Ethical Issues Concerning the Selection and Hiring Process of Police Officers



Abstract

The social contract dictates that because people choose to live in a civil society bound by rules to protect themselves and the safety of those around them, they are to sacrifice some of their own liberties in exchange for protection from the harsh and unrelenting outside world (Friend, 2004). If there is no one to enforce the rules, there is no civil society. This is why the selection of those who will uphold the law is vital – these individuals are given an incredible amount of authority while still maintaining their roles as public servants. They walk a fine line of performing justice or negating the social contract.

Brief History

There have been many different incarnations of a police officer's role ranging from the frankpledge system in England during the Middle Ages, where tythings would work together to enforce the law in their communities . Throughout the ages, law enforcement became more specialized. When the colonies were founded, the policing systems from England carried over to the New World. When the dust settled after the American Revolution, policing changed as well (“The History”, 2013).

During the early 1800's to the 1970's, police were seen as an extension of whoever was in political power. This was known as The Political Model – police had a tremendous amount of discretion and were highly decentralized. They were in the pockets of local politicians and rife with corruption due to the fact that the officer's main goals were not maintaining order, but to enforce the political agenda of whomever was in office. Enforcement standards differed from city to city, however this allowed for law enforcement officers to be more personable with the citizenry due to their close ties. This allowed for police also have a community oriented persona (Roberg et al, 2002).

The next evolution in policing was The Reform Model, where police became more centralized and bureaucratic. This was a large move away from political influence and the use of standards for law enforcement became heavily implemented. This move emphasized the “crime fighting” aspect of policing, while reemphasizing the role of police officers as public servants. Arrest rates, response rates, and crime rates were all utilized to determine the effectiveness of police. Many felt this separated police from the community who came to view law enforcement officers as adversaries (Robert et al, 2002).

With the advent of The Service Model, three areas of policing came into focus – policy development, selection/training, and management. Policies were created that dictated discretion in situations where force was used by focusing on training and guidelines. Selection became a more job related and not capricious. More minorities and women were hired. Training programs focused more on community-centric policing and human relations. Also, there was more of a focus on educational background in the selection of police candidates. New organizational and management programs were implemented including community relations programs, team policing, and crime prevention programs (Roberg et al, 2002).

Further evolution brings about the Community-Policing Model. This model focuses on community relations, especially with minority groups, police evaluations, implementing policy based on research, and crime response. Overall, there has been a paradigm shift back to police becoming public servants again, while utilizing new resources to create better and more efficient police departments (Roberg et al, 2002). Using these new resources and new concepts requires better selection and training of new officers, as well as retraining veteran officers to conform to the new set of standards.

Generalized Selection and Hiring Processing

Because of the shift back to a more community-centric police officer, and avoiding the mistakes of older policing models, many police departments are starting to implement quality control measures even before considering any candidates.

Getting the Word Out

The crux of the recruitment process is attracting “quality” candidates. This includes advertisements in the classified section of the newspaper, internet, radio, etc. Police departments will also use job fairs and travel to college campuses to recruit students nearing graduation (Roberg et al, 2002). Once such recent job fair took place in DeKalb County, Georgia earlier this month where 80 positions were advertised with qualifications including:
  • 20 years of age
  • U.S. Citizen
  • No felony or domestic violence charges in the past
  • High School Diploma/GED
  • Valid Drivers License (Banks, 2013).
Compared to other police departments hiring requirements, these seem lax. For instance, a job posting from the Louisville Police Department in Kentucky lists more stringent application requirements including physical requirements like “Lifts and carries items weighing in excess of 100 pounds in a team setting” and “Must be vaccinated for hepatitis B, have provided evidence of immunity, or have signed a declination form within ten days of initial assignment.” Other requirements are listed such as “Must not have an accumulation of nine or more points for traffic violations”, “Must be eligible for certification as a State Peace Officer”, and “Within the last 2 years must not have conducted the business of a private detective agency or any agency supporting private detectives, private policeman or private guards/advertised or solicited any such business in connection with any labor dispute” (“Police Recruit”, 2013).

As pointed out, each department has its own standards for advertizing an available position as a police recruit. Another method of recruiting includes having officers, on paid time, travel to different communities, or even to different states to recruit potential candidates (Roberg et al, 2002.

