego Garcia released after judge rules Trump admin lacked valid removal order

"Kilmar Abrego Garcia, the El Salvadoran illegal immigrant that became the face of the Trump administration's mass deportation campaign, has been released from detention.

Garcia's lawyer confirmed his release with Fox News. 

His release came after a federal judge on Thursday ordered he be freed."

Federal judge orders Kilmar Abrego Garcia released from ICE custody; Fox News, December 11, 2025

 Breanne Deppisch , Alex Nitzberg , Fox News; Federal judge orders Kilmar Abrego Garcia released from ICE custody

"A federal judge in Greenbelt, Maryland, on Thursday ordered Salvadoran migrant Kilmar Abrego Garcia released from ICE custody, capping — for now – an extraordinary, 10-month legal fight that has spanned two continents, multiple federal courts, and prompted dozens of hearings in the aftermath of his removal.

U.S. District Judge Paula Xinis ordered Abrego Garcia released from the ICE Moshannon Valley Processing Center in Philipsburg, Pa., ruling that the Trump administration had not obtained the final notice of removal order needed to remove him to a third country."

Friday, November 28, 2025

Retired judges warn that the rule of law is unraveling; The Washington Post, November 28, 2025

 , The Washington Post; Retired judges warn that the rule of law is unraveling

"In a dozen interviews with The Washington Post, former judges and one soon-to-be-retired judge described a judiciary under incredible strain and its integrity threatened by partisan attacks, antagonistic rhetoric from public officials and ambiguous decisions handed down by the nation’s highest court.

Many judges said the politicization of judges, the Supreme Court’s expanding use of emergency dockets and sustained criticism from the Trump administration have pushed the courts and democracy to a fragile tipping point — one where cooperation with rulings and adherence to the rule of law can no longer be assumed.

“There’s not a person in our country that, whether they think about it or not, does not depend upon the ability of these fundamental rights and liberties to be protected in an action in court if there is someone who violates that,” said Paul Grimm, a retired judge for the U.S. District Court for the District of Maryland.

The consequences, judges warn, are already becoming visible in who’s willing to serve as a jurist, global shifts in judicial norms and the types of justice the U.S. system can still deliver."

Wednesday, November 26, 2025

Kristi Noem directed Venezuelans to be sent to El Salvador after federal judge ordered deportation planes turned around: DOJ; ABC News, November 25, 2025

Laura Romero and Luke Barr , ABC News; Kristi Noem directed Venezuelans to be sent to El Salvador after federal judge ordered deportation planes turned around: DOJ

"Department of Homeland Security Secretary Kristi Noem directed that hundreds of Venezuelan men who were removed from the U.S. in March be transferred to El Salvador, despite a federal judge ordering deportation planes turned around, according to a new court filing from Trump administration lawyers. 

In the filing late Tuesday, the Department of Justice said that DOJ and DHS officials conveyed their legal advice to Noem after U.S. District Judge James Boasberg gave first an oral directive and then a written order that sought to block the deportations under the Alien Enemies Act. 

"After receiving that legal advice, Secretary Noem directed that the AEA detainees who had been removed from the United States before the Court's order could be transferred to the custody of El Salvador," DOJ said on Tuesday."

Wednesday, November 19, 2025

Pope Leo calls out 'extremely disrespectful' treatment of migrants in the U.S.; NPR, November 18, 2025

, NPR; Pope Leo calls out 'extremely disrespectful' treatment of migrants in the U.S.

"Pope Leo XIV said he is troubled by the violent and at times "extremely disrespectful" ways migrants have been treated in the United States. 

The Pope made his remarks while answering questions from journalists at Castel Gandolfo, the papal vacation residence outside Rome. 

"We have to look for ways of treating people humanely, treating people with the dignity that they have. If people are in the United States illegally, there are ways to treat that. There are courts. There's a system of justice," the Pope said. 

"No one has said that the United States should have open borders," the Pope continued. "I think every country has the right to determine who enters, how, and when.""