News
Judges and Judiciary
Dec. 30, 1999
Bird Soared To New Heights, Whether in Victory or Defeat
Old campaign buttons recall the ugly, uneven 1986 judicial retention war between Rose Bird and her foes. Supporters of the overmatched California chief justice and her beleaguered colleagues, Joseph Grodin and Cruz Reynoso, wore tiny low-key disks that quietly pleaded, "Affirm the Justices."
Rose Bird
1936-1999
California Chief Justice
Rose Bird
1936-1999
California Chief Justice
Career Highlights: California chief justice, 1977-86; California secretary of agriculture, 1975-77; Santa Clara deputy PD, 1966-74; clerk, chief justice, Nevada Supreme Court, 1965-66
Law School: Boalt Hall, 1965
By John Roemer
Daily Journal Staff Writer
Old campaign buttons recall the ugly, uneven 1986 judicial retention war between Rose Bird and her foes.
Supporters of the overmatched California chief justice and her beleaguered colleagues, Joseph Grodin and Cruz Reynoso, wore tiny low-key disks that quietly pleaded, "Affirm the Justices."
Opponents sported yellow badges the size of doorknobs emblazoned, "Recall Rose Bird" and "Restore Justice." The buttons displayed scales with a map of California outweighed by a rose and a flapping pigeon.
After contentious campaigning in which opponents spent a record $10 million and the justices less than a twentieth of that, the politically liberal Bird in November 1986 lost all 58 counties in California except San Francisco and Alameda.
The no-on-Bird vote was 66 percent to 34 percent. Reynoso mustered 40 percent approval and Grodin got 43 percent, nowhere near enough to keep their seats.
"She was an excellent chief justice, and I don't think she'll get credit for it anytime soon," said Stephen Buehl, who served as Bird's executive assistant and now is a partner at Gagen McCoy McMahon & Armstrong in St. Helena. "I don't think she was treated at all fairly."
Buehl recalled a bar association magazine published after the election that showed an artist painting portraits of California chief justices - with Bird omitted.
"It was as if she'd been written out of the history books," he said. "It was a dismissal of her in a poignant way."
Grodin recently protested that to ask for an assessment of the Bird years was asking a lot. "It's like being asked to describe World War II," he said.
Longtime antagonist Ronald A. Zumbrun cheered the fall of Bird and said the vote against her reverberated across the country as a rejection of a liberal, activist judiciary.
"We sent a major message that had a chilling effect nationally on the direction the law was taking," said Zumbrun, a Ronald Reagan gubernatorial appointee to a welfare reform team and a founder of the conservative Pacific Legal Institute. He is now in private practice at the Zumbrun Law Firm in Sacramento. "There was revulsion toward judicial activism," he said.
In the spring of 1977, Bird took over a state Supreme Court thought by many to have become, under Chief Justice Donald Wright and Acting Chief Justice Mathew O. Tobriner, the finest in the country. Bird also inherited a growing disquiet among the state's businesspeople over the panel's trend of liberal decisions.
Bird's rejection by voters nine years later was a unique event in California Supreme Court history, one that altered forever the state's legal landscape.
Before Rose Bird, appellate courts maintained a low profile. No major news organization assigned a reporter regularly to cover the state Supreme Court.
Since Bird, judges have found themselves judged politically. Their decisions rate headlines. The black robe has acquired notoriety and cachet.
But as the jurisprudential sun rose, Bird, who died Dec. 4 at 63, sought the shade.
Bird, who lived in Palo Alto, let her bar card lapse and no longer practiced law. She avoided interviews and most public appearances after 1986, though she briefly did some television commentary and wrote a syndicated newspaper column. A promised book was not forthcoming. An attorney who remained close to her said she had surgery for breast cancer last year, and complications from the disease led to her death.
Yet Bird lives. Her reluctance to reply to reporters' queries seemed understandable. As chief justice she answered her share of tough questions, and she continues to speak through the 161 opinions she wrote on consumer rights, the duties of landlords and insurance companies, free speech and even the standards for deciding when to sanction attorneys for filing frivolous appeals.
Reynoso, who teaches at UCLA School of Law and is special counsel at Kaye Scholer Fierman Hays & Handler in Los Angeles, did not return a phone call requesting comment.
Grodin, a faculty member at Hastings College of the Law in San Francisco, observed that a chief legacy of the Rose Bird years is that voters now equate judges with lawmakers.
