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  • Sizing Up Sentences: When it comes to white-collar crime, crooks may or may not land inthe slammer. Federal data indicate their penalties might depend on where cases are heardAuthor(s): MICHAEL HIGGINSSource: ABA Journal, Vol. 85, No. 11 (NOVEMBER 1999), pp. 42-47Published by: American Bar AssociationStable URL: http://www.jstor.org/stable/27841272 .Accessed: 12/06/2014 16:15

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  • COVER STORY / FEDERAL PROSECUTIONS

    Sizing Up

    Sentences When it comes to white-collar crime, crooks may or may not

    land in the slammer. Federal data indicate their penalties

    might depend on where cases are heard.

    BY MICHAEL HIGGINS In the world of criminal sentenc

    ing, the most violent criminals? the killers, rapists and robbers

    ?can be the easiest cases. We all know, or think we know, what should be done with them.

    But the sentencing of white collar crooks?the embezzlers, the scam artists, the contractors who overbill the government?can be a trickier matter. Some suggest sav

    ing scarce prison cells for the vio lent criminals; others balk at the idea of allowing white-collar crooks to "buy their way out" of prison by paying a fine or restitution.

    So which view reigns in the federal criminal justice system? The answer appears to be both, judging by disparities in white-col lar sentencing throughout 90 fed eral districts.

    For white-collar defendants, the choice between diverging views can mean the difference between prison and freedom. Stephen Hur

    ley, a criminal defense lawyer in Madison, Wis., saw that in the

    early 1990s when he represent ed a 58-year-old letter carrier caught in a sting operation.

    To test its carriers, the government had put $5 bills

    Michael Higgins, a lawyer, is a

    former reporter for the ABA Journal.

    4!

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  • in translucent envelopes marked "Green Giant Rebate Offer," Hurley says. One of the envelopes "was placed on his route?to an address that clearly didn't exist and a name that was incorrect," he says. "It's a rebate, so [the carrier says], 'Hell, the company's not expecting it back. I'll just keep it.'

    "

    The carrier was fired and lost his pension. Then, to Hurley's dis may, the government prosecuted, sending his client to jail for sever al months.

    Meanwhile, in the nearby East ern District of Wisconsin, "Those cases were not even being prosecut ed," Hurley says. "I remember just being so sad about the case. ... I be lieve there was a great disparity among districts in how these cases were treated."

    After that instance, the local U.S. attorney in Madison revised the policy on postal sting cases to be

    more lenient, Hurley says. . But statistics analyzed j^^g

    by the aba Journal suggest p3y{ that variations remain in how white-collar criminals are treated throughout the L %i federal system. The Trans actional Records Access Clearinghouse, a group of re searchers at Syracuse Uni versity, gathered the statis tics from Department of Justice data.

    Geographical Differences Nationwide from 1993

    to 1997, about one white collar defendant was sen tenced to prison for every two convicted, according to trac data. But prosecutors in some districts were ei ther more willing or more able to put white-collar crooks behind bars.

    In the Western District of Wisconsin, more than eight white-collar criminals were sent to prison for every 10 who were convicted. In the Southern District of Florida, the number was more than six for every 10.

    Contrast those num bers with figures for the same period in the District of New Jersey, where fewer than three white-collar de fendants went to prison for every 10 convicted. In Ari zona, the ratio was also fewer than three of 10.

    The trac data on white-collar crime looks at all convictions in what the Justice Department calls its white-collar crime program cate gory. That category encompasses prosecutions of a long list of fraud offenses, including consumer fraud, bank fraud and embezzlement, se curities fraud, insurance fraud, health care fraud and federal pro gram fraud. The data includes de fendants convicted before magis trate judges.

    Attorneys who were contacted for this article urged caution in putting too much emphasis on the numbers in smaller districts. A rash of bank teller embezzlements

    might skew the numbers toward no jail time. A big sting operation might skew toward more jail. Most agreed that the facts of a given case are the most important factor dri ving possibility of prison vs. proba tion, and that the guidelines have

    m

    increased uniformity overall. But the majority of lawyers in

    terviewed agreed that, especially in districts where trac data measure a large number of cases, it was more than happenstance driving the disparities.

    The goal of the federal sentenc ing guidelines is uniformity?the same conduct yielding the same punishment. Yet, "Everyone knows the guidelines have not achieved that," Hurley argues. "You only have to look at your [white-collar sentencing] statistics to see that."

