Published in Jewish Insider 3/7/24; Story by Haley Cohen

Task force punts on whether some slogans chanted at anti-Israel rallies are antisemitic

The recommendations handed down earlier this week from Columbia University’s task force on antisemitism painted a picture of Jewish students feeling “isolation and pain” in the wake of pro-Palestinian protests that have gripped the campus since Oct. 7. 

They also cited a lack of disciplinary response from the university regarding unauthorized protests of the Israel-Hamas war as contributing to Jewish students’ struggles on campus, and called for the university to more effectively investigate policy violations by creating an easier process for filing complaints.

But on the pivotal question of whether some of the slogans chanted at those rallies veer from legitimate political speech into antisemitism the task force’s recommendations are ambiguous.

The report states, “Obviously, the chants ‘gas the Jews’ and ‘Hitler was right’ are calls to genocide, but fortunately no one at Columbia has been shouting these phrases… Rather, many of the chants at recent Columbia protests are viewed differently by different members of the Columbia community: some feel strongly that these are calls to genocide, while others feel strongly that they are not.” 

The report does not, however, specifically address the slogan “from the river to the sea Palestine will be free,” which has frequently been chanted at protests on Columbia’s campus and is widely viewed by Jewish groups as a call for genocide of Israelis.

According to David Schizer, a professor of law and economics and dean emeritus of Columbia’s law school, who is one of the three co-chairs of the task force, the key issue that the 24-page report addresses is the thorny matter of campus free speech — emphasizing that “everyone needs to have a right to speak and to protest,” he said. 

“How can we make sure the people have the right to speak and protest, while at the same time ensuring that protests don’t interfere with the ability of other members of the community to teach classes, study for a test, to hear their professors,” Schizer, who is also the former CEO of the American Jewish Joint Distribution Committee, continued. While the report emphasizes the right to peaceful demonstrations, it also condemns faculty for participating in unauthorized demonstrations.

But some prominent leaders of the movement to fight antisemitism in higher education expressed skepticism that a set of recommendations could fix the raging antisemitism on Columbia’s campus — which has included repeated violations of the rules on protests and physical assault and other serious attacks on Jewish students. 

“The new recommendations have some technically good work which could provide incremental advances, but it’s certainly not the kind of thing that will solve Columbia’s problems,” Kenneth Marcus, founder of the Louis D. Brandeis Center for Human Rights Under Law, told JI. The Brandeis Center recently filed federal complaints against the University of California for antisemitism at UC Berkeley and American University, while the Department of Education is currently investigating Brandeis Center complaints filed against Wellesley, SUNY New Paltz, the University of Southern California, Brooklyn College and the University of Illinois for violating Title VI of the Civil Rights Act and for discrimination against Jewish students.

The recommendations come as Columbia faces pressure from donors and investigations by Congress and the Biden administration over antisemitism. It also comes in the wake of scrutiny regarding a number of antisemitism task forces set up at elite universities as a response to the surge in antisemitism that erupted following the Oct. 7 Hamas terror attacks in Israel. Five months later, questions remain over the effectiveness and direction of such groups — with some experts claiming task forces have been all talk with minimal action so far

But Schizer said that in Columbia’s case, there have been months of ongoing research of university policies, including interviewing students. It aims to release a series of reports in the coming months with the goal of gaining a deeper understanding of the campus climate and providing further recommendations.

The report states that while it agrees with the university’s principle that calls for genocide, like other incitement to violence, violate the rules, “the application of it should be clarified.”

It goes on to encourage the university’s legal team to “provide more guidance on this issue,” and emphasizes that clearer guidance is needed, like the university has done with its rules on gender-based misconduct to include “scenarios,” “to provide greater clarity help to provide fair notice, so Columbia affiliates have more of a sense of what is permissible (even if offensive) and what is not.” 

Columbia administration plans to review the task force’s interim policy at the end of this semester. Minouche Shafik, the university’s president, said in a statement that the new recommendations —  the first set in a series — are welcomed by the university and “will continue across a number of fronts as the University works to address this ancient, but sadly persistent, form of hate.” 

Marcus said it’s “good that Columbia finally has good people asking serious questions about harassment and disruptive protests,” but he added, “What’s needed is not just a few recommendations regarding the rules on protest. The fact is that there’s been antisemitic bigotry [at] Columbia University for decades now.”