Also, police develop recruitment strategies to target specific types of people they feel would fill a niche in their police department – women and minorities. One way to target females to apply for the job is to describe the community centric and caring aspect of the position; they lessen the “crime fighting” aspect of the job. Three of the most common minority groups targeted for recruiting are Blacks, Hispanics, and Asians. For each type of applicant, police departments tailor the way the advertize to them. For Blacks, police departments emphasize the ever-changing nature of the job as well as the public service and responsibility aspect. For Hispanics, police departments emphasize pay, responsibility, and the public service aspect of the job. For Asians, responsibility and variety are highlighted (Roberg et al, 2002). Overall, police departments try to use recruitment tactics to select the best, brightest, and most qualified applicants depending on the needs of the community and the needs of the department itself.

Screening Potential Candidates

After a pool of candidates are selected, the police department then whittles down candidates through a series of tests and measurements including physical fitness tests, examining the candidate's educational background, psychological screening, polygraph tests, and other qualifiers.

When conducting these types of examinations, validity and reliability are key. The tests need to be capable in demonstrating the quality of the candidate (Roberg et al, 2002). The measures need to be equal and static for everyone. For instance, on a physical fitness test, everyone needs to perform to a certain standard regardless of age, gender, race, weight, and how physically fit the candidates are. A standardized bar needs to be set – some people may go above and beyond the set measure, some people may barely cross it, and some may not cross it at all. This should be the same for all aspects of the screening process – it should be objective and based purely on the quality of the individual in that specific type of examination.

There are several types of behaviors that agencies do not want to have in their new recruits. These traits include tardiness or absenteeism. These behaviors cost departments money in overtime pay and create a distrustful and resentful atmosphere among the officers. Another main issue departments try to weed out is past disciplinary actions. Obviously, if an officer is troublesome it also creates a bad atmosphere among officers as well. These types of behaviors also cost the department time and money in reprimanding and retraining a troublesome employee and it also adds to public distrust – law enforcement is one of the few types of employment where force and authority used upon the public is acceptable. The people who are hired into this position need to be fully qualified for the position and able to perform the duties they are assigned (Cochrane et al, 2008).

What is considered the most important part of whittling down potential police recruits is the background examination. A large portion of the candidate's background is provided by the candidate. Also, other information checked can include criminal background, credit, family background, employment, personal references (friends, neighbors, family, coworkers), and military records, if applicable. The examiner determines from the information they are given if the candidate would be a good match (Roberg et al, 2002). The main way this information is gathered is by getting a signed and notarized waiver to investigate every aspect of the candidate's background. Although officers can correspond with the personal references via mail or phone, the most reliable way is to knock someone's door. Also, it is recommended the background investigator also try to find other references through the references the candidate provided. Generally, the candidate provided these references because they will have positive things to say about the candidate, and a deeper look is required to acquire a better idea of the candidate's personality (Bushman, 2004). This method has been considered the most reliable method for determining a good candidate.

Psychological evaluations are used as a measure police departments use to determine the quality of a candidate. The examination may be given as either a verbal or written examination or both. The purpose of this type of exam is to determine if an individual is psychological “cut out” to be a police officer. Also, the test screens out applicants who may be mentally unstable or unfit. Although critics suggest this type of evaluation may be too subjective, it is still utilized by police departments around the country because it has been shown to sift out candidates who not only are mentally or emotionally unfit for the position but also may have a mental disorder (Roberg et al, 2002) The main psychological examinations used are MMPI, California Psychological Inventory (CPI), Sixteen Personality Factor Questionnaire (16PF), Edwards Personal Preference Schedule, and the Inwald Personality Inventory. Is debatable as to which instrument determines the best results, however every police department that utilizes psychological exams, uses one of these types of test. There are two ways police agencies utilize the results of these exams – a pass/fail system, or weighted against other selection criteria. In one study, the majority (68.1%) of the agencies who provided data considered it a pass/fail examination. The rest (31.9%) considered it weighted (Cochrane et al, 2008)

Another measure police departments use to whittle down potential candidates is a polygraph examination, more commonly known by its misnomer, a lie detector test. Agencies utilize this too to see if candidates have had illegal or inappropriate behavior in the past, including drug use and criminal activity (Roberg et al, 2002). A polygraph examination does not measure a person's veracity; it measures their stress reactions when being questioned, including heart rate, blood pressure, respiration, and skin conductivity. The test is conducted by instructing and explaining the “gravity” of the examination including the types of questions to induce the candidate's concern about their honesty. Also, “control” questions are used during the examination to measure the candidates honesty and also increase their concern about being deceptive (“The Truth”, 2004).