    Prosecutor Power The sentencing guidelines, put

    into effect in 1987, attempt to stan dardize sentences by assigning an offense level, or point value, to every federal crime. Then the guide lines mandate that points be added or subtracted for factors such as a criminal's prior record. Once the

    .-----^^^^^^^^^^^^

    BY WAYNE SLEZAK AND JEFF MILLER

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  • point total is determined, judges must sentence the defendant with in certain fairly narrow bounds.

    But former prosecutors and other experts say that in reality, the process is not that simple. Var ious factors in the guidelines give prosecutors leeway on how to charge.

    For example, prosecutors have more discretion than is sometimes acknowledged to classify the amount of money at issue in a case. Prose cutors also have discretion in decid ing which charges to bring. There is also discretion in which cases to bring, and which to leave for state authorities. And there are ques tions of when a defendant will be credited with substantial assis tance for aiding a prosecution, a

    key to reducing the sentence. "In practice, the prosecutors

    have a lot of discretion," says Michael Simons, a former federal prosecutor in the Southern District of New York who is now a law pro fessor at St. John's University in

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    Jamaica, N.Y. He says the reason is partly that "prosecutors control the facts."

    How does it work? Unlike, say, a bank robbery, white-collar crimes frequently unfold over a longer pe riod of time. Simons recalls a case in which the defendant had sent small, phony invoices to public companies to try to trick them into paying. The schemer was eventual ly caught, but bank and phone records didn't clearly reveal how much the scam had netted.

    The final plea agreement, like the vast majority of plea agree

    ments, contained a stipulation as to the amount of the loss, Simons says. "It was the subject of some

    negotiation. It was inexact." That bargaining can be crucial

    for the defendant, says T. Mark Flanagan Jr., a former federal pros ecutor in the District of Columbia who is now a partner at McKenna & Cuneo in Washington, D.C. "Loss is what drives?more than any other variable?the amount of the

    ^^^^^^^^^^^^

    prison term," he says. A basic fraud case, say, in the

    defense contracting or health care area, might have a base offense level of six, says Flanagan, who co chairs the Sentencing Guidelines Subcommittee of the aba Criminal Justice Section's White Collar Crime Committee.

    Then if the amount at issue was more than $70,000 but less than $120,000, for example, the guidelines add six points for a total of 12 points. That already would qualify the defendant for a 10- to 16-month sentence, although the judge would have some flexibility in regard to how much time the defen dant served.

    "It doesn't take a lot money ... when you're talking about a white collar fraud case," Flanagan says.

    Playing the Charge Card There's also discretion over

    how to charge crimes, Flanagan says. Take the case of someone who is lying to cover up a crime. Should prosecutors tack on a charge of making false statements, or the generally more severe obstruction of justice? "Some might go with the false statements; some might go with the obstruction of justice," he says.

    Legally, the prosecutor is ob ligated to bring the charge that

    most directly applies to the facts of the case, Flanagan says. "Having said that, I'm still saying that there is flexibility," he adds. And, "There is variation among juris dictions as to how they use that flexibility."

    One of the most important uses of that flexibility, some de fense attorneys say, is the prose cutor's decision about whether to add a money laundering charge. Originally intended as a tool in drug prosecutions, the charge is often tacked on now in fraud cases as well.

    Money laundering is also a fre quent tool in pre-indictment bar gaining. Prosecutors may tell the target of an investigation that if he agrees to plead guilty, the prosecu tors will limit the indictment to mail fraud, says David Rothman, a crim

    T. MARK FLANAGAN JR. "Loss is what drives?more than any other variable? the amount" of prison time.

    44 ABA JOURNAL / NOVEMBER 1999

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  • inal defense lawyer in Miami and president-elect of the Florida Asso ciation of Criminal Defense Lawyers.

    The prosecutor then warns that a refusal to plead will bring a mon ey laundering indictment, explains Rothman, whose four-lawyer firm handles some 20 to 25 white-collar cases a year. "And that jacks up the penalty substantially."

    It's not that hard for prosecu tors to do, says Rebekah Poston, a former federal prosecutor in Miami and Cleveland who is now a partner at Steel Hector & Davis in Miami. "All you need is an illegal source of funds, which you then try to secrete or hide," and most who commit fraud try to do that with the illegal ly gained money.

