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1 2014 WL Only the Westlaw citation is currently available. UNPUBLISHED OPINION. CHECK COURT RULES BEFORE CITING. Superior Court of Connecticut, Judicial District of New Britain. City of HARTFORD v. CONNECTICUT STATE BOARD OF LABOR RELATIONS et al. No. HHBCV S. May 7, Attorneys and Law Firms Corporation Counsel Hartford, Hartford, CT, for City of Hartford. Board of Labor Relations Conn, Wethersfield, CT, for Connecticut State Board of Labor Relations et al. Opinion ELIOT D. PRESCOTT, J. *1 The principal issue in this administrative appeal is whether, pursuant to General Statutes of the Municipal Employees Relations Act, a municipality s adoption of a nepotism policy that is used by the city to assign, transfer, and promote employees is a mandatory, discretionary, or illegal subject of collective bargaining. For the reasons set forth below, the court concludes that the adoption of such a policy is a mandatory subject of collective bargaining. I FACTS AND PROCEDURAL HISTORY The record discloses the following relevant facts and procedural history. The plaintiff, the city of Hartford, is a municipal employer within the meaning of the Municipal Employees Relations Act (Act), General Statutes 7 467(1). The defendant, Hartford Municipal Employees Association, Inc. (HMEA), is an employee organization within the meaning of the act. See General Statutes 7 467(6). The plaintiff and HMEA are parties to a valid collective bargaining agreement. The agreement was effective from July 1, 2007 through June 30, Nicole Plessy Cloud was hired as a junior accountant in the custody-of-funds unit of the city treasurer s office in December of In 1999, she married Adam Cloud. Around 2003, Plessy Cloud was promoted to financial systems manager and was assigned to supervise the custody-of-funds unit within the city treasurer s office. On January 7, 2011, Cloud was hired as assistant city treasurer and on February 1, 2011, when then city treasurer Kathleen Palm Devine retired, he became city treasurer. On August 18, 2011, the plaintiff s director of human resources and labor relations, Santiago Malave, sent to HMEA representatives an regarding new city policies, including a policy regarding nepotism. The indicated that the nepotism policy will be implemented by the Mayor effective August 26, Distribution of the policies will begin thereafter. A document describing the policy was attached to the . 1 Effective September 12, 2011, subsection (H) was added to of the plaintiff s code of ordinance, stating: to insure that the financial and professional integrity of the City is maintained, employees shall abide by the City s nepotism policy which generally prohibits conferring benefits and privileges based upon familial relationships, rather than on merit. On September 29, 2011, the plaintiff s mayor authorized Plessy Cloud s immediate transfer to the finance department in order to eliminate any and all concerns regarding claims of nepotism or favoritism. On November 21, 2011, HMEA filed a complaint with the defendant, the Connecticut State Board of Labor Relations (board), claiming that the plaintiff violated the act by unilaterally implementing the nepotism policy. The board, in its August 14, 2013 decision and order, found that the plaintiff unilaterally adopted the nepotism policy, that Plessy Cloud was transferred pursuant to that policy, and that the adoption of the policy and transfer of Plessy Cloud were in violation of the act because they constituted a unilateral change in a condition of employment. 2 *2 The plaintiff, who is aggrieved by the agency s decision, then filed this timely appeal. On appeal from the board s decision, the plaintiff does not challenge the 2014 Thomson Reuters. No claim to original U.S. Government Works. 1

2 factual findings of the board. Rather, the plaintiff challenges the board s legal determination that the act required the plaintiff to bargain with HMEA before implementing the nepotism policy. 3 II ANALYSIS A Standard of Review This court reviews the board s decision pursuant to the Uniform Administrative Procedure Act (UAPA), General Statutes et seq. As our Supreme Court summarized: Under the UAPA, it is [not] the function... of [the court] to retry the case or to substitute its judgment for that of the administrative agency... Even for conclusions of law, [t]he court s ultimate duty is only to decide whether, in light of the evidence, the [agency] has acted unreasonably, arbitrarily, illegally, or in abuse of its discretion... [Thus] [c]onclusions of law reached by the administrative agency must stand if the court determines that they resulted from a correct application of the law to the facts found and could reasonably and logically follow from such facts... Cases that present pure questions of law, however, invoke a broader standard of review than is... involved in deciding whether, in light of the evidence, the agency has acted unreasonably, arbitrarily, illegally or in abuse of its discretion... Furthermore, when a state agency s determination of a question of law has not previously been subject to judicial scrutiny... the agency is not entitled to special deference... We have determined, therefore, that the traditional deference accorded to an agency s interpretation of a statutory term is unwarranted