The Role of the State Attorney General Syllabus — Fall 2015 Columbia Law School

Professor James E. Tierney Director of the National State Attorney General Program at Columbia Law School (http://www.stateag.org)

Attorney General of Maine (1980 - 1990)

Professor Peter Brann Lecturer in Law, Columbia Law School Solicitor General and Assistant Attorney General in Maine (1981 – 1999)

Note: Syllabus is subject to change depending on the schedules of visiting attorneys general

Introduction:

This Syllabus contains federal and state statutes and case law, law review and descriptive articles from a variety of sources, and hypotheticals that describe the nature and function of the Office of State Attorney General. There is no text for the course and all materials have been collected from over thirty years of studying and participating in the decision making of attorneys general and their staffs.

The roots of the Office of State Attorney General run deep in American jurisprudence. All thirteen American colonies had an attorney general and today all fifty states have opted for providing legal services through an office of state attorney general. Each office possesses extraordinarily broad jurisdiction and to varying degrees is independent from the executive branch of state government. Attorneys general in forty three states are elected statewide on a partisan basis

The combination of sweeping jurisdiction and constitutional independence has given rise to a unique American legal institution of growing importance. Although the course will discuss the largest and most controversial of legal issues - marriage equity, consumer protection, public corruption and mass incarceration to name a few - it will also cover the day to day challenges faced by attorneys general and their staffs in delivering the high quality legal advice that will guide state government in a constitutional and ethical manner. The course will also cover the relationship of attorneys general with the federal government, the private bar and a myriad of advocacy organizations.

Although each state is unique, the course will demonstrate the remarkable congruence that exists among state attorneys general when addressing similar challenges and issues. Unlike private and other government lawyers, who work subject to ethical rules that defer decision making to agency “clients,” for the 13,000 men and women it is the representing the "public interest" that is the day-to-day reality of their professional lives.

The course is weighted toward those decisions by attorneys general that reflect their independent status that is most often revealed when legislatures, other elected officials or state agencies exceed their constitutional or statutory authority.

The Syllabus also focuses on those parts of the Model Rules of Professional Responsibility and various articles and statutes that govern representation by attorneys general. It also contains numerous hypotheticals, almost all of which have been drafted by Columbia Professor Peter Brann, that are drawn from actual cases but because of their nature have not been studied or, in most cases, ever been made public.

Week #1—September 10, 2015

The Authority and the Culture of the Role of the Attorney General

This week explores the nature of the authority and the culture that pervades offices of attorney general. The first chapter of Walter Mondale's The Good Fight, which covers Mondale's time as the Attorney General of Minnesota over 50 years ago, serves as a good introduction to the Role of the Attorney General. Used with the permission (and to the personal delight) of the author, this edited chapter combines almost all aspects of the office of attorney general, e.g., the common law, statutory authority, conflicting legal and policy demands, resource restriction, the role of academics and outside counsel, hard core partisan politics and personal ambition. The chapter is also testimony that for all of the changes in the legal and political world, some things remain remarkably the same.

Also included in this first week are edited sections of Paul Wilson's "A Time to Lose, Representing Kansas in Brown v. Board of Education," which show a very different side of state attorney general authority that reflects the long term consistency of issues facing attorneys general in their decision making.

Because the culture of offices of attorney general is marked by a "fix it" agenda, the first week also contains readings that describe state "parens patriae" and the duty of state attorneys general to represent all the people of their states and not be limited to representing a specific state agency. Finally, we will include the reflections of three attorneys general who left office at the end of 2014.

1. Walter Mondale, The Good Fight (2010) (Chapter 1, edited)

2. Wilson, Paul E. A Time To Lose, Representing Kansas In Brown v. Board Of Education. Kansas: University Press of Kansas, 1995

3. State v. Lead Industries Association, Inc. 951 A.2d 428, (R.I. 2008)(Track III, A and B)

4. Memorandum of Former Members of the New Hampshire Attorney General Office on HB 89, Docket No. 2011-0319, May 23, 2011 (Amici to the NH Supreme Court on an Opinion of the Justices.)