    The use of money laundering charges varies among jurisdictions, says Atlanta defense lawyer Mar cia Shein, who handles criminal ap peals all over the country.

    "To me it's a very serious prob lem," Shein says, "because clients

    who really should be classified ac cording to their crime are getting tagged with money laundering."

    Another key decision prosecu tors make is when to credit cooper ating defendants with "substantial assistance," the key phrase that de termines whether a defendant who rolls over for the government has rolled far enough to stay out of prison. If a prosecutor finds a de fendant's help to be substantial, the prosecutor can make a motion not ing that fact. Without that motion, the judge has no authority to re duce the offender's sentence.

    But prosecutors can interpret that key phrase in different ways. Sometimes telling everything you know is good enough. In other cases, that information must be truly new information, not merely confirming

    what investigators already know. "You must always check with the district you are practicing in to see what the policy is," Poston says.

    In some cases, prosecutors de mand that the information lead to the conviction of another person, Poston says. In that scenario, "If this person you're cooperating against doesn't plead out, you're stuck with [the result of] a trial," she says.

    "That is a huge issue," Shein says. "There are no guidelines as to what ... constitutes substantial assistance. So you get a very incon sistent application of what hap pens to someone for their substan tial assistance."

    ABAJ/ROB CRANDALL

    NEARLY AS TOUGH Districts that sent 60 percent-69 percent to prison: Vermont: 68% of 109 convicted; Tennessee, Middle: 67% of 236; Maine: 67% of 156; Texas, South: 65% of 789; Texas, North: 64% of 1,511; Indiana, South: 64% of 318; New Hampshire: 64% of 150; Tennessee, East: 63% of 327; Mississippi, South: 63% of 240; N. Carolina, Middle: 62% of 343; Arkansas, East: 62% of 281; Michigan, West: 61% of 345; Illinois, Central: 61% of 253; Rorida, South: 60% of 1,221; Tennessee, West: 60% of 512; Hawaii: 60% of 172.

    EN THE MIDDLE Districts that sent 50 percent-59 percent to prison:

    Oklahoma, West: 59% of 302 convicted; W. Virginia, North: 59% of 80; Texas, East: 59% of 407; Massachusetts: 58% of 633; Michigan, East: 58% of 977; Texas, West: 58% of 676; Georgia, North: 58% of 713; Florida, Middle: 58% of 1,147; Louisiana, West: 57% of 371; Iowa, North: 57% of 138; Georgia, Middle: 56% of 223; California, East: 56% of 583; Louisiana, East: 56% of 444; Nevada: 55% of 695; California, Central: 55% of 1,211; Idaho: 54% of 103; Missouri, West: 54% of 436; Nebraska: 54% of 255; Illinois, North: 54% of 1,405; Missouri, East: 54% of 513; Kentucky, East: 53% of 321; Virginia, East: 53% of 785; Alabama, Middle: 53% of 148; Maryland: 52% of 591; California, South: 52% of 627; N. Carolina, West: 52% of 521; Minnesota: 52% of 428; Pennsylva nia, West: 52% of 488; Mississippi, North: 52% of 139; Delaware: 52% of 159; Kansas: 52% of 351.

    MORE LENIENT THAN SOME Districts that sent 40 percent-51 percent to prison:

    Kentucky, West: 51% of 378 convicted; W. Virginia, South: 51% of 252; Colorado: 51% of 334; Wyoming: 51% of 114; Florida, North: 49% of 306; New Mexico: 48% of 109; Pennsylvania, Middle: 48% of 461; S. Carolina: 48% of 719; Ohio, South: 48% of 589; Ohio, North: 47% of 954; S. Dakota: 47% of 148; Oregon: 47% of 335; Wisconsin, East: 46% of 361; Oklahoma, North: 45% of 291; Alabama, North: 45% of 390; N. Carolina, East: 4$% of 305; Connecticut: 43% of 365; Washington, West: 43% of 496; Oklahoma, East: 43% of 37; District of Columbia: 42% of 681; New York, North: 42% of 339; Utah; 42%(rf249;ffl?^?

    THE LOW END ? Districts that sent 26 percent-39 percent to arisen:

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  • So what's going on, for exam

    ple, in the Western District of Wis consin, where the most white-collar criminals are going to prison? Noth ing but prosecutors following the law, says the U.S. attorney for the district, Peggy Lautenschlager.