"There's been a tendency ever since to view court decisions in political terms," Grodin said. "Thankfully, the conditions for repeating what happened in the Bird era have not recurred."
Grodin pointed out, however, that the campaign mounted last year by abortion protesters against Chief Justice Ronald M. George and Associate Justice Ming W. Chin echoed the battle to unseat Bird and her colleagues.
Though ultimately unsuccessful at the ballot box, the outcry forced George and Chin to raise and spend more than $1 million defending themselves.
"The situation reflected the assumption that judges act like legislators and should be evaluated the same way," Grodin said.
"It's an extremely difficult subject to speak to without being boring and philosophical, but the public tends to take an exaggerated view of the extent to which a judge's opinions are determined by his own personal view of morality or politics."
That was an argument Bird and her supporters found difficult to make convincingly.
Bird-bashers had been gunning for her even before Gov. Jerry Brown appointed her as the first woman ever to serve on the state's high court. As Brown's secretary of agriculture, the former Santa Clara County deputy public defender had become notorious to the state's powerful agribusiness lobby for prohibiting use of the short hoe and for drafting the Agriculture Labor Relations Act, empowering Cesar Chavez' United Farm Workers Union.
After she joined the bench, five unsuccessful signature-gathering recall drives preceded the retention election that finally brought her down - and produced a stormy climate starkly at odds with the ideal of judicial serenity.
Death threats against Bird forced armed state troopers to accompany her as bodyguards in public. Two hundred forty-three California law school professors signed a statement saying it was "destructive to inject partisan politics" into the state Supreme Court and pledged support for all six justices on the 1986 ballot.
With the votes counted, Gov. George Deukmejian's two appointments to the Bird court, Malcolm Lucas and Edward Panelli, were each retained by 79 percent of the votes. And Stanley Mosk, a liberal who unlike Bird voted to uphold a number of death sentences, got 74 percent and was unopposed throughout the campaign.
Bird's landslide loss was widely read as a judgment by voters fearful of crime and outraged by her votes against executions in each of the 61 death penalty cases that came before her during her nine years as chief justice.
But the frenzy over the death penalty was largely the creation of California businesspeople concerned that the court's liberal bias on economic questions was costing them money, Bird and her defenders have long argued.
A pro-Bird group of professors from 13 law schools charged that many Chamber of Commerce types wanted to replace Bird, Grodin and Reynoso with justices "more subservient to their interests."
Oil and natural gas lobbies, for example, contributed $51,225 to defeat the court liberals in the wake of Western Oil and Gas Assn. v. California Air Resources Board, 32 Cal.3d 347 (1984), in which Grodin wrote the majority decision upholding strict clean air standards.
Auto dealers forked over $23,935 to anti-Bird forces after the chief justice wrote a unanimous consumer-rights decision in Ford Dealers Assn. v. California Department of Motor Vehicles, 37 Cal.3d 502 (1982). The court ruled dealers can be responsible for what car salespeople say under truth-in-advertising regulations.
"There's very little doubt that the death penalty issue was selected as a flag behind which to rally forces opposed to the court's decisions affecting working people and consumers," Grodin said. "Also, gender was a subtext. An undercurrent of hostility stemmed from the fact that she was a woman in charge, and the hostility was an attitude not confined to men."
Once Bird was gone, Deukmejian elevated Lucas to be chief justice and appointed conservatives Marcus Kaufman, John Arguelles and David Eagleson to the high bench. The new majority took a dramatically different view of business issues.
Landlords, for instance, had taken a major hit from the Bird court's decision in Isaacs v. Huntington Memorial Hospital, 38 Cal.3d 112 (1985), rejecting the rule that one prior incident of violence or harm must occur before a propertyholder may be liable for personal injury damages.
Bird rejected the rule as unfair. "Surely, a landowner should not get one free assault before he can be held liable for criminal acts which occur on his property," she wrote for a unanimous court.
In 1993, the Lucas court struck back, handing landlords a big win in Ann M. v. Pacific Plaza Shopping Center, 6 Cal.4th 666. A woman raped at a mall could not recover damages because the owner's duty did not include supplying security guards in common areas, Panelli wrote. His analysis made clear that the one-prior-incident rule was back.