when the construction of a statute... has not previously been subjected to judicial scrutiny [or to]... a governmental agency s time-tested interpretation... (Citation omitted; internal quotation marks omitted.) Chairperson, Connecticut Medical Examining Board v. Freedom of Information Commission, 310 Conn. 276, , 77 A.3d 121 (2013). B Discussion At the outset, it is important to note what is not at issue in this appeal. The court need not decide whether the plaintiff is ultimately prohibited from adopting a nepotism policy. Indeed, a municipality s adoption of a policy that prevents the influence of nepotism on the hiring, assigning, and promotion of its employees may well be both wise and admirable. Rather, the issue in this case is whether the Municipal Employees Relations Act requires a municipality to bargain in good faith with its employees representative regarding the aspects of its nepotism policy that impact its employees conditions of employment. General Statutes 7 470(a) provides, in relevant part: Municipal employers or their representatives or agents are prohibited from... (4) refusing to bargain collectively in good faith with an employee organization which has been designated in accordance with the provisions of said sections as the exclusive representative of employees in an appropriate unit... General Statutes 7 470(c) provides, in relevant part: For the purposes of said sections, to bargain collectively is the performance of the mutual obligation of the municipal employer or his designated representatives and the representative of the employees to meet at reasonable times... and confer in good faith with respect to wages, hours and other conditions of employment, or the negotiation of an agreement, or any question arising thereunder, and the execution of a written contract incorporating any agreement reached if requested by either party, but such obligation shall not compel either party to agree to a proposal or require the making of a concession. (Emphasis added.) *3 The term conditions of employment has been broadly defined as encompassing the entire spectrum of conditions and benefits which apply to public employment, in addition to the commonly understood basic provisions relating to pay and hours of work, including but not limited to: seniority, grievance procedures, holiday and vacation pay, shift premiums, sick leave, jury duty, pensions and severance pay, insurance coverage of various kinds, seniority in promotions, transfers and layoffs, discipline and discharge and grievance arbitration provisions. Rapaport & Benedict, P.C. v. Stamford, 39 Conn.App. 492, , 664 A.2d 1193, 1199 (1995) (citing Board of Police Commissioners v. White, 171 Conn. 553, 560, 370 A.2d 1070 (1976)). The phrase conditions of employment 2014 Thomson Reuters. No claim to original U.S. Government Works. 2

3 limits the area of negotiability and excludes the sort of managerial decisions that lie at the core of entrepreneurial control. Danbury v. International Ass n of Firefighters, Local 801, 221 Conn. 244, 253, 603 A.2d 393 (1992). In the present case, the nepotism policy, by its own language, shall be taken into consideration when relatives of employees are being reviewed for new job assignments, transfers or promotions. On its face, therefore, the policy affects transfers. Furthermore, Plessy Cloud was transferred pursuant to the policy. Thus, the policy affects a condition of employment as that term has been defined by our Appellate Court. Rapaport & Benedict, P.C. v. Stamford, supra, 39 Conn.App. at ( conditions of employment has been defined as encompassing... transfers ). As a result, 7 470(a) and (c) require the plaintiff to bargain with HMEA in good faith regarding the implementation of that policy. Nevertheless, the plaintiff claims it was not required to bargain regarding the nepotism policy, and instead that it may unilaterally impose it on employees. According to the plaintiff, bargaining with HMEA regarding the nepotism policy would be illegal as it is against public policy. Specifically, the plaintiff argues that, because our statutes, rules, and case law support the public policy that a public official with a personal interest in a matter, including the matter s effect on a spouse or dependent, is prohibited from rendering decisions on that matter. Further, the plaintiff argues that it has been delegated the power to adopt ethics rules and its home rule authority... including the authority... to regulate the ethics, integrity and honesty of government officials, constitutes a preeminent and absolute power of the people embodied in the state constitution and common law which cannot be bargained away. Accordingly, the plaintiff argues that the board erred in its ruling because, in its view, the nepotism policy is either (1) an illegal subject of collective bargaining or, at the least, (2) is not a mandatory subject of collective bargaining. The court disagrees. 1 Whether the Nepotism Policy is an Illegal Subject of Collective Bargaining *4 The plaintiff first argues that, because the power to maintain honesty and integrity of government operations, a unique government duty, is one that cannot be bargained away, bargaining regarding the nepotism policy would be illegal in violation of public policy. 