5. Richard P. Ieyoub and Theodore Eisenberg, State Attorney General Actions, the Tobacco Litigation, and the Doctrine of Parens Patriae, 74 Tul. L. Rev. 1859, 1863-1870 (2000) (Edited)

6. Gansler Reflects As Frosh Prepares To Take Office As Attorney General, WBAL NewsRadio 1090, January 5, 2015

7. The Role of Attorney General[Nebraska Attorney General Jon Bruning] KOLN-TV; 1011Now, October 31, 2014

8. Greg Neumann, Van Hollen Says Scrutiny From Media And Partisans Contributed To His "Burn Out" As Attorney General, KNOW.com, December 18, 2014

Week #2—September 17, 2015

The Structure of the Office of the Attorney General

State attorneys general have never fit easily into the existing framework of state government. This week explores the independence inherent in the office of modern attorney general.

1. Feeney v. Commonwealth, 373 Mass. 359, 366 N.E.2d 1266 (1977)

2. People ex rel. Deukmejian v. Brown, 29 Cal.3d 150, 624 P.2d 1206 (1981)(Edited)

3. William P. Marshall, Break Up the Presidency? Governors, State Attorneys General and Lessons from the Divided Executive, 115 Yale L.J. 2445-2469 (2006)

4. Generic State Attorney General’s Office Organization Chart.

5. Delaware AG Investigates Own Client, Celia Cohen, Grapevine Political Writer, Sept. 15, 2007

6. “AGs' powers a subject of contention.” Denver Post Capitol Bureau, Martinez, J. C. (2003, December 7).

7. “Kentucky attorney general skewers health cabinet for failing to release child death records.” Loftus, T. The Courier-Journal 2012, October 15; “R.I. Attorney General Steps Up for Press,” Connelly, Cara, Courthouse News Service, July 16, 2014

8. No Charges to Be Filed In Prison Sentence Screw- Up, Nebraskawatchdog.Org, November 24, 2014

9. White, E (February 1, 2015) Michigan Prison System Challenged In Lawsuit Alleging Sexual Abuse Of Male Teens By Adults, The Associated Press

9. Breaking the Law—and Blaming the Supreme Court, Garrett Epps, The Atlantic, May 13, 2015

12. After Tiff, AG’s Office Resumes Enforcing Public Records Law, The Boston Globe, June 12, 2015

13. Samantha Lachman, For North Carolina Attorney General, Running For Governor Will Mean Taking On His Top Client, Huffington Post, April 2, 2015

14. “Who is the Client?” – A Role Playing Hypothetical

Week #3 — September 24, 2015

Model Rules and the Ethics of Client Representation

The constitutional and statutory duties of attorneys general can be at variance with the Model Rules of Professional Responsibility. This week focuses on core ethical readings as well as concrete ethical dilemmas that are faced by almost every attorney general.

1. Justin G. Davids, State Attorneys General and Client-Attorney Relationship: Establishing the Power to Sue State Officiers, 38 Colum. J.L. & Soc. Probs. 365 (2005)

2. Jack B. Weinstein, Some Ethical and Political Problems of a Government Attorney, 18 Me. L. Rev. 155 (1966)

3. Newspaper stories describing positions of then Alabama Attorney General William Pryor and Alabama Supreme Court Chief Justice Roy Moore, (2003 - 2012)

4. Richard W. Painter, Letter to ABA President on State Attorneys General and MR 3.8, December 27, 2014

6. Watts, A., & Martinez M. (February 5, 2015) Judge rejects Arizona's effort to dismiss prison teacher rape lawsuit, CNN

7. Freeport v. FERC, 962 F.2d 45 (D.C. Cir. 1992)

8. Columbia Law School, Ethics Resources: http://goo.gl/LBYLFi

9. Ethics Hypotheticals

Week #4 – October 1, 2015

AGs and U.S. Supreme Court Practice

Other than the U.S. Solicitor General, state government is by far the most frequent litigant in the U.S. Supreme Court on such issues as the death penalty, climate change, gun control, foreclosure jurisdiction, immigration, voting rights and, of course, the Affordable Care Act. This class will study states’ practice before the Supreme Court, including the important role played by attorneys general submitting amici curiae briefs.