Mosk, in a blistering dissent, complained that Lucas was doing a 180-degree turnaround from his prior position in Isaacs: "The Isaacs decision should be controlling in the instant case, the bottom line being that the issue of liability and what the majority gratuitously describe as 'an unfair burden on landlords' are factual matters that should be decided by a jury, not by summary judgment."
Lucas, who currently works for JAMS in Los Angeles, did not return a call requesting comment.
The Isaacs question remains a hot one. On Dec. 16, the Supreme Court decided Sharon P. v. Arman Ltd., 1999 Daily Journal D.A.R. 12615, a case of sexual assault of a tenant in a building's underground parking garage.
Following Ann M., Los Angeles Superior Court Judge Richard Neidorf found for the defendant on summary judgment. The 2d District Court of Appeal reversed, holding the building's owner owed a duty of care to the tenant. The state Supreme Court granted review, seeking to harmonize Ann M. with Isaacs. Underground parking garages are not "inherently dangerous" locations that automatically subject their owners to tort liability for crimes committed there, the divided court ruled.
Once again, Mosk wrote a blazing dissent. The majority view "defies logic," he said. "And the result is demonstrably unjust."
Ironically, one of Bird's former law clerks, Paul D. Fogel, found himself arguing in Sharon P. against his former boss' position as an amicus for a consortium of security services.
Fogel, now an appellate specialist at Crosby Heafy Roach & May in San Francisco, contended for his client that the prior similar incident rule should be the law.
He declined to comment on whether he and Bird had ever discussed the matter. But he agreed that economic forces were behind the effort to recall Bird, Grodin and Reynoso.
"I think there's some merit to that viewpoint," he said last month .
Fogel mentioned a 1979 decision in Royal Globe Insurance Co. v. Superior Court, 23 Cal.3d 880, a slip-and-fall case in which the Bird court alarmed the insurance industry by holding that third-party claimants could sue insurers for bad faith.
Soon after Lucas became chief justice, he wrote a majority opinion overturning Royal Globe. In Moradi-Shalal v. Fireman's Fund Insurance Co., 46 Cal.3d 287 (1988), the court said that, in insurance cases, third parties no longer would have a bad faith cause of action.
"That was unexpected because the issue was not before the court," Fogel said.
His surprise was matched by that of Mosk, who in another strong dissent commented, "In the trial court, defendant demurred and at no time there or in the Court of Appeal raised any question about the continued vitality of Royal Globe....The insurance industry asked for a loaf of bread. The majority, with remarkable magnanimity, gave it the whole bakery."
Mosk added, "The majority have now replaced Royal Globe with a 'Royal Bonanza' for insurance carriers, i.e., total immunity for unfair and deceptive practices committed on innocent claimants. They have exalted principal over principle."
Fogel suggested a short representative list of other Bird decisions that made significant law:
??????????????????????????????????????????????????????????????????????????????????????????? Moles v. Regants, 32 Cal.3d 867 (1983), established the right of litigants to oral argument in civil cases.
??????????????????????????????????????????????????????????????????????????????????????????? Koire v. Metro Car Wash, 40 Cal.3d 24 (1985), held that "Ladies Day" discounts reinforced harmful stereotypes and violated the sex discrimination provisions of the Unruh Civil Rights Act.
??????????????????????????????????????????????????????????????????????????????????????????? Isbister v. Boys' Club of Santa Cruz, Inc., 40 Cal.3d 72 (1985), written by Grodin with a separate concurrence by Bird, ruled that the Unruh Act bars boys' clubs from discriminating against girls who want to join.
??????????????????????????????????????????????????????????????????????????????????????????? Press v. Lucky Stores Inc., 34 Cal.3d 311 (1983), ratified the award of attorney fees to plaintiffs who established their right to gather ballot initiative signatures at a shopping center.
??????????????????????????????????????????????????????????????????????????????????????????? Hovey v. Superior Court, 28 Cal.3d 1 (1980), contradicted the public image of Bird as soft on crime by approving the exclusion of jurors in the guilt phase of death-penalty cases who are unequivocally opposed to capital punishment.
??????????????????????????????????????????????????????????????????????????????????????????? Baker v. Los Angeles Herald Examiner, 42 Cal.3d 254 (1986) shielded journalistic opinion from suits for defamation.