4 Specifically, the plaintiff contends that General Statues 7 148h(b), 5 Rule 2.13(a)(2) of the Code of Judicial Conduct, 6 and our Supreme Court s decision in Low v. Madison, 135 Conn. 1, 60 A.2d 774 (1948), 7 stand collectively for the proposition that [s]tatutory law, as well as general ethical principles, and the common law prohibit a public official with a personal interest in a matter, extending to an interest of a spouse or dependent, from taking official action on that matter, the interest being in conflict with the official s obligation to act in the public interest. In response, the defendants contend that (1) the public policy exception to the obligation to collectively bargain should be narrowly construed and limited to situations in which an award directly violates an explicit and well-defined public policy, (2) the authorities upon which the plaintiff relies are inapplicable to this case, and (3) the plaintiff has failed to show that a familial relationship in the workplace is so inherently unethical or illegal that it precludes collective bargaining over the particulars of a nepotism policy that impact upon working conditions. The court agrees with the defendant. Our Supreme Court has written: The duty and/or ability to bargain... is necessarily limited to those subjects to which the parties can legally agree... As with contracts generally, the bargaining process and resulting agreements are subject to the restrictions and limitations of public policy as manifested in constitutions, statutes and applicable legal precedents. Lieberman v. State Board of Labor Relations, 216 Conn. 253, , 579 A.2d 505 (1990). The initial question that must be answered in determining the scope of public sector labor negotiations, therefore, is whether the parties involved in the bargaining process can legally agree to the subject in question. Id., at 265. In Lieberman, our Supreme Court conclude[d] that an agreement to destroy public records conflict[ed] with relevant provisions of the General Statutes, and... h[e]ld, therefore, that the destruction of a public employee s discipline record [wa]s an illegal subject of collective bargaining. Id., at 261. In the present case, unlike in Lieberman, HMEA and the plaintiff have not reached an agreement that contravenes some established law or legal precedent. If the plaintiff and HMEA reached an agreement that incorporates the same or similar terms of the nepotism policy that the plaintiff unilaterally imposed, there would be nothing in that contractual agreement that contravenes any public policy of which the court is aware. Perhaps, if the plaintiff and HMEA reached an agreement establishing a pro-nepotism policy that required or encouraged the 2014 Thomson Reuters. No claim to original U.S. Government Works. 3

4 promotion of relatives, the authorities the plaintiff cites for the proposition that nepotism is against public policy might be sufficient to show that such an agreement was an illegal subject of collective bargaining. Obviously, no such scenario exists here. In the absence of any subject matter to which the parties cannot legally agree on the basis that it contravenes public policy as manifested in constitutions, statutes and applicable legal precedents, this court concludes that the nepotism policy in this case is not an illegal subject of collective bargaining. 2 Whether the Nepotism Policy was a Mandatory Subject of Collective Bargaining *5 The plaintiff argues that its nepotism policy is an ethics rule, and the power to adopt the policy has been explicitly delegated to it by article tenth, 1, of the Connecticut constitution 8 and General Statutes 7 148(c)(10)(B). 9 Thus, according to the plaintiff, adopting the nepotism policy was within its managerial prerogative, so it was not required to collectively bargaining with HMEA before adopting that policy. Moreover, the plaintiff contends that any obligation to bargain with HMEA before adopting the nepotism policy violates its home rule authority under the Connecticut constitution. In response, the defendants contend that the nepotism policy relates to conditions of employment that are not exclusively within the managerial prerogative of the plaintiff and that the requirement to collectively bargain regarding the nepotism policy did not violate the plaintiff s home rule authority because it did not affect a matter of purely local concern. With respect to managerial prerogatives, our Supreme Court has stated: [N]ot all unilateral changes made by an employer constitute a refusal to bargain, such as when... the change solely concerns a matter fundamental to the operation of the public agency and falls within the realm of sole managerial discretion... Board of Education v. Board of Labor Relations, 299 Conn. 63, 74, 7 A.3d 371 (2010). In West Hartford Education Ass n, Inc. v. DeCourcy, 162 Conn. 566, 295 A.2d 526 (1972), our Supreme Court addressed an issue, similar to that in the present case, involving whether a board of education was required to bargain in good faith regarding changes in education policies concerning extra-curricular activities. The DeCourcy court reasoned that [t]he notion that decisions concerning the core of entrepreneurial control are solely the business of the employer appears to have a special kind of vitality in the public sector. Id., at 583. The court noted that, regarding federal