1. Statistics on Amicus Briefs filed by States in the U.S. Supreme Court, NAAG (2015)

2. 2014 Supreme Court Report - Workload of the Courts

3. “Results of Cert Petitions on Filed by States” NAAG (2014) 4. Kevin C. Newsom, “The State Solicitor General Boom,” 32 Appella Practice J. 6 (2013)

5. “Where Are They Now? Former State Solicitor Generals,” Newspaper articles about former State Solicitor Generals (Update needed)

6. Respondent’s Brief (Ted Cruz), Medellín v. Dretke Director, Texas Department Of Criminal Justice, Correctional Institutions (2005) (Winner of NAAG Best Brief Award)

7. Amicus Brief (Noah Purcell - Washington) - Texas v, United States (Pending. US Dist Court, Southern Texas)

8. Amicus Brief (Michael Scodro - Illinois) – State of Mississippi v. Au Optronics Corp., Et Al.

9. Roper v Simmons Alabama amicus

10. Roper v. Simmons (2005) (Edited)

AGs and the Issuance of AG Opinions

All state attorneys general have the authority to issue formal opinions. They provide advice on issues large and small to government actors, from municipalities up to the Governor. This section reviews that authority, and the factors that go into when, and when not, to issue an attorney general opinion.

1. Aid for Women v. Foulston, 427 F. Supp. 2d 1093 (D. Kan. 2006), vacated as moot following repeal of statute, 2007 WL 6787808 (10th Cir. 2007) (Edited)

2. State Attorneys General Powers and Responsibilities, Chapter 5, “Opinions,” Emily Myers, Antitrust Chief Counsel, NAAG; Andy Bennett, Judge, Tennessee Court of Appeals, 2013

3. “Virginia Attorney General Ken Cuccinelli was just doing his job,” Jeff Schapiro, Richmond Times-Dispatch, September 16, 2012

4. Selected Attorney General Opinions (2007 – 2015)

5. What’s Your Opinion?

Week #5 – October 8, 2015

Consumer Protection

Since the passage of state Unfair and Deceptive Practices Acts (UDAP) in the late

1970’s, all state attorneys general have responsibility in the area of consumer protection. This week discusses the broad nature of that authority as well as its limitations. Future weeks will discuss how state attorneys general cooperate with other attorneys general on multistate matters, and also how UDAP cases interact with the private bar and the federal government.

1. “Consumer Protection in the United States: An Overview,” Waller, Brady, and Acosta, European Law Journal (2011)

2. Ch 93A: Regulation of Business Practices for Consumer's Protection. (Ma. Consumer Protection Statute) (2013)

3. Massachusetts Attorney General's Office awards $1.66 million to consumer protection agencies, Masslive.com, October 29, 2015

4. Consumer Protection Attorney General website sampling, (2015)

5. Henry N. Butler & Joshua D. Wright, Are State Consumer Protection Acts Really Little-FTC Acts?, 63 Fla. L. Rev. 163 (2011)

6. Dougherty C., [March 10, 2015]CFPB Finds Arbitration Harms Consumers, Presaging New Rules, Bloomberg Business

7. “Should State Attorneys General Be Setting National Policy? A Case Study of Mandatory Consumer Credit-Card Arbitration.” Nick Houpt, Columbia Law School, ‘11 (2010)

8. Accretive Readings – 2012-2014: “Tolan’s Way,” Steven Strahler, Crain’s Chicago Business, March 3, 2008.

9. Minnesota Attorney General v Accretive various articles 2012- 2015

10. New Rules to Limit Tactics on Hospitals’ Fee Collections

11. Massachusetts Attorney Generals Office Mediation Process (2015)

12. Consumer Protection and Health Fraud Newsletters (2013-2015)

13. “New York's Attorney General: Reluctant Scourge of the Sharing Economy,” Joshua Brustein, Bloomberg News, July 16, 2014

14. Eric Lipton, Lobbyists, Bearing Gifts, Pursue Attorneys General, New York Times, October 28, 2014

15. Koster Releases Top 10 List of Consumer Complaints in 2014, February 5, 2015, KOLR10 News

16. Chris Koster, Missouri Attorney General, Decision Making in Consumer Investigations

17. Attorney General (Greg Zoeller) settles with Aspen Dental, Kokomo Tribune, October 23, 2015

18. Vermont AG: Propane dealer to pay over $700K in penalties, SFGate.com, October 26, 2015

19. Gisriel, Sarah, “West Virginia Attorney General reaches settlement with Frontier”, http://www.your4state.com, December 10, 2015

Week #6 —October 15, 2015

Multistate Advocacy Over the last twenty five years, attorneys general have increasingly worked together in multistate advocacy. This section explores this development in a wide range of different subject matter areas.

1. Jason Lynch, Federalism, Separation of Powers, and the Role State Attorneys General in Multistate Litigation, 101 Colum. L. Rev. 1998 (2001)

2. Early cases: a. “Baldwin Accord Criticized,” The New York Times, February 8, 1985, Page D2 b. “States Sue Over Acid Rain,” U.P.I., March 20, 1984.