“It’s not as if a few changes to the protest policies are going to substantially change the institution as long as they continue business as usual,” he continued. “Much of what’s in this new set of recommendations could have been written on Oct. 6 given everything that’s happened since. What’s needed is not a series of incremental measures, but a rethinking of what Columbia is doing to cause harm, not just to Jewish students but also to the surrounding community. These recommendations may lead to technical and marginal changes in the ways that the university responds to specific incidents, and generally speaking that’s a good thing. 

But it’s certainly not a solution to the problem.” 

Marcus noted that the recommendations are “framed fairly narrow, with response to only one narrow piece of the problem.” 

“I know this is only one of the series of reports that we can anticipate, but if this is an indication of what’s to come, it may provide some useful professional iteration but not a truly substantial change,” he said. “It does not indicate a new mindset that is ready to deal with the problems Oct. 7 has revealed.” 

Mark Yudof, chair of the Academic Engagement Network, expressed a similar sentiment as Marcus, but added that he’s “hopeful” the report will bring change. Schizer, as well as the two other co-chairs of the task force, Ester Fuchs and Nicolas Lemann, are all longtime members of AEN. 

“We need adequate rules about speech and we need to put teeth into it and have reasonable procedures in which people are actually disciplined for violating the rules,” Yudof said, calling the report “complex.” 

While skeptical, Yudof also expressed praise for the recommendations — “I think Columbia’s report gets at the core problem of education and I applaud them,” he said. 

“I like the report and am hopeful… I would urge the Columbia administration to adopt the recommendations of the task force, but the proof will be in the pudding.”

Published 12/27/23 by Campus Reform; Story by Patrick McDonald

In late November, several Jewish organizations filed a lawsuit against the University of California, Berkeley, alleging a ‘longstanding, unchecked spread of anti-Semitism.’
The lawsuit was filed in a federal court in San Francisco by the Louis D. Brandeis Center and Jewish Americans for Fairness in Education.

In late November, several Jewish organizations filed a lawsuit against the University of California, Berkeley, alleging a “longstanding, unchecked spread of anti-Semitism” at the college.

Filed in a federal court in San Francisco by the Louis D. Brandeis Center and Jewish Americans for Fairness in Education, the lawsuit is one of only a few brought against large colleges since the Israel-Hamas war broke out in October.

The lawsuit claims that the lack of a university response to anti-Semitism on campus has “erupted in on-campus displays of hatred, harassment, and physical violence against Jews,” necessitating a court intervention. It also states that “no fewer than 23” student organizations at UC Berkeley School of Law have enacted discriminatory policies that “exclude Jewish students, faculty, and scholars.” 

Specifically, the document points to Women of Berkeley Law, the Queer Caucus at Berkeley, and the Asian Pacific American (APA) Law Students Association. According to the lawsuit, to join these student groups, students must support the anti-Israel Boycott, Divestment, Sanctions (BDS) movement.

Additionally, the suit mentions Berkeley Law Legal Services organizations, which require students to take a “Palestine 101” training program—a program that allegedly “emphasizes the illegitimacy of the State of Israel.”

Although the UC administration “publicly acknowledged the fundamentally anti-Semitic nature” of various student groups, the plaintiffs allege that the school has “taken no action to address them.”

The plaintiffs identify alleged acts of unaddressed anti-Semitism, including a professor ranting against Israel for 18 minutes in the presence of around 1,000 freshmen, “anti-Semitic mobs” on campus who cause Jewish students to feel “afraid to go to class,” and a Jewish student being attacked by two pro-Palestinian protesters and hit in the head with a metal water bottle.

The plaintiffs also aim to change the university’s response to anti-Semitism through a court order mandating that UC Berkeley uphold its nondiscrimination policies, and refrain from providing support or recognition to campus organizations that exclude Jewish students.

In an interview with The Hill, Dan Mogulof, an assistant vice chancellor at UC Berkeley, denied the allegations made in the lawsuit, saying that UC Berkeley has “long committed to confronting” anti-Semitism. He specifically pointed to UC Berkeley’s “Antisemitism Education Initiative” that began in fall 2019.

Campus Reform has contacted the University of California, Berkeley and the Louis D. Brandeis Center for comment. This article will be updated accordingly.