Physical fitness is another criteria that is considered when hiring potential police officers. Considering law enforcement officers are constantly in the field, are required to run after or apprehend a person, they need to be physically capable of doing so. Many police departments require an applicant to be at least 21 years; some may consider as young as 18, but they may be considered “too immature” and are assigned to community centric duties. However, the main concern has not been too young an applicant is, but how old. Most departments generally do not hire officers over the age of 38, but have reconsidered due to policy. Also, one of the most important parts of the physical fitness examination is physical strength and agility. Mostly the tests center on activities police officers will be doing routinely. There are also other health measures such as cardiovascular health, flexibility, strength. These tests are standardized and differentiated between age and gender (Roberg, 2002).

Lastly, education is another large contender when law enforcement agencies consider hiring on a new candidate. Since the 1970's there has been a movement across college campuses to include Criminology and Criminal Justice programs to encourage education among current and potential officers. Also, with the increase in technology and complexities of the legal system, having an education is extremely helpful to officers (Decker & Huckabee, 2002). It has been affirmed that officers with a higher level of education are more even keeled and are able to utilize the complex problem solving skills they learned in college. However, an educational requirement, other than a GED or high school diploma, is not required by most agencies and only a quarter of officers have any kind of post secondary degree (Roberg et al, 2002).

It is feared that an educational requirement will racially discriminate against Blacks and Hispanics, however this has been disproven. Many agencies are moving to have an educational requirement put into place because they feel the more educated their officers are, the more organic the department is – officers are less authoritative, had a greater acceptance of different people and cultures, and better acclimatized them to community policing roles. Also, having a college education increases chances of moving upward in a department (Roberg et al, 2002).

Ethical Issues Concerning the Hiring Process

There has been a concerning issue with a dearth of qualified candidates. In spite of the recession and an increase of job applicants, there have been issues finding properly qualified candidates. This has led to some agencies to lower the bar to attract more candidates. For example, consider the requirements listed for DeKalb County Georgia and the ones listed for Louisville, Kentucky. More applicants would respond to the DeKalb County advertisement than for the Louisville advertisement based on the lessened criteria. DeKalb County would have a larger task screening proper applicants, than Louisville would because of the criteria, but this becomes a quality versus quantity issue. Also, another factor is police departments trying to diversify their force, but lowering the standards for more “ethnically diverse” applicants.

There have been many criticisms of the selection process of candidates for law enforcement positions. The main factor is bias. Many argue these test discriminate against potential candidates that may be more qualified than other candidates. Some of these issues encompass every aspect of the process from advertizing to physical and mental health. It has become a balancing act between whether these measures are necessary to how necessary and important they are.

Because of the Age Discrimination in Employment Act, police have had to consider candidates over the age of 40. Also, police department have imposed height and weight limits in the past, however that has been found to discriminate against women, who are typically shorter than men. Also, when it comes to physical fitness and agility, the tests were found to be discriminatory because not all tests were “job related”. Now most of the physical fitness tests revolve around “job related” tasks like dragging a body, climbing fences, sprints, etc (Roberg et al, 2002) Another issue with the age of a candidate, is that police departments are starting to consider officers who are “older” to ensure they are selecting more quality officers. Many are concerned these age requirements will hurt the chances of minorities and women being hired.

Another issue seen in hiring practices concerns people with disabilities – Under the Americans with Disabilities Act, “no qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of services, programs, or activities of a public entity”. Because working as a police officer is considered a “public entity”, candidates are given a conditional offer of employment before a medical exam and examiners who perform a background screen or a psychological examination are prohibited from asking questions that could disclose a disability – it would be considered discriminatory (Roberg et al, 2002).

Another hot point is education. Although many agencies do not have an educational requirement, it is highly encourage that higher education be obtained for the purposes of moving up in the agency. In addition, there has been an argument against educational requirements because studies show that the level of job dissatisfaction increases concurrently with the level of education and the years with the police department. This could create burn-out and turn over (Decker & Huckabee, 2002).