3. States Flex Prosecutorial Muscle: AG’s Move Into What Was Once Federal Territory, Brooke A. Masters, Washington Post, Wednesday, January 12, 2005, Page 2005, Page A1

4. Stag Hunting with the State AG: Anti-tobacco Litigation and the Emergence of Cooperation Among State Attorneys General, Thomas A Schmeling, SSRN, (2004)

5. Clevenger, A.“AG's offices settles with Publishers Clearing House” The Charleston Gazette. 2010, September 9; Penn, I. “Sweepstakes 'winners' complain about charges from National Magazine Exchange” Tampa Bay Times. 2011, February 25.

6. Lupika, Mitch. “Consumer Complaints Against DIRECTV lead to $14 million Settlement” Daily Finance. 2010, December 14.

7. Testimony of New York Assistant Attorney General Deanna Nelson, Soldiers as Consumers (2013)

8. Testimony of Tennessee Attorney General Robert Cooper, Soldiers as Consumers (2013)

9. Delaware Office of The Attorney General. (July 29, 2014) “Biden

Acts to Protect Military Servicemembers from Predatory Lending Scheme” [Press Release]

10. Nolette Paul, [March 5, 2015], State attorneys general are more and more powerful. Is that a problem?, The Washington Post

11. Multistate Case Hypothetical (2014)

Week #7 and 8— October 22 and 29, 2015

Relationship with Federal Government Relationship with Federal Government State attorneys general have a complex relationship with the federal government, including the Department of Justice, local U.S. Attorneys, and other federal agencies. In most cases, attorneys general cooperate with federal agencies to carry out federal policy. In some cases and in some states, such as on matters arising from health care, immigration, voting rights and the environment, attorneys general attempt to either challenge or prompt federal action. This section analyzes this complex and changing relationship.

We will be joined for the first hour of the class on October 29, by The Hon. Patrick Lynch, the former Attorney General of Rhode Island and the former President of NAAG.

I. Theory:

1. “Federalism Under Obama,” Gillian E. Metzger. 53 Wm. & Mary L. Rev. 567 (2011) (Edited)

2. “Partisan Federalism,” Jessica Bulman-Pozen, 127 Harvard Law Review 1077, 1083, (2014) (Edited)

II. AGs Cooperation With The Federal Government:

1. Obama Preemption Order, The White House Office Of The Press Secretary May 20, 2009

2. Dannon Settlement 2010:

a. Attorney General Bill McCollum “Attorney General Reaches Settlement Agreement with Dannon Over Advertising Practices” Press Release, 2010, December 15

b. Williams, T. “Dannon Settles With F.T.C. Over Some Health Claims.” New York Times. 2010, December 15

3. “Indiana Attorney General Joins FTC in Efforts to Fight Business opportunity scams,” Press Release of the Indiana Attorney General, November 15, 2013

4. “CFPB, 47 States and D.C. Take Action Against JPMorgan Chase for Selling Bad Credit Card Debt and Robo-Signing Court Documents”, Press Release from The Consumer Financial Protection Bureau, July 8 2015

5. Gara, Antoine, Federal Judge Rules In Favor Of FTC Challenge To Sysco And US Foods Merger, Forbes, June 23, 2015

6. Department of Justice Sues Standard & Poor’s press release and news articles (updated 6/12/15)

7. Justice Department Charges Standard & Poor’s Defrauded Investors, PBS Newshour, February 5, 2014 (VIDEO)

8. Justice Department and State Partners Secure $1.375 Billion Settlement with S&P for Defrauding Investors in the Lead Up to the Financial Crisis, Department of Justice (Press Release), February 3, 2015

9. Madigan, DOJ & States Announce $1.375 Billion Settlement With Standard & Poor’s, Illinois Attorney General (Press Releases), February 3, 2015

10. Steve Mistler, States Vary On Plans For Money From Standard & Poor’s Settlement, Portland Press Herald, March 30, 2015

11. Ivory, Danielle, U.S. States Jumping Into Investigation of VW Emissions Deception, The New York Times, October 2, 2015

III. AGs In Opposition For The Federal Government:

1. States Sue Over Acid Rain,” U.P.I., March 20, 1984

2. Massachusetts v. Environmental Protection Agency

3. “They Warned Us: The Watchdogs who Saw the Subprime Disaster Coming– and How they were Thwarted by the Banks and Washington,” Robert Berner and Brian Grow. Business Week, October 20, 2010