Published 12/28/23 by JewishPress.com; Q&A by Alan Zeitlin

A Q&A with Kenneth Marcus

Kenneth L. Marcus is at the forefront of the battle against antisemitism in the U.S. He is the founder and chairman of the Louis D. Brandeis Center for Human Rights Under Law which handles numerous complaints of antisemitism from Jewish college students as well as from other arenas. Some of these complaints have resulted in federal investigations and lawsuits. From 2018-19, he served as Assistant Secretary for Civil Rights at the United States Department of Education in the administration of then President Donald Trump. He is also the author of The Definition of Anti-Semitism and Civil Rights in America. For a time, he was a visiting professor at Yeshiva University.

Marcus spoke with The Jewish Press about whether or not Jewish parents should still send their children to Harvard, UPenn, or MIT, whether a group that calls itself a Muslim civil rights group has shown itself to be extremist, and one step he thinks would help in the fight against antisemitism.

Were you surprised that in the congressional hearing, the presidents of Harvard, Penn, and MIT refused to say that calling for the genocide of Jews was against their university codes of conduct?

I was surprised that the university presidents did such a poor job of responding to questions that should not have been so difficult for them to answer. There are many things they could have said that would have assured Congress and the public that they were properly focused on fighting campus antisemitism. They failed to do that. They gave narrow, lawyerly answers that suggested an inability to address problems that are not merely societal but have engulfed their own campuses.

Liz Magill resigned from her position leading UPenn. The three women appeared to provide similar answers during the hearing. Do you think the other two presidents should resign or be fired?

I don’t think President Magill was notably worse than [Harvard] President [Claudine] Gay who also failed to respond in a presidential way. To me, the bigger issue is not whether additional presidents resign or are fired. The bigger question is whether these universities are willing to tackle these issues in a very serious way. Simply removing a president is hardly enough, if there isn’t a will to make substantial changes both in the policies and the culture.

The hearing was viewed by many people, and there is a fear that such answers normalize antisemitism. Do you think that even if there are new leaders, anything will change?

This hearing has had an impact on our society which is only beginning to be felt. There are many people, including strongly self-identified Jewish Americans, who were at best passingly aware of antisemitism on college campuses until very recently. Even after October 7, there were some who didn’t get the magnitude of the problem. But now, it is very much in the news and on people’s minds. I have talked to many people who were unaware of the issue until recently who are now enraged and are calling for serious change. This is a moment that creates opportunities. It’s not about changing individuals; it’s about changing culture, and I hope we have the moment to do that.

Some Jewish parents are saying they now may not want to send their kids to Harvard, Penn, or MIT. What would you advise?

There are parents saying they would rather send their children to Yeshiva University or Brandeis University. Far be it from me to discourage them from supporting Jewish communal organizations. Having said that, I don’t think anything is to be gained if we as a community give up on the finest institutions of higher learning. We do not want a situation in which Jewish students lack the credentials and prestige of another student.

The White House condemned the remarks of Nihad Awad, executive director of the Council on American Islamic Relations (CAIR), after he said he was “happy to see” Palestinians “breaking the siege” regarding the terrorist attack of Hamas on October 7. At colleges, there are Diversity, Equity, and Inclusion (DEI) officials who have worked for CAIR. Are you surprised that the government seemed to be surprised by Awad’s statement, and should there be concern that DEI officials who have worked for CAIR may share similar opinions to its leader?

For many years, especially since CAIR was designated as an unindicted conspirator in a terrorism case, there have been many in the Jewish community and elsewhere who have viewed CAIR as being an extremist organization that is merely pretending to be a civil rights group. In recent years, I think there have been a lot of people who have been hopeful, maybe wishful that CAIR could fill a responsible role as a Muslim civil rights organization and maybe have turned something of a blind eye towards indications that they are not what they seem. The most salient example of this was when the Biden White House included CAIR as one of its partners for administering the Biden National Strategy on Antisemitism. These recent comments from the leader of CAIR simply affirm the worst fears that people have had and reveals the White House’s wishful thinking was simply baseless. It’s unfortunate.

In your book The Definition of Antisemitism, you include a portion about whether or not anti-Zionism is antisemitism. You write that criticism of Israel is part of democracy and not antisemitism. But you note Natan Sharansky’s 3 D’s of Demonization, Double Standards, and Delegitimization. After calls to gas the Jews and attacks against Jews around the world, the prevalent belief is that anti-Zionism is almost always antisemitism. What is your take?