There has been speculation that the psychological examination is biased based on race and that it does not sift out differences between officers who under-perform or over-perform. Also, it has been suggested the psychological examination be removed completely – there are better behavioral indicators such as the background check, which shows past actions (Roberg et al, 2002). However, the main argument for having a psychological assessment is purely financial. For instance, the Los Angeles police department spends, on average, $100,000 training one new recruit. This includes 1,000 hours of training. If the officer is found to not be a proper “fit” for the job, the city is out nearly $100,000. Simply put, some agencies cannot afford not to thoroughly screen their potential employees (Cochrane et al, 2008)

Also, another criticism of psychological examinations are the different types of tests used and how the results are interpreted – cut off scores on standardized tests and the use of norms. Also, the Equal Employment Opportunity Commission suggests that some of the questions used in the psychological examination may be discriminatory based on gender and/or race (Cochrane et al, 2008).

Another method used in the selection process having been criticized is the polygraph test. Many feel this is an unreliable measure because of the stress-load on a candidate and how it may effect their answers – false positives (Roberg et al, 2002). Another concern among the psychological community is the fact they have not been able to separate “placebo-like effects”. It has been surmised polygraph examinations seem to work because of the anxiety of being subject to a “lie detector test” will cause the person being tested to confess anyway (“The Truth”, 2004). Also, when concerning testing for police officer candidates, the questions have been described as unethical or discriminatory, including questions about an applicant's sexual background and/or lifestyle (Roberg et al, 2002).

The last issue, which encompasses all of the issues, is diversifying – adding more qualified women and minorities to the police force. Many feel there are pitfalls in the recruitment and hiring system for minorities and women. These can range from advertisements, to the educational requirement, physical fitness, psychological tests, etc. Decker and Huckabee suggest that by increasing educational standards, this could discourage minorities and women from applying for positions.

Under the Civil Rights Act of 1964 outlawed discrimination based upon ethnicity, gender, nationality, and religion. The Act was amended in 1972 to create the Equal Employment Opportunity Act which states “It shall be an unlawful employment practice for an employer to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.” Because of this act, it is illegal for an employer to discriminate based on the aforementioned criteria. However, because of the heavy screening for a job as a police officer, critics argue that it does cause discrimination and standards should be lowered to allow the hiring of more minorities (Roberg et al, 2002).

Diversifying a police department has been shown to make a police department more effective in its work ethic and with community relations. It has been shown that officers who are part of a minority group are easier to trust and empathize with when dealing with minority groups in the community, and vise versa. But, this is only testimonial evidence. There is no empirical evidence to demonstrate a positive or negative affect on focusing on having minority officers in the department (Roberg et al, 2002).

However, even with the lack of empirical evidence, police departments still specifically target minority groups as potential candidates. This includes lowering standards that are in place to determine whether or not a candidate is qualified to even perform the job. Some police departments were under court order, under affirmative action plans, to increase the number of women and minorities in the department, under the notion that the dominant demographic represented was white male. This led to certain allowances for individuals who were from a minority group (Roberg et al, 2002).

A recent court case, Ricci v. DeStefano, discussed racial bias in the hiring of individuals for a public service job. In the case, the fire department held an objective standardized examination for candidates considered for a management positions. The results showed the white and hispanic candidates performed better than the minority candidates. Because of the uproar it caused, the results were thrown out and nobody was promoted. The white and Hispanic candidates who were denied the promotion even though they were qualified for it filed civil charges against the city under Title VII of the Civil Rights Act of 1964. In this case, the Supreme Court held “before an employer can engage in intentional discrimination for the asserted purpose of avoiding or remedying an unintentional, disparate impact, the employer must have a strong basis in evidence to believe it will be subject to disparate-impact liability if it fails to take the race-conscious, discriminatory action.”

It is not that one person is better or more qualified because of their ethnic background, age, or gender, or any myriad of other qualifiers, it is simply put that the selection of law enforcement officers – people entrusted to uphold the social contract and are legally allowed to use force another individual – should be held to the highest standard.

In sum – the overarching ethical issue with the selection and hiring of officers is bias, whether it is physical, mental, racial, educational, etc. It begs the question if it is all necessary to recruit and hire the most qualified candidates for this job, keeping in mind that these individuals, these officers are placed in a position of trust and authority and can use force against people.