agencies, the obligation to negotiate does not extend to such areas of discretion and policy as the mission of the agency, its budget, its organization and the assignment of its personnel, or the technology of performing its work. The court analogized that, with regard to school boards, [e]ducational policy is the parallel concept limiting the scope of negotiations in teacher-school board relations... [and] at the very least, matters of educational policy are those which are fundamental to the existence, direction and operation of the enterprise. Id. Nevertheless, the DeCourcy court reasoned that, with regard to [t]eacher load [which] means the number of teaching classes per day or per week and the number of different preparations per day or per week... [t]here can be no doubt that policy questions are involved in these matters but that cannot be decisive... The basic question... is whether these matters are mandatory subjects of negotiation in accordance with the legislative mandate by its adoption of the Teacher Negotiation Act. Class size and teacher load chiefly define the amount of work expected of a teacher, a traditional indicator of whether an item is a condition of employment. Further, we see from the stipulation that of the ninety-six group teacher contracts negotiated in Connecticut, sixty-one have class size provisions and forty-one have provisions dealing with teacher load. The legislative intent is clear that class size and teacher load are mandatory subjects of negotiation. Id., at *6 The DeCourcy court then determined that although [t]here can be no doubt that the defendant board of education alone is empowered to determine whether there shall be extracurricular activities and what such activities shall be... issues involving assignment of teachers to such activities and the question of compensation for such extracurricular activities affect salaries and other conditions of employment and are to that extent only, mandatory subjects of negotiation. Id., at The dichotomy between those subjects within a public entity s managerial discretion and those conditions of employment that are subject to mandatory collective bargaining was well-illustrated by the court in Board of Trustees for Community/Technical Colleges v. Board of Labor Relations, Superior Court, judicial district of Hartford, Docket No. CV S (January 8, 1993, Flynn, J.) (8 Conn. L. Rptr. 217, 219). There, the court, citing several earlier cases, wrote, Examples of such managerial discretion include: whether to conduct extra curricular school activities, and what, if any, they 2014 Thomson Reuters. No claim to original U.S. Government Works. 4

5 would be, DeCourcy, supra, at ; whether to establish a paramedic unit in a city fire department, Danbury v. International Association of Firefighters, I.A.F.F., Local 801 et al., 221 Conn. 244 [603 A.2d 393 (1992) ]; how much to appropriate for housing security, New Haven v. New Haven Police Local 530, 2 [1]0 Conn. 597 [557 A.2d 506 (1989) ]; whether to shut down a facility no longer needed, First National Maintenance Corporation v. NLRB, 452 U.S. 666, 686 [101 S.Ct. 2573, 69 L.Ed.2d 318]. However, when the agency decides to hire a coach for an extracurricular school sport, or staff a paramedic unit in the fire department, or hire housing security guards, or shut down a facility which becomes unnecessary, rates of pay, promotional security, seniority in layoffs or any other aspect of the employment necessary to implement that discretionary decision may require mandatory collective bargaining. Id. In the present case, although the plaintiff is empowered to adopt a code of ethical conduct under 7 148(c)(10)(B), to the extent that such a code affects conditions of employment, its provision are subject to mandatory collective bargaining under DeCourcy. The plaintiff s nepotism policy mandates that familial relationships shall be taken into consideration when relatives of employees are being reviewed for new job assignments, transfers or promotions and requires that, if two existing employees of the City work together in a supervisory relationship, in some circumstances one of the employees may be transferred or otherwise reassigned. Application of that policy plainly affected the conditions of Plessy Cloud s employment because it required her transfer to another department within the city. To that extent, the plaintiff was required to bargain collectively in good faith with HMEA regarding that policy. *7 The plaintiff contends, nonetheless, that being required to bargain regarding even aspects of the nepotism policy that affect conditions of employment violates the home rule provision of our state constitution. Article tenth, 1, of the Connecticut constitution prohibits the legislature from encroaching on the local authority to regulate matters of purely local concern, such as the organization of local government or local budgetary policy. (Internal quotation marks omitted.) Carofano v. Bridgeport, 196 Conn. 623, 630, 495 A.2d 1011 (1985). Section s mandatory collective bargaining provision regarding conditions of employment of municipal employees, however, goes to matters that are not of purely local concern. The protection of the right of municipal workers to collectively bargain regarding their conditions of employment is one of statewide