??????????????????????????????????????????????????????????????????????????????????????????? In re Marriage of Flaherty, 31 Cal.3d 637 (1982), held that juddges should not impose penalties for bringing allegedly frivolous appeals without giving fair warning, affording the attorney an opportunity to respond, and holding a hearing.
"Rose Bird made it clear that the law is a tool to effect social change," Fogel said. "She really shook things up."
1936-1999
California Chief Justice
Rose Bird
1936-1999
California Chief Justice
Career Highlights: California chief justice, 1977-86; California secretary of agriculture, 1975-77; Santa Clara deputy PD, 1966-74; clerk, chief justice, Nevada Supreme Court, 1965-66
Law School: Boalt Hall, 1965
Supporters of the overmatched California chief justice and her beleaguered colleagues, Joseph Grodin and Cruz Reynoso, wore tiny low-key disks that quietly pleaded, "Affirm the Justices."
Opponents sported yellow badges the size of doorknobs emblazoned, "Recall Rose Bird" and "Restore Justice." The buttons displayed scales with a map of California outweighed by a rose and a flapping pigeon.
After contentious campaigning in which opponents spent a record $10 million and the justices less than a twentieth of that, the politically liberal Bird in November 1986 lost all 58 counties in California except San Francisco and Alameda.
The no-on-Bird vote was 66 percent to 34 percent. Reynoso mustered 40 percent approval and Grodin got 43 percent, nowhere near enough to keep their seats.
"She was an excellent chief justice, and I don't think she'll get credit for it anytime soon," said Stephen Buehl, who served as Bird's executive assistant and now is a partner at Gagen McCoy McMahon & Armstrong in St. Helena. "I don't think she was treated at all fairly."
Buehl recalled a bar association magazine published after the election that showed an artist painting portraits of California chief justices - with Bird omitted.
"It was as if she'd been written out of the history books," he said. "It was a dismissal of her in a poignant way."
Grodin recently protested that to ask for an assessment of the Bird years was asking a lot. "It's like being asked to describe World War II," he said.
Longtime antagonist Ronald A. Zumbrun cheered the fall of Bird and said the vote against her reverberated across the country as a rejection of a liberal, activist judiciary.
"We sent a major message that had a chilling effect nationally on the direction the law was taking," said Zumbrun, a Ronald Reagan gubernatorial appointee to a welfare reform team and a founder of the conservative Pacific Legal Institute. He is now in private practice at the Zumbrun Law Firm in Sacramento. "There was revulsion toward judicial activism," he said.
In the spring of 1977, Bird took over a state Supreme Court thought by many to have become, under Chief Justice Donald Wright and Acting Chief Justice Mathew O. Tobriner, the finest in the country. Bird also inherited a growing disquiet among the state's businesspeople over the panel's trend of liberal decisions.
Bird's rejection by voters nine years later was a unique event in California Supreme Court history, one that altered forever the state's legal landscape.
Before Rose Bird, appellate courts maintained a low profile. No major news organization assigned a reporter regularly to cover the state Supreme Court.
Since Bird, judges have found themselves judged politically. Their decisions rate headlines. The black robe has acquired notoriety and cachet.
But as the jurisprudential sun rose, Bird, who died Dec. 4 at 63, sought the shade.
Bird, who lived in Palo Alto, let her bar card lapse and no longer practiced law. She avoided interviews and most public appearances after 1986, though she briefly did some television commentary and wrote a syndicated newspaper column. A promised book was not forthcoming. An attorney who remained close to her said she had surgery for breast cancer last year, and complications from the disease led to her death.
Yet Bird lives. Her reluctance to reply to reporters' queries seemed understandable. As chief justice she answered her share of tough questions, and she continues to speak through the 161 opinions she wrote on consumer rights, the duties of landlords and insurance companies, free speech and even the standards for deciding when to sanction attorneys for filing frivolous appeals.
Reynoso, who teaches at UCLA School of Law and is special counsel at Kaye Scholer Fierman Hays & Handler in Los Angeles, did not return a phone call requesting comment.
Grodin, a faculty member at Hastings College of the Law in San Francisco, observed that a chief legacy of the Rose Bird years is that voters now equate judges with lawmakers.
"There's been a tendency ever since to view court decisions in political terms," Grodin said. "Thankfully, the conditions for repeating what happened in the Bird era have not recurred."
Grodin pointed out, however, that the campaign mounted last year by abortion protesters against Chief Justice Ronald M. George and Associate Justice Ming W. Chin echoed the battle to unseat Bird and her colleagues.