In the 21st century, today’s anti-Zionism is antisemitism.

In working on the Executive Order on Combating Anti-Semitism, what was the goal?

The goal was to take work that I had done in enforcement matters and formal guidance and to elevate them to the level of a presidential executive order. Having one on combating antisemitism gave much more visibility and force and made it harder for other government officials to disregard them. I’m very pleased that the Biden administration, which rescinded so many other of Donald Trump’s executive orders, has not rescinded this one. Biden officials will say, when asked, that Executive Order 1399 remains in active force. Nevertheless, it would be far stronger to have a regulation codify the executive order, or better yet, a statute. That’s why I recommended toward the end of the Trump administration that the Education Department issue a formal regulation codifying the Trump order and making it less vulnerable to challenge. The Trump and the Biden administrations agreed to it.

It is awful to see at this moment in time, when antisemitism is so rampant, that the White House is not willing to give this issue the priority it deserves. They have continuously delayed this regulation throughout the entire presidential term. The fact that they could at the beginning of Chanukah announce that they need yet another entire year to issue this very simple regulation is just stunning. They’ve done a draft. It doesn’t require any significant amount of work. They just have to be willing to prioritize this issue.

In this hearing and a previous hearing by the New York City Council, there hasn’t been reference to a single student disciplined for antisemitic behavior. I did see an NYU student posted that she has been disciplined for ripping down a hostage poster. Are you aware of cases where students have been disciplined? I know there are rules precluding [the witnesses from] using the names of students, but could they speak of the cases?

There have been times universities have hinted to us that students have been disciplined in some way as a result of our complaints or allegations. They seldom are willing to say so clearly or publicly. In cases in which I am familiar, if they provided a description, it would be obvious who they were talking about.

What lawsuits or investigations are taking place due to your work?

If we are talking colleges as opposed to school districts, in federal district court, the case of the University of California-Berkeley is pending. With the Office of Civil Rights, there is Wellesley University, the University of Pennsylvania, the University of Southern California, the University of Illinois at Urbana-Champaign, Brooklyn College, and SUNY New Paltz. We have filed those complaints with OCR (Office of Civil Rights), other than [the Berkeley case in federal court], and 100 percent have resulted in active open investigations.

There is always talk of the importance of the adoption of the IHRA (International Holocaust Remembrance Alliance) definition of antisemitism. Why is it important?

The government has already adopted IHRA. The federal government substantially adopted the same definition under the Obama administration, and it was raised to a higher level under the Trump administration. The question is whether the Biden administration is willing to state with clarity and specificity that it is using IHRA and holding colleges and universities responsible if they fail to act in a way that is consistent with the legal requirements of IHRA. There is a great deal of confusion and ignorance about whether IHRA needs to be adopted or has been adopted. It is part and parcel of a current active policy of the U.S. Department of Education. Federal funds recipients, which include nearly every college in this country, are responsible for complying with federal guidance. They have this legal responsibility, but they act as if they do not. At this moment, it is so important to have clarity in the law. That’s why it was important that the Biden White House promised to issue their regulation by December 2023. They now say they refuse to do so.

Jewish college students hear chants, get yelled at, there are images projected, and there have been a wider range of complaints from what a professor can or can’t say in class or other instances where they feel intimidated. Of course, they can contact you or their own personal lawyer if they have one, but how do they know what is or is not actionable if the presidents of colleges can’t articulate it?

The IHRA working definition isn’t going to solve every question, but it would be a big step forward. I have to say we get a lot of questions about close calls and gray areas. The fact is, this obscures what’s really happening on college campuses. A lot of smart people, including professors and pundits, like to explore where the boundary lines are and create the impression that what’s happening on college campuses [is] what’s in the gray area. The fact is Jewish students are being assaulted, Jewish property is being vandalized. There are many instances of anti-Jewish activity that is not within the gray area. We can have discussions about where the lines are in some cases, but those discussions tend to create the misleading impression that that is the biggest issue happening for Jewish students in higher education.

At the rally in Washington, D.C. a number of speakers said antisemitism will not be tolerated, but it seems like it is. What would be one thing that would give you hope or a sign of things improving?

I would like to see universities adopting the IHRA definition and integrating it in their DEI programs and procedures.