4. Julia Preston, States Are Divided by the Lines They Draw on Immigration, The New York Times, March 29, 2015

5. Dylan Scott, Why GOP Attorneys General Are Suing Obama Over Any And Everything, February 19, 2015, Talkingpointsmemo.com

6. Horgan, Sean “State targets NOAA science, tactics,” Gloucester Times, March 19, 2014

7. Eric Lipton, Lobbyists, Bearing Gifts, Pursue Attorneys General, New York Times, October 28, 2014

8. Lipton, Eric, Energy Firms in Secretive Alliance With Attorneys General, The New York Times, December 6, 2014

9. Your 5News Team, Attorney General Leads Multi-State Lawsuit Against EPA, 5 News WDTV, October 23, 2015

Week #9 – November 5, 2015

Relationship of the Attorney General and Private Lawyers

Attorneys general increasingly allow private lawyers to represent state government sometimes on a contingent fee basis and sometimes on an hourly fee basis. This has been criticized by interest groups on both sides of the political spectrum. This section explores the legal and ethical issues that arise from attorneys general allowing state legal work to be done by private counsel. The questions that will be asked will include: why is there an increase in the use of outside counsel?; when is the practice okay?; and what protections should be put into place to make sure it is not abused?

We will be joined for the first hour of the class by The Hon. Nick Gess, a Principal at Morgan Lewis Consulting, who also served as a member of U. S. Attorney General Janet Reno’s senior staff and as an Associate Deputy Attorney General (ADAG) where he was a senior adviser to Reno and then Deputy Attorney General Eric H. Holder, Jr. Prior to that time he served as an Assistant United State Attorney, an Assistant Attorney General and an Assistant District Attorney in Maine.

1. State v. Lead Industries Association, Inc. 951 A.2d 428 (R.I. 2008) (Edited)

2. Richard Samp - Growing Concern over Contingency Fee Agreements, BNA, Sept 9, 2012

3. Lipton, Eric, Lawyers Create Big Paydays by Coaxing Attorneys General to Sue, New York Times, Dec. 18, 2014

4. Outside Legal Counsel – Mississippi

5. Chamber of Commerce Report – Frequent Flyers

6. AT&T Mobility v. Concepcion (2011)

7. Georgia “Attorney general sets contingency fee policy”. Walter C. Jones, Morris News Service, May 30, 2012

8. “Kansas Abortion Lawsuits Cost $913K,” Hanna, John, The Washington Post, October 14, 2013

9. Kansas AG defends decision to hire outside abortion counsel. The Capital-Journal, 2011, July 15

10. Elmore, Charles, “Lobbying group picks up costs of Florida's health-care legal

challenge,” Palm Beach Post, Feb. 19, 2011

11. Ryan Luby, Attorney general [Hector Balderas] unveils changes on hiring private lawyers, KOB Eyewitness News 4, March 30, 2015

12. Silver-Greenberg, Jessica and Gebeloff, Robert, Arbitration Everywhere, Stacking the Deck of Justice, New York Times, October 31, 2015

13. Steve Terrell, Few financial ties found between private attorney contracts, AG campaigns, The New Mexican, April 5, 2015

Week #10—November 12, 2015

Negotiation Exercise

This week, we put to use the information we have learned so far about Attorneys’ General, multistate litigation, outside counsel, and the relationship to the federal government, by engaging in a mock negotiation between a bank (along with its insurer) on the one hand, and the states and the federal government (along with outside counsel), on the other hand. The problem is posted below, along with the character assignments. Also posted are a couple of student articles that will provide background on the financial crisis and the states’ approaches to dealing with that crisis. Each student also will be given secret, personal instructions that you may share, or not, with your team or with the other side, as you see fit. Each side should meet ahead of class to discuss strategy. Come to class prepared to negotiate.

1. Character List

2. Multistate Predatory Lending Negotiations Background

3. John Schwab, The Road Less Travelled: Alternatives to Multi-State Litigation in Response to the American Mortgage Crisis

4. Sally Peacock, How the Household Settlement Uncorked a Law Enforcement Bottleneck (Edited)

Week #11 – November 19, 2015

Attorneys General and Prosecution of Public Corruption

Public corruption cases are often the most challenging, sensitive and complicated criminal matters that state attorneys face. This class will focus on the challenges the criminal jurisdiction of attorneys general with a discussion of the appropriate ways in which state attorneys general respond to allegations of corruption and ethics violations by state and local elected officials.