concern. Furthermore, given that a municipality s workforce is usually not exclusively residents of that municipality, even when applied to a single municipality, collective bargaining regarding conditions of employment is seldom confined exclusively to the residents of one municipality. See id., at 631. Therefore, requiring that municipalities collectively bargain regarding conditions of employment does not violate the home rule provision of the Connecticut constitution. It is evident from our case law, the face of the plaintiff s nepotism policy, and Plessy Cloud s transfer that the policy affected conditions of employment, making it a mandatory subject of collective bargaining under Furthermore, mandatory collective bargaining with regard to conditions of employment does not encroach on the plaintiff s local authority to regulate matters of purely local concern because it pertains to employees rights to collectively bargain regarding their conditions of employment, which is of statewide concern and because such collective bargaining seldom applies only to the residents of a single municipality. 11 III CONCLUSION For the foregoing reasons, the court affirms the decision of the board. Judgment shall enter accordingly. Footnotes 1 That attachment stated, in relevant part: STATEMENT OF POLICY Relatives of City of Hartford employees are eligible for employment at the City. However, to insure that the financial and professional integrity of the City is maintained, the employment of relatives shall not: 1. Create a direct supervisory relationship between relatives; 2. Create a situation where an individual who is appointed or elected into a supervisory role not of their creation continues to supervise a relative; 2014 Thomson Reuters. No claim to original U.S. Government Works. 5

6 3. Allow one relative to influence job assignments, promotional opportunities, compensation, discipline, and performance review of another relative; or 4. Allow one relative to approve compensation of another relative. 5. Create an actual conflict of interest or the potential for or appearance of conflicts of interest. * * * This policy shall be taken into consideration when relatives of employees are being reviewed for new job assignments, transfers or promotions. If two existing employees of the City work together in a supervisory relationship, and become related, as defined herein, a case-by-case analysis shall be made. In some circumstances, one of the employees may be transferred or otherwise reassigned. Exceptions may be made if there is a plan, approved by the Chief Operating Officer, that is designed to eliminate the conflict of interest or the opportunity for favoritism. 2 The board ordered that the plaintiff cease and desist from unilaterally employing the nepotism policy to members of the bargaining unit, restore Plessy Cloud to her previous position until the parties completed collective bargaining, bargain in good faith with the union regarding the purposed nepotism policy, post a copy of the decision and order in a conspicuous place for sixty days, and notify the board within thirty days regarding the steps taken to comply with the order. 3 The plaintiff, in its brief, states that the decision and order should be reversed on the law. It is evident from this and the remainder of the plaintiff s brief that it is challenging the legal determination of the board and not its factual findings. Nevertheless, to the extent that the plaintiff s appeal can be construed as challenging any factual determinations of the board, the court finds that the board s factual determinations are supported by substantial evidence in the record. 4 It is unclear from the city s brief whether it is arguing that the nepotism policy is an illegal subject of collective bargaining because (1) any contractual provision regarding the nepotism would violate public policy, or (2) a requirement that it engage in the process to bargain collectively regarding the nepotism policy violates public policy. For instance the plaintiff writes in its brief: Public policy trumps both the enforcement of an illegal contractual term and the obligation to collectively bargain. Therefore, the court will address both claims. 5 General Statutes 7 148h(b) provides: Notwithstanding the provisions of any special act, municipal charter or ordinance to the contrary, an elected official of any town, city, district or borough that has established a board, commission, council, committee or other agency under subsection (a) of this section, has an interest that is in substantial conflict with the proper discharge of the official s duties or employment in the public interest... if the official has reason to believe or expect that the official, the official s spouse or dependent child, or a business with which he is associated, as defined in section 1 79, will derive a direct monetary gain or suffer a direct monetary loss... by reason of the official s official activity. Any such elected official does not have an interest that is in substantial conflict with the proper discharge of the official s duties in the public interest... if any benefit or detriment accrues to the official, the official s spouse or dependent child, or a business with which he, his spouse or such dependent child is associated as a member of a profession, occupation or group to no greater extent than to any other member of such profession, occupation or group. Any such elected official who has a substantial conflict may not take official action on the matter. 