Though ultimately unsuccessful at the ballot box, the outcry forced George and Chin to raise and spend more than $1 million defending themselves.
"The situation reflected the assumption that judges act like legislators and should be evaluated the same way," Grodin said.
"It's an extremely difficult subject to speak to without being boring and philosophical, but the public tends to take an exaggerated view of the extent to which a judge's opinions are determined by his own personal view of morality or politics."
That was an argument Bird and her supporters found difficult to make convincingly.
Bird-bashers had been gunning for her even before Gov. Jerry Brown appointed her as the first woman ever to serve on the state's high court. As Brown's secretary of agriculture, the former Santa Clara County deputy public defender had become notorious to the state's powerful agribusiness lobby for prohibiting use of the short hoe and for drafting the Agriculture Labor Relations Act, empowering Cesar Chavez' United Farm Workers Union.
After she joined the bench, five unsuccessful signature-gathering recall drives preceded the retention election that finally brought her down - and produced a stormy climate starkly at odds with the ideal of judicial serenity.
Death threats against Bird forced armed state troopers to accompany her as bodyguards in public. Two hundred forty-three California law school professors signed a statement saying it was "destructive to inject partisan politics" into the state Supreme Court and pledged support for all six justices on the 1986 ballot.
With the votes counted, Gov. George Deukmejian's two appointments to the Bird court, Malcolm Lucas and Edward Panelli, were each retained by 79 percent of the votes. And Stanley Mosk, a liberal who unlike Bird voted to uphold a number of death sentences, got 74 percent and was unopposed throughout the campaign.
Bird's landslide loss was widely read as a judgment by voters fearful of crime and outraged by her votes against executions in each of the 61 death penalty cases that came before her during her nine years as chief justice.
But the frenzy over the death penalty was largely the creation of California businesspeople concerned that the court's liberal bias on economic questions was costing them money, Bird and her defenders have long argued.
A pro-Bird group of professors from 13 law schools charged that many Chamber of Commerce types wanted to replace Bird, Grodin and Reynoso with justices "more subservient to their interests."
Oil and natural gas lobbies, for example, contributed $51,225 to defeat the court liberals in the wake of Western Oil and Gas Assn. v. California Air Resources Board, 32 Cal.3d 347 (1984), in which Grodin wrote the majority decision upholding strict clean air standards.
Auto dealers forked over $23,935 to anti-Bird forces after the chief justice wrote a unanimous consumer-rights decision in Ford Dealers Assn. v. California Department of Motor Vehicles, 37 Cal.3d 502 (1982). The court ruled dealers can be responsible for what car salespeople say under truth-in-advertising regulations.
"There's very little doubt that the death penalty issue was selected as a flag behind which to rally forces opposed to the court's decisions affecting working people and consumers," Grodin said. "Also, gender was a subtext. An undercurrent of hostility stemmed from the fact that she was a woman in charge, and the hostility was an attitude not confined to men."
Once Bird was gone, Deukmejian elevated Lucas to be chief justice and appointed conservatives Marcus Kaufman, John Arguelles and David Eagleson to the high bench. The new majority took a dramatically different view of business issues.
Landlords, for instance, had taken a major hit from the Bird court's decision in Isaacs v. Huntington Memorial Hospital, 38 Cal.3d 112 (1985), rejecting the rule that one prior incident of violence or harm must occur before a propertyholder may be liable for personal injury damages.
Bird rejected the rule as unfair. "Surely, a landowner should not get one free assault before he can be held liable for criminal acts which occur on his property," she wrote for a unanimous court.
In 1993, the Lucas court struck back, handing landlords a big win in Ann M. v. Pacific Plaza Shopping Center, 6 Cal.4th 666. A woman raped at a mall could not recover damages because the owner's duty did not include supplying security guards in common areas, Panelli wrote. His analysis made clear that the one-prior-incident rule was back.
Mosk, in a blistering dissent, complained that Lucas was doing a 180-degree turnaround from his prior position in Isaacs: "The Isaacs decision should be controlling in the instant case, the bottom line being that the issue of liability and what the majority gratuitously describe as 'an unfair burden on landlords' are factual matters that should be decided by a jury, not by summary judgment."
Lucas, who currently works for JAMS in Los Angeles, did not return a call requesting comment.