1. State Attorneys General Powers and Responsibilities, Chapter 17, “Attorneys General and Criminal Law” Chris Toth, Deputy Director, NAAG; Adam Eisenstein, AAG Visiting Fellow; Salini Nandipati, NAAG Visiting Fellow

2. New Mexico Attorney General’s parallel proceedings policy. 2011, March 9

3. Commonwealth v. Powers Fasteners, Inc. Ma Sup Ct Docket No 07-10802 (Dec 12, 2007)

4. Nevada AG Indictment of Nevada Lt. Governor case and dismissal - Various articles Dec 2009

5. Massachusetts Attorney General v. Cahill and settlement - Various articles 2011- 2013

6. Various DA Cases referred to AG - 2011 – 2015

7. Mayor - Age 91 - Steals from Alabama Town - NYT - October 12, 2012

8. Hawaii v. Peters

9. New Mexico Attorney General Balderas outlines new goals for Law Enforcement Academy board, The Associated Press, June 10, 2015

10. New Mexico Attorney General Prosecutes Secretary of State (2015)

11. Attorney General Matt Denn, Criminal Justice Reform, October 15, 2015

12. “Ohio attorney general wants tougher entry standards for officers,” The Associated Press, December 8, 2015

Week #12— December 3, 2015

The Role of State Attorneys General in Non-Profit Governance

State attorneys general have always had some responsibility to review the operations of nonprofit charities and foundations. Particularly as non-profit organizations, such as hospitals, play a larger and larger role in the economy, the attorney general’s increased use of that authority has taken on national significance. The role has taken on new importance with greater scrutiny of non-profit governance of large institutions such as hospitals, health insurers, and universities. This section analyzes the parameters of that authority.

1. By far the most comprehensive treatment of the role of attorneys general and non-profit governance is found at Columbia Law School’s website, “Charities Law Project.”

2. “A Guide to Charitable Trust Case Review: Bob Carlson, Missouri Assistant Attorney General and Hugh Jones, Hawaii, Assistant Attorney General. 2010

3. State Attorneys General Powers and Responsibilities, Chapter 12, “Protection and Regulation of Nonprofits and Charitable Assets.” Bob Carlson, Missouri, Assistant Attorney General. NAAG, 2013

4. Random Charities Cases—Fall 2004-2015

5. New York State Office of the Attorneys General, The Nonprofit Revitalization Act's New Annual Filing Requirements

10. Halperin, David, "Which For-Profit College Lobbyist Are You?” Huffington Post, March 28, 2014

7. Cohen, Rick, “Danger Sign: AGs Succumb to Special Interest Lobbying”, Nonprofit Quarterly, November 3, 2014

8. Barron, James, “New York Attorney General Accuses Brooklyn Children’s Charity of Fraud”, The New York Times, July 20, 2015

9. May 19, 2015 - FTC and 50 AG's - Charities Filing

10. Readings on DeCoster Story (2003-2015)

Week #12— December 3, 2015

The Role of State Attorneys General in Non-Profit Governance

1. By far the most comprehensive treatment of the role of attorneys general and non-profit governance is found at Columbia Law School’s website, “Charities Law Project.”

2. A Guide to Charitable Trust Case Review: Bob Carlson, Missouri Assistant Attorney General and Hugh Jones, Hawaii, Assistant Attorney General. 2010

3. State Attorneys General Powers and Responsibilities, Chapter 12, “Protection and Regulation of Nonprofits and Charitable Assets.” Bob Carlson, Missouri, Assistant Attorney General. NAAG, 2013

4. Hewitt, Elizabeth, “Vermont Attorney General: Paid fundraisers take 70 percent of cash for charities,” VTDigger.com, December 6, 2015

5. Daniels, Alex, Nonprofits Proliferate but Not the Regulators, Says Report, Chronicle of Philanthropy, October 5, 2015 6. Random Charities Cases—Fall 2004-2015

7. New York State Office of the Attorneys General, The Nonprofit Revitalization Act's New Annual Filing Requirements

11. Cohen, Rick, “Danger Sign: AGs Succumb to Special Interest Lobbying”, Nonprofit Quarterly, November 3, 2014

12. Barron, James, “New York Attorney General Accuses Brooklyn Children’s Charity of Fraud”, The New York Times, July 20, 2015

13. May 19, 2015 - FTC and 50 AG's - Charities Filing

14. Readings on DeCoster Story (2003-2015)