Ethical Systems

Ethical systems are defined as “a structured set of principles that defines what is moral” (Pollock, 2012). These types of systems are the basis of moral beliefs and decision making. Utilizing these systems will aid an individual in deciding the right and moral way of approaching the ethical implications of an issue. In the case of bias in the hiring of police officers, there are several different types of ethical systems that can explain the moral significance of this issue (Pollock, 2012).

Teleological Ethical System

A teleological ethical system focuses on the consequences of an action to determine the morality of an action – do the ends justify the means? The main vehicle of this system is utilitarianism, which main focus is the goodness of the act and how it affects the overall goodness in terms of consequences.
There are two types of utilitarianism – act and rule utilitarianism (Pollock, 2012).

Under act utilitarianism, it is the single incident that is being judged for morality. When considering the hiring of police officers, it is good to attract as many candidates as possible in order to find the best one. It is good to have high standards in place considering the nature of the job. And, it is good to encourage different people with different qualifications to apply for a position with a law enforcement agency – it allows for the agency to become more dynamic. The act in itself is good and moral. However, under utilitarianism, an act may be considered “good”, even if it was a “bad” act, if the consequences are perceived as “good” (Pollock, 2012). For instance, take a department who is court ordered to hire more minorities. They may have to lower the standards to hire these individuals, which appeases the order. Therefore, it is good. But, under rule utilitarianism, this act would be wrong.

Rule utilitarianism determines the “goodness” of an act if it is made into a rule or standard (Pollock, 2012). If preference was given to all minority candidates in order to hire more of them on, this act would be “bad” because it lowers the standards of the individuals hired on. As mentioned before, a law enforcement officer has a uniquely stressful job in that they are held to higher standard, placed in a position of authority, and are allowed to use force. If a candidate who is of a minority background is hired just because they are of a minority background does not mean that they are qualified for the position.

Critics argue that utilitarianism is very uncaring and objective. Bentham, the main proponent of this ethical system, did not weigh the moral significance of an act – just whether or not the action was good or bad. Also, critics point out that the rights of one may be sacrificed for the good of the many (Pollock, 2012). In this case, because the issue at hand deals with individual rights, a deontological ethical system can also be used to weigh the situation.

Deontological Ethical System

Deontological systems focus on the morality of the actor's intent. If a person's intent was good, even if the consequences were bad, the act is still good. The main vehicle for a deontological ethical system is ethical formalism – proposed by Immanuel Kant and focuses solely on the actor's good will (Pollock, 2012).

In the case of recruitment and hiring of candidates for a law enforcement position, the actor or actors (the person or group responsible for determining the hiring criteria) would be in the right. They are using their best judgment and good will to hire a candidate that they feels best fits the position based on the qualifications of that candidate whether they be subjective or objective. If the department has to lower the standards to allow for the hiring of minority candidates, this is still considered a good act because the will of the actor is good, regardless if an under qualified candidate is hired. However, under this ethical system there are other factors at play.

The two main imperatives involved in ethical formalism are categorical imperatives and hypothetical imperatives. A categorical imperative describes an action that is simply necessary regardless of outside factors. A hypothetical imperative is an if-then statement (Pollock 2012).

Using the categorical imperative the actor in this situation would be bound by duty – to hire quality candidates to fill a the position of a law enforcement officer position. They have to find the best candidate for the position, regardless of any auxiliary conditions. In the case presented, if the individual or group responsible for screening candidates is remiss in their duty and hires someone who is not qualified, the have done wrong. A categorical imperative is similar to rule utilitarianism in that it is not a short term issue.

Conversely, using a hypothetical imperative, their actions would be justifiable – the ends justify the means. Where a categorical imperative is stricter, the hypothetical imperative allows for desires; the actor is not bound by duty. If the desires of the actor are of good will the action is good (Pollock, 2012). Considering the issue at hand, the act would be considered “good”. The actor has the best intent in hiring minority candidates regardless of whether the applicant is qualified for the position because of the actor's desires and will being good, despite the consequences.