    Lautenschlager points out that Justice Department policies require lawyers in her office to charge the

    most serious offenses they believe they can prove. She says her of fice isn't making a special, con scious effort to send white-collar crooks to prison. (Hurley's postal ? carrier case happened before ? Lautenschlager's tenure.)

    They are not adding money laundering charges to fraud com

    plaints, a practice Lautenschlag er says she doesn't think would account for disparities anyway. And Lautenschlager says the dis trict's white-collar cases have | largely involved one defendant I acting alone. So substantial as sistance has rarely been a con- ? sideration.

    However, Lautenschlager is quick to acknowledge that when it comes to the dollar amount in- ; volved in a fraud, her office is un- ? bending. It's her duty to prove f the full extent of a loss, she says, and it's also what the district's 1, judges require. Judges in Madi- ? son are more than ready to throw 3 out plea agreements they don't 1

    like, and they turn instead to the | federal probation office for an as- | sessment of the amount of money | involved in a case.

    | "We have to show the court |

    why we don't think we can prove ? the greater amount," Lauten

    schlager says. If not, "The judge will throw out the plea."

    Hurley, the Madison defense lawyer, knows the judges' attitudes

    well. "They won't agree to be bound" by a deal, he says. "So even if we went to the court in this district and the prosecution said, 'Judge, I think Mr. Hurley's client ought to get probation,' the judge will not agree to be bound by that recom mendation. They do what they want here."

    That's the correct legal result, Lautenschlager says. "I think the judges [here] follow the guidelines to a T," she says. "And I don't know, but I would guess that might not be the case in other jurisdictions."

    It's not the case in many other jurisdictions, other lawyers agree. And the result is that a white-collar

    crime committed in the Western District of Wisconsin is a potential ly more serious offense than the same crime committed elsewhere.

    Flanagan, the Washington, D.C., attorney, says it's uncommon

    to have judges and probation offi cers undoing plea agreements. "You can't just go out and make up some fiction," he says. But, "If you're deal

    Alan Abies says the office won't comment on any plea bargaining practices or on how judges sentence in the district.

    In the federal district of Ari zona, officials say they can't tell, based on the numbers available, why Arizona appears to be sending fewer white-collar crooks away.

    "I can't think of any reason

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    ing with a fairly complicated fraud case, most of the time, I think most judges feel that the prosecution is not going to be signing up for a deal that is not in the public interest.

    "If you have structured some

    thing that is a good agreement, I think nine times out of 10, the pro bation office is going to agree as well," he says.

    Leniency Without a Cause And what is happening in dis

    tricts where proportionately fewer white-collar criminals are going to prison?

    Officials at the Justice Depart ment referred the Journal's ques tions about variations to the indi vidual districts. In the federal district of New Jersey, spokesman

    ^^^^^^^^^^^^^^^^^^

    why it would be Arizona in partic ular," says Cathy Colbert, spokes woman for the U.S. attorney's office in Phoenix. "It could be that they're all first-time offenders, but it would be odd that it would fall that way."

    It's also possible that the dis trict has been taking lower-dollar value cases, with $10,000 to $15,000 in losses, that other federal prose cutors might pass on, Colbert says. But she says the office doesn't have statistics to either confirm or dis prove that.

    In any event, Colbert says the office has taken steps recently that may change the statistical outlook.

    For one, the office has changed its approach to bank teller cases, in which a bank employee is caught taking money from the cash draw

    46 ABA JOURNAL / NOVEMBER 1999

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  • er. The prosecutors had commonly charged tellers with both a misde meanor and felony count, then al lowed the defendant to plead to the

    misdemeanor, Colbert says. They're less flexible now, taking only clear felony cases and not bargaining.

    And the office recently added a prosecutor who specializes in asset forfeiture and money laundering

    issues, Colbert says. "You didn't see money launder ing in any of our indict

    ments until the last year," she says. "That is some

    thing that our office is def initely beefing up, and as that continues to be added to indictments obviously our numbers will change."

    What is it that deter mines whether a district is a good or bad place to be a white-collar crime de fendant?

    ?iSSi?;^ One theory is that smaller, lower-volume dis

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    But other experts sug gest that large, busy districts may be more likely to decline smaller cases, thus leaving themselves

    mostly prison-worthy cases to pros ecute.

    Rothman, the Miami lawyer, notes the number of white-collar defendants heading to prison in the Southern District of Florida. "The bigger the system gets, the more impersonal the system gets and the less ability the judges have to hear the same thing again and again and react to it" on a case-by-case basis, Rothman argues. That world wear iness might lead to a send-them all-away approach.