The Isaacs question remains a hot one. On Dec. 16, the Supreme Court decided Sharon P. v. Arman Ltd., 1999 Daily Journal D.A.R. 12615, a case of sexual assault of a tenant in a building's underground parking garage.
Following Ann M., Los Angeles Superior Court Judge Richard Neidorf found for the defendant on summary judgment. The 2d District Court of Appeal reversed, holding the building's owner owed a duty of care to the tenant. The state Supreme Court granted review, seeking to harmonize Ann M. with Isaacs. Underground parking garages are not "inherently dangerous" locations that automatically subject their owners to tort liability for crimes committed there, the divided court ruled.
Once again, Mosk wrote a blazing dissent. The majority view "defies logic," he said. "And the result is demonstrably unjust."
Ironically, one of Bird's former law clerks, Paul D. Fogel, found himself arguing in Sharon P. against his former boss' position as an amicus for a consortium of security services.
Fogel, now an appellate specialist at Crosby Heafy Roach & May in San Francisco, contended for his client that the prior similar incident rule should be the law.
He declined to comment on whether he and Bird had ever discussed the matter. But he agreed that economic forces were behind the effort to recall Bird, Grodin and Reynoso.
"I think there's some merit to that viewpoint," he said last month .
Fogel mentioned a 1979 decision in Royal Globe Insurance Co. v. Superior Court, 23 Cal.3d 880, a slip-and-fall case in which the Bird court alarmed the insurance industry by holding that third-party claimants could sue insurers for bad faith.
Soon after Lucas became chief justice, he wrote a majority opinion overturning Royal Globe. In Moradi-Shalal v. Fireman's Fund Insurance Co., 46 Cal.3d 287 (1988), the court said that, in insurance cases, third parties no longer would have a bad faith cause of action.
"That was unexpected because the issue was not before the court," Fogel said.
His surprise was matched by that of Mosk, who in another strong dissent commented, "In the trial court, defendant demurred and at no time there or in the Court of Appeal raised any question about the continued vitality of Royal Globe....The insurance industry asked for a loaf of bread. The majority, with remarkable magnanimity, gave it the whole bakery."
Mosk added, "The majority have now replaced Royal Globe with a 'Royal Bonanza' for insurance carriers, i.e., total immunity for unfair and deceptive practices committed on innocent claimants. They have exalted principal over principle."
Fogel suggested a short representative list of other Bird decisions that made significant law:
??????????????????????????????????????????????????????????????????????????????????????????? Moles v. Regants, 32 Cal.3d 867 (1983), established the right of litigants to oral argument in civil cases.
??????????????????????????????????????????????????????????????????????????????????????????? Koire v. Metro Car Wash, 40 Cal.3d 24 (1985), held that "Ladies Day" discounts reinforced harmful stereotypes and violated the sex discrimination provisions of the Unruh Civil Rights Act.
??????????????????????????????????????????????????????????????????????????????????????????? Isbister v. Boys' Club of Santa Cruz, Inc., 40 Cal.3d 72 (1985), written by Grodin with a separate concurrence by Bird, ruled that the Unruh Act bars boys' clubs from discriminating against girls who want to join.
??????????????????????????????????????????????????????????????????????????????????????????? Press v. Lucky Stores Inc., 34 Cal.3d 311 (1983), ratified the award of attorney fees to plaintiffs who established their right to gather ballot initiative signatures at a shopping center.
??????????????????????????????????????????????????????????????????????????????????????????? Hovey v. Superior Court, 28 Cal.3d 1 (1980), contradicted the public image of Bird as soft on crime by approving the exclusion of jurors in the guilt phase of death-penalty cases who are unequivocally opposed to capital punishment.
??????????????????????????????????????????????????????????????????????????????????????????? Baker v. Los Angeles Herald Examiner, 42 Cal.3d 254 (1986) shielded journalistic opinion from suits for defamation.
??????????????????????????????????????????????????????????????????????????????????????????? In re Marriage of Flaherty, 31 Cal.3d 637 (1982), held that juddges should not impose penalties for bringing allegedly frivolous appeals without giving fair warning, affording the attorney an opportunity to respond, and holding a hearing.
"Rose Bird made it clear that the law is a tool to effect social change," Fogel said. "She really shook things up."
#274446
John Roemer
Daily Journal Staff Writer
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