Published 12/22/23 by Ynet News; Story by Clint Van Winkle

American NGO files numerous legal complaints against Ivy League universities saying their neglectful nature toward rising antisemitism cannot continue

Antisemitism has been on the rise across U.S. college campuses since Hamas’ October 7 attack on Israel and the ensuing Israel-Hamas war.

In recent months, reports of antisemitic incidents at American universities have inundated news channels. Masked marchers advocate for a “free Palestine” that stretches “from the river to the sea” at the expense of Israel’s existence, and claim a right to “resist” Israel “by any means necessary,” including a “globalized intifada.” Jewish students often report being harassed, intimidated, and sometimes outright terrorized by antisemitic mobs who act with impunity.

“Antisemitism is spreading like wildfire across the campuses in the United States, and it is doing so because the ground was primed,” Alyza Lewin, president and general counsel of the Louis D. Brandeis Center for Human Rights Under Law, told The Media Line. “The campus communities were really groomed, and they were groomed to see Zionist Jews as evil. They have been fed for years now a constant diet of anti-Jewish hate.”

A rising tide of antisemitism

The Brandeis Center is a Washington, DC-based nonprofit, nonpolitical legal group with the goal of advancing human rights and civil rights for Jews. The group has filed numerous legal complaints against U.S. universities for antisemitism, including University of California, Berkeley; University of Southern California; Brooklyn College; University of Illinois Urbana-Champaign; State University of New York at New Paltz; and the City University of New York system.

A recent study conducted by the Anti-Defamation League (ADL), Hillel International, and College Plus, an analytics company, found that 73% of the Jewish students they surveyed had experienced or witnessed antisemitism since the beginning of the school year.

The ADL recorded 400 incidents of antisemitism on college campuses between Oct. 7 and Dec. 7. During the same period in 2022, 33 antisemitic incidents were reported.

The elite universities are awash in antisemitism. And it’s not just coming from the students. Recently, Dr. Zareena Grewal, an associate professor of American studies at Yale, posted on social media statements the advocacy group StandWithUS said “promote violence and display an alarming hatred for Jews, Israelis and Zionists” without recourse from Yale.

U.S. politicians have taken notice of rising antisemitism on campus, and representatives are working to address the problem.

“The federal government should leverage the power it has over federal funding to pressure colleges and universities to combat antisemitism,” Congressman Ritchie Torres (D-NY) told The Media Line. “There should be enhanced enforcement under Title VI of the Civil Rights Act, which prohibits discrimination based on race, religion, and national origin.”

Antisemitism scorecards for U.S. campuses

Torres, who represents the Bronx and spoke at the Washington, DC March for Israel, has been said to represent the future of pro-Israel politicians. His vocal support for Israel has led multiple New York-based pro-Palestinian groups to rally outside his offices over the past two months.

“Accountability should come not only from government but also from civil society, which should create a scorecard, rating colleges and universities on campus antisemitism,” Torres said. “A scorecard would create a reputational incentive for colleges and universities to treat the crisis of campus antisemitism with the urgency it deserves.”

Lewin called Torres’ scorecard suggestion “a very creative idea.” “We need to figure out ways to hold the schools accountable and to motivate them to take the steps they can take to really make a difference,” she said.

Three weeks ago, the U.S. House of Representatives summoned the presidents of three elite universities to speak about antisemitism on college campuses.

University of Pennsylvania President Liz MagillHarvard University President Claudine Gay, and Massachusetts Institute of Technology President Sally Kornbluth sat before the U.S. House Committee on Education and the Workforce to discuss their efforts to address antisemitism at their universities.

Their testimony proved disastrous, with one of the university presidents losing her job in the wake of the hearing.

Magill resigned from her position as president of Penn a week after the hearing. After she refused to specify whether calling for a genocide of Jews violated the university’s harassment policy, financier Ross Stevens threatened to withdraw a donation to the school of $100 million. Magill stepped down as president but will remain a tenured member of the law school.

Lewin called the presidents’ testimony “clearly disturbing” and said that the testimony served to raise awareness about antisemitism on college campuses.

Many have demanded that Gay and Kornbluth resign as well, but both have received formal backing from their respective boards.

“I and the Executive Committee of the MIT Corporation entirely support President Kornbluth,” Mark P. Gorenberg, chair of the MIT Corporation, wrote in a statement.