    Big districts also may have big resources. In the Southern District of Florida, prosecutors have a spe cial health-care fraud task force

    and other specialized units. Those prosecutors "have a vested interest ... in that particular genre of cases,"

    Rothman says. "They're going to re ally stay focused on those particu lar cases" and not be willing to deal as much.

    Officials at the U.S. attorney's office in Miami did not return calls seeking comment.

    A clear message from the data is hard to come by. Russell Coombs, a law professor at Rutgers law school in Camden, N.J., calls prose cutors' charging decisions "a big possible source of these variations." But he notes, too, that there are other possibilities, and it's hard to know without delving into the facts in every case. "If you want to know

    why are there variations, ... you have to go beyond the data they're giving us," he says.

    Tim McGrath, interim staff di rector of the U.S. Sentencing Com mission, makes the same point. The data "doesn't take into considera tion the mix of the crimes or the severity of the conduct," he says. "Those issues have to be explored further before you can make any determination whether there is any disparity."

    But McGrath also acknowl edges that the commission hasn't done any work that would explain variances among districts. Simple demographics don't seem to be the answer; rural districts aren't con

    sistently tougher than urban ones, for example.

    So What's the Problem? To what extent is the variation

    a problem? Not surprisingly, de fense attorneys say the problem is that tough jurisdictions push for prison time in too many cases. And of course, prosecutors and crime victims are more likely to worry about jurisdictions where fraud defendants seem to escape jail too often.

    But in any case, should we be worried that the outcome of some cases may depend on geography?

    Frank Tuerkheimer, a law pro fessor at the University of Wiscon sin in Madison, says some geo graphic variation is acceptable. Tuerkheimer, U.S. attorney in the Western District of Wisconsin dur ing the Carter administration, says the tough-on-white-collar-crime en

    vironment may make sense for the district.

    White-collar crime, because it

    requires planning, "is a wonderful, prototypical example of deterrable conduct," Tuerkheimer reasons.

    "Somebody goes to jail [in Madi son], everybody knows about it. In that way, it's a small town."

    Tuerkheimer tells a story from his days as a prosecutor about a

    judge who was planning on giving a white-collar defendant probation. Then a newspaper reporter walked into the courtroom. The judge promptly sent the defendant to jail for 30 days.

    "That judge changed that sen tence when he saw it was going to be in the paper, and I can't say that's crazy," Tuerkheimer says. "There is a spirit among the judges here ... of being concerned with general deterrence. It's part of the ethic of the place."

    Hurley calls the idea that Madison is a model for deterrence "hogwash." Maybe tougher sen tences make prosecutors feel good, but "I don't think our rate of white collar crime has dropped," he says. "There just isn't data to support that notion."

    Hurley sees it as a simple case of a lack of uniformity. "They're harsh here," he says. "My assump tion is [defendants] will always go to prison."

    Others see notice as the key factor. Extreme numbers on either side might be troubling, says Ed ward Ohlbaum, a professor at Tem ple law school in Philadelphia and the head of the school's clinical pro gram in criminal law. But to the extent a district wants to be tough and has a well-known reputation for that, "I'm not sure there's any thing particularly wrong with that. There's a component of notice and fairness in that."

    Ohlbaum says he would be more troubled by variation within a district. For example, if a district sent small-time thieves packing but gave probation to more affluent white-collar offenders, that would be unfair.

    But Shein suggests there could be a policy regarding how U.S. at torneys make decisions on topics such as when to credit substantial assistance or when to charge money laundering.

    "There's got to be some coordi nation in this," she argues. "Where is their balance? I don't think you're ever going to fix it 100 per cent. But you can get better guid ance" for U.S. attorneys.