This ethical system is also limited in certain ways – the actor is bound by duty, regardless of what type of duty. For instance, take a prosecutor, whose job is to prove a person is guilty of a crime regardless of whether or not the person committed a crime. Also, this system does not take into account consequences of actions. With the issue of recruitment and selection of candidates for a law enforcement position, only the selection process is considered... not the consequences (Pollock, 2012).

Policy and Implications

Ultimately, the largest policy implication is the way in which police officers are recruited, selected, and hired and how the quality of the candidate affects the police department and the community as a whole.

The selection and training of police officers is one of the keys to eliminating police misconduct. Police misconduct comes in many different forms – accepting gratuities, excessive use of force, obstruction of justice, off duty illegal activities, and administrative failures. Gratuities include anything from buying an officer's lunch simply because they are an officer, and there is no personal relationship, down to bribery (or payment to cover up a crime). Excessive use of force is when a police officer oversteps their bounds. This occurs when something as simple a shove to a more extreme example of using lethal force in a situation that did not require it (Pollock, 2012).

A recent case of excessive use of force revolves around a patrol officer in Seattle, Washington who was suspended for eight days resulting in excessive use of force. This resulted from an incident in June where the officer, Eric Faust, had arrested an individual who was being uncooperative. The man was not guilty of any type of crime and was pulled over on a routine traffic stop (Miletich, 2013). Even though this was a minor issue, these types of incidents occur all the time.

Two other large issues plaguing law enforcement agencies are drugs and money, which often go hand in hand. There are some incidents, like Leo Liston, a now ex-officer in St. Louis, Missouri, who was sentenced to three months in prison for stealing $8,000 in cash during a drug bust. Or, Two officers, in Robeson County, North Carolina, who were indicted on embezzlement charges (Pollock, 2012).

These incidents can be curtailed by selection and training. There are tests and measures in place to ensure the best candidates for the position are selected. To subvert these measures can lead to incidents like those mentioned above.

In addition to hiring qualified officers, these officers must be trained to handle uniquely stressful or tempting situations. For instance, accepting gratuities needs to be emphasized as wrong and against policy with a deterring factor. Something as simple as accepting a free lunch solely because of being a law enforcement officer can lead to greater issues like the infamous police corruption that ran rampant in New York City during the 1980's. A ring of officers in the NYPD, dubbed the “Buddy Boys” were engaging in activities ranging from transporting firearms, drug use, bribery, drug sales, and armed robbery (Pollock, 2012). Training officers, and ensuring those who are being trained are the best and most qualified candidates before they are even hire, is one of the best ways to stop incidents like this from occurring.

When it comes to misconduct, Pollock mentions research data that shows different demographics for officers who are more likely to commit misconduct. The data demonstrated that the group least likely to be disciplined for misconduct is women, depending on the police culture of the department. However, females were more likely to be terminated during probationary periods and terminated for off-duty illegal activities. Male officers are more likely to be terminated due to excessive use of force and brutality. Research also shows that college educated officers received less citizen complaints and also terminated less for misconduct. Black officers were shown to be disciplined more for misconduct, over any other minority, due to drug test failures and off duty criminal activity.

Also, instead of hiring an individual simply because they are of a minority group, who may be under qualified, in order to better community relations, train the officers to utilize more community-centric police tactics. As mentioned before, Los Angeles spend a great deal of money training a new officer. It would be more economical to train the existing officers to have better community relations skills, instead of hiring an individual who was held to lower standards because of political correctness.

Overall, from the research Pollock presented, higher educational standards, regardless of ethnicity or gender, as well as length of service, and older candidates demonstrated the best indicator for not being disciplined for misconduct. When discussing the hiring of officers, educational background, as well as the already prominent background check should be the two largest items considered when considering a candidate.

Conclusion

Each police department has its own qualifiers for selecting a candidate. They weigh out the results of the examination tools they feel best suit their needs and the needs of the community whether it is education, physical fitness, polygraph test, the background check or any other determining factors including ethnicity, gender, or age. Each candidate must meet the agency's particular criteria in order to even be considered for hire. There are many different factors, opinions, and even laws that determine who can be “weeded out” for the position.

Until there is more and better research in determining which candidates are best suited for the position of a law enforcement officer, the agencies and departments have to use ethical systems such as utilitarianism and ethical formalism to determine whether or not they are doing the right thing by hiring a particular candidate.






























Works Cited:

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