A separate letter of support for Kornbluth, signed by MIT deans, department heads, and senior faculty leaders, addressed the issue of free speech on campus, distinguishing between “what we can say and what we should say.”

Harvard’s board also released a statement of support for President Gay following her testimony.

“Our extensive deliberations affirm our confidence that President Gay is the right leader to help our community heal and to address the very serious societal issues we are facing,” the Harvard Corporation said in a statement.

Rep. Torres said that Gay should resign.

“When it came to the question of whether [calling for] a genocide of Jews constitutes harassment, I found Claudine Gay’s answer to be so offensive and outrageous as to merit resignation, and I have said so publicly,” Torres said.

Gay’s comments came on the heels of several antisemitic incidents that have taken place at Harvard in the recent past. The Brandeis Center sent a legal warning to Harvard representing the complaints of three Israeli students who claimed that a Harvard professor discriminated against them.

Days after the Oct. 7 attacks, over 30 Harvard student groups signed a letter that claimed Israel was “entirely responsible for all unfolding violence.” Some leaders of the student groups had job offers rescinded as a result of signing the letter.

Help is available for students experiencing discrimination. The Brandeis Center has partnered with the ADL, Hillel International, and the Gibson Dunn law firm to launch the Campus Antisemitism Legal Line (CALL). According to Lewin, CALL will provide American Jews on U.S. college campuses “the legal guidance and support they need” to combat university antisemitism. Additionally, CALL aims to assist law firms and lawyers involved in administrative complaints and lawsuits.

Lewin explains that this will “better coordinate with one another to ensure these efforts work in concert, rather than potentially undermining each other.” CALL, accessible at Legal-protection.org, aims to “ensure all students who need it receive the best legal support possible,” Lewin told The Media Line.

Universities failing to protect Jewish students on campus can expect legal challenges from Lewin and the Brandeis Center. “When university administrators fail to act, even when made aware of clear discrimination, we are left with no choice,” Lewin stated.

The University of Illinois-Urbana Champaign (UIUC) recently announced the formation of the Chancellor’s Advisory Council on Jewish and Campus Life. By creating the Council, UIUC is making good on one of the commitments it made in its “Joint Statement on Anti-Semitism.” In that Statement, to which the Brandeis Center is a signatory, the university pledged to take a number of concrete steps to address anti-Semitism on its campus and support Jewish students. The university promised to create an advisory council on Jewish and campus life to “assist the chancellor and university leadership to identify opportunities to enhance the campus environment for all students, faculty, and staff, and to advance its commitment to an inclusive community where all feel welcome.” UIUC’s Chancellor stated that the creation of the Council will “help us advance our commitment to an inclusive community where anti-Semitism and other forms of hate will not be tolerated.” Former Chancellor, Richard Herman, and Erez Cohen, the executive director of Illini Hillel, will co-chair the Advisory Council. Other notable members include Rabbi Dovid Tiechtel, director of the Chabad Center for Jewish Life, and the assistant director of the Gies College of Business. The Council also includes UIUC alumni, students, and professors. In November of 2020, the U.S. Education Department’s  Office for Civil Rights (OCR) opened an investigation into a complaint filed on behalf of UIUC’s Jewish students, alleging that UIUC has allowed a hostile environment to proliferate on its campus in violation of Title VI of the Civil Rights Act of 1964. The complaint was filed by Arnold & Porter Kaye Scholer LLP together with the Louis D. Brandeis Center for Human Rights Under Law in March 2020, with consultation from the Jewish United Fund and Hillel International. OCR’s investigation of the complaint is ongoing.

Good news: This month the Brandeis Center’s legal case at the University of Illinois at Urbana- Champaign (UIUC) enjoyed two successes: The U.S. Department of Education’s Office of Civil Rights (OCR) agreed to open an investigation, while the University issued an important joint statement with LDB and allied organizations. Meanwhile, Scholars for Peace in the Middle East have intervened in support of LDB’s anti-BDS lawsuit against the American Studies Association. Read about these and other developments, as well as LDB Chairman Kenneth L. Marcus’s Newsweek challenge to the incoming Biden-Harris administration, in this edition of the December Brandeis Brief. As we approach year-end, we thank you for your tax-deductible donations and acknowledge that without you our work could not be done.

Read the Brandeis Brief here.