    ABAjAAMi CHAPPELL ABA JOURNAL / NOVEMBER 1999 47

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    Article Contentsp. 42p. [43]p. 44p. [45]p. 46p. 47

    Issue Table of ContentsABA Journal, Vol. 85, No. 11 (NOVEMBER 1999), pp. 1-128Front MatterPRESIDENT'S MESSAGEThe Meeting of the Millennium [pp. 8-8]

    LETTERS [pp. 10, 14, 16, 18]OBITER DICTA [pp. 20-20]NEWS'Equality With a Vengeance': Violent crimes and gang activity by girls skyrocket [pp. 22, 24]Doin' the Bench Shuffle: Tort reform Republicans now sit on Ala. high court [pp. 26-26]Split-up Insurance: Postnups are gaining in popularity for couples in property predicaments [pp. 30-30]

    TRENDS IN THE LAWOffshore Trust Busting: A contempt ruling may mean trouble in debtors' paradise [pp. 32-33]Now You See It, Now You Don't: Older workers watch pensions erode as employers turn to cash-balance plans [pp. 34-35]Satisfaction or Your Money Back: Ruling says fees may be forfeited if client is unhappy with attorney conduct [pp. 36-37]

    SUPREME COURT PREVIEW: Freedom From Forced Fees: University students reject the notion of subsidizing campus groups whose views they don't share [pp. 38-38]SUPREME COURT PREVIEW: Strange Advocacy: Court to say whether no-merits briefs violate defendants' right to counsel [pp. 40-40]COVER STORY / FEDERAL PROSECUTIONSSizing Up Sentences: When it comes to white-collar crime, crooks may or may not land in the slammer. Federal data indicate their penalties might depend on where cases are heard [pp. 42-47]

    CHURCH/STATE SEPARATIONEvolution of a Controversy: Almost 75 years after the Scopes trial, a new species of the old Darwin vs. creation debate has come to life in a suburban Seattle community [pp. 50-55]

    LAW PRACTICEProtecting the Wealth: Keeping clients' assets out of the clutches of creditors and tax collectors is a primary goal of any estate plan. But lawyers need effective strategies to help clients go the distance [pp. 58-62, 64]

    ASIAN PACIFIC AMERICANS AND THE LAWLong Struggle for Justice: Asian Pacific Americans have played a key role in this country's civil rights struggles. Their fight is not yet over [pp. 66-67]A Common Commitment [pp. 67-67]Pain and Promise of Memory [pp. 68-69]Upbeat Approach Working [pp. 70-71]Symbol of the Times [pp. 71-71]Advocacy for Justice [pp. 72-72]COMMENTARY: Living the American Dream [pp. 73-73]

    LEGAL TECHNOLOGYREV UP YOUR RESEARCH ENGINES: While publishing giants Lexis and Westlaw race for the Internet market, smaller firms tail close behind [pp. 74-76, 78-79]

    IN RE TECHNOLOGYGet Hold of Minutes in a Matter of Seconds: Speedy, informative and accessible, electronic corporate records replace musty old notebooks [pp. 80-81]

    13TH ANNUAL LEGAL SOFTWARE &TECHNOLOGY DIRECTORY [pp. 82, 84-89]PROFESSIONAL LIABILITYWhat's in the Cards? Absent case law, counsel clients carefully to avoid a malpractice suit [pp. 90-90]

    LITIGATIONThe Sin of Self-Persuasion: Getting carried away with your rhetoric can be perilous [pp. 92-93]

    SOLO NETWORKDon't Take Their Guff: Sever ties with abusive clients before they ruin your practive or your life [pp. 94-95]

    IN THE OFFICECase Clothed: Many law firms opt for casual dress codes, but work habits and ethics stay formal [pp. 96-96]

    YOUR FINANCESMom/Dad, We Have to Talk: Long-term care insurance shields assets of elderly parents, unburdens children [pp. 97-97]

    BOOKSMy Sweet, Unimpeachable You: A federal judge parses the Clinton-Lewinsky messand finds no heroes [pp. 98-99]

    YOUR ABATrials for the Ages: ABA museum highlights cases that shaped American history [pp. 100-100]WASHINGTON REPORT: Remedy of Last Resort: ABA opposes plan to restructure 9th Circuit Court of Appeals [pp. 101-101]Laudable Lawyering: Association expresses appreciation to a long list of honorees [pp. 102-105]Good Time for Early Birds: Registration fees for 2000 ABA Annual Meeting Sessions start rising on Dec. 1 [pp. 106-107]EXECUTIVE DIRECTOR'S REPORT: ABA Membership Hits New High [pp. 108-110, 112]

    ABE 1999 Annual Report: CONTRIBUTING THROUGH INSURANCE American Bar Endowment 1999 [pp. 113-115]LifeStyleAUTOMOTIVE [pp. 116-119]

    PERSPECTIVEJudy Lays Down the Law [pp. 128-128]

    Back Matter