6 Rule 2.13(a)(2) of the Code of Judicial Conduct provides: In making or facilitating administrative appointments, a judge... shall avoid nepotism, favoritism, and unnecessary appointments. 7 The court in Low v. Madison, supra, 135 Conn. at 10, determined that a member of a town s zoning commission could not, with propriety, vote upon his wife s application, and, since the change of zone purportedly made depended upon his participation, the action of the zoning commission was invalid. 8 Article tenth, 1, of the Connecticut constitution provides: The general assembly shall by general law delegate such legislative authority as from time to time it deems appropriate to towns, cities and boroughs relative to the powers, organization, and form of government of such political subdivisions. The general assembly shall from time to time by general law determine the maximum terms of office of the various town, city and borough elective offices. After July 1, 1969, the general assembly shall enact no special legislation relative to the powers, organization, terms of elective offices or form of government of any single town, city or borough, except as to (a) borrowing power, (b) validating acts, and (c) formation, consolidation or dissolution of any town, city or borough, unless in the delegation of legislative authority by general law the general assembly shall have failed to prescribe the powers necessary to effect the purpose of such special legislation. 9 General Statutes 7 148(c)(10)(B) provides: Any municipality shall have the power to do any of the following, in addition to all powers granted to municipalities under the constitution and general statutes:... [a]dopt a code of ethical conduct The Teacher Negotiation Act provision at issue was General Statutes d, which at the time provide[d] in pertinent part as follows: The town or regional board of education and the organization designated or elected as the exclusive representative for the appropriate unit, through designated officials or their representatives, shall have the duty to negotiate with respect to salaries and 2014 Thomson Reuters. No claim to original U.S. Government Works. 6

7 other conditions of employment about which either party wishes to negotiate, and such duty shall include the obligation of such board of education to meet at reasonable times, including meetings appropriately related to the budget-making process, and confer in good faith with respect to salaries and other conditions of employment, or the negotiation of an agreement, or any question arising thereunder and the execution of a written contract incorporating any agreement reached if requested by either party, but such obligation shall not compel either party to agree to a proposal or require the making of a concession. DeCourcy, supra, 162 Conn. at Additionally the board s decision is entitled to significant deference. As this court has previously articulated, [E]ven if an agency s construction of a statute has not been the subject of judicial scrutiny, the agency s interpretation of the statute is still entitled to significant deference if the agency has consistently followed its construction over a long period of time, that construction has been formally articulated, and its construction is reasonable. Peruta v. Freedom of Information Commission, Superior Court, judicial district of New Britain, Docket No. CV S (November 7, 2013, Prescott, J.) [57 Conn. L. Rptr. 135] (citing Longley v. State Employees Retirement Commission, 284 Conn. 149, , 931 A.2d 890 (2007)). As the board indicated in its decision in the present case: It is by now well settled that nepotism policies are mandatory subjects of bargaining. Waterbury Board of Education, Decision No (2008); Town of Newington, Decision No (1991). The decisions the board cites demonstrates that it has consistently constructed nepotism policies as being mandatory subjects of collective bargaining for more than twenty years. Furthermore, the board has formally articulated this construction. As the board stated, citing its decision in Waterbury Board of Education, Decision No (2008), a nepotism policy has a direct effect on conditions of employment in that it has the potential to affect wages, foreclose the possibility of promotion or transfer, or lead to demotion or termination, among other employment-related actions. Moreover, following the board s 1991 decision interpreting to require collective bargaining regarding nepotism policies, the legislature amended by enacting No of the 1993 Public Acts, but, in so doing, did not make any amendments that indicated a rejection of the board s construction of the statute as it pertained to nepotism policies. The legislature has not subsequently amended Thus, the legislature s lack of action in response to the board s decision also strongly suggests its acquiescence to the board s construction of the statute. Finally, the board s construction is a reasonable one as indicated by this court s discussion in Part IIB above. End of Document 2014 Thomson Reuters. No claim to original U.S. Government Works Thomson Reuters. No claim to original U.S. Government Works. 7