October 13, 2017

Co-Chairs Rasha Demashkieh and Laura Reyes Kopack Michigan Civil Rights Commission 110 West Michigan Avenue, Suite 800 Lansing, MI 48913

Dear Co-Chairs Demashkieh and Reyes Kopack,

The undersigned are twenty-seven attorneys and law professors who write to urge the Commission to act on Equality Michigan’s request for an interpretive statement regarding the scope of the Elliott-Larsen Civil Rights Act’s prohibition on sex discrimination.

We are deeply concerned by the events leading up to the Commission’s decision to “table” Equality Michigan’s request. As you know, that decision was made in response to (1) an “informal” oral interpretation of Elliot-Larsen made by a “divisional level” assistant attorney general; and (2) that same assistant attorney general’s assertion that the Commission would forfeit governmental immunity if it issued an interpretive statement that differed from his “informal” interpretation.

Those events should not prevent the Commission from issuing an interpretive statement. It is a bedrock principle of Michigan’s Administrative Procedures Act—and of administrative law generally—that agencies maintain the authority, in the first instance, to interpret the statutes they administer. An assistant attorney general cannot usurp that authority by issuing an “informal” oral interpretation. Nor is there any legal support for the proposition that the Commission forfeits governmental immunity if it disagrees with an “informal” interpretation offered by an assistant attorney general.

We write this letter not on behalf of any client, firm, or institution, but in our capacity as legal professionals and members of the Bar. We are concerned that these recent events undermine the legal order in this State. Michigan’s legislature has expressly granted agencies the authority to interpret the statutes they are charged with enforcing. Allowing an assistant attorney general to unilaterally strip an agency of that interpretive authority—simply because he disagrees with one potential conclusion—circumvents the administrative scheme established by our legislature. It renders nugatory the authority granted to agencies. And it undermines the rule of law.

Ultimately, although we note some strong arguments in favor of Equality Michigan’s position, we do not purport to provide an answer as to the precise scope of Elliott-Larsen’s sex- discrimination provision. Our focus, instead, is on the Commission’s statutory authority to

1 answer that question. For the reasons set forth below, we urge the Commission to exercise that authority as soon as possible.

I. The Commission Has The Authority To Interpret The Scope Of The Elliott- Larsen Civil Rights Act’s Prohibition On Sex Discrimination

A. Michigan Law Empowers The Commission To Issue Interpretive Statements Regarding The Elliott-Larsen Civil Rights Act

“Agencies,” the Michigan Supreme Court has explained, “have the authority to interpret the statutes they are bound to administer and enforce.” Clonlara, Inc. v. State Board of Education, 442 Mich. 230, 240 (1993). That foundational principle is codified in Michigan’s Administrative Procedures Act, which was enacted to facilitate agency promulgation of “rules” and “determinations” regarding statutes. MCL Ch. 24 prec. The Legislature has designated the Commission the body responsible for making such determinations about the scope of the Elliott- Larsen Civil Rights Act. MCL 37.2601(f).

In June, Equality Michigan asked the Commission to exercise that authority, and to issue an “interpretive statement” clarifying that Elliott-Larsen’s sex-discrimination provisions prohibit discrimination on the basis of sexual orientation and gender identity. “Interpretive statements”— a category of agency action which is specifically enumerated in the Administrative Procedures Act, MCL 24.207(h)—“are, basically, those that interpret and apply the provisions of the statute under which the agency operates.” Clonlara, 442 Mich. at 240 (quoting 1 Cooper, State Administrative Law, at 174-175). As the Michigan Supreme Court has explained, agencies should issue interpretive statements to “state the interpretation of ambiguous or doubtful statutory language which will be followed by the agency unless and until the statute is otherwise authoritatively interpreted by the courts.” Id. at 241. Consistent with that instruction, the Commission has at least once issued an interpretive statement to “provide clarity and uniformity in the application of existing law.” Michigan Civil Rights Commission, Interpretive Statement 2012-1 at 1 (May 21, 2012) (interpretive statement regarding the meaning of “qualified interpreter” for deaf people).

B. Elliott-Larsen’s Prohibition On Sex Discrimination Is Ambiguous And Uncertain, And Requires An Interpretive Statement

The need for an interpretive statement regarding Elliott-Larsen’s sex-discrimination provision is manifest. Elliott-Larsen broadly, and repeatedly, prohibits discrimination “because of . . . sex.” See, e.g., MCL 37.2402; 37.2504; 37.2302. Yet the term “sex” is nowhere defined in the Act. Nor does the Act specify precisely what it means to engage in discrimination “because of” sex. And there is at least a plausible argument that discrimination occurs “because of” sex when discrimination is based on sexual orientation or gender identity. After all, where a man is denied housing because he is attracted to men—but a woman attracted to men would not

2 be so denied—that man, quite literally, has been denied housing “because of” his sex. The same is true for gender identity. Where an individual assigned the sex female at birth can be fired for identifying as male—but an individual assigned the sex male at birth who identifies as male could keep his job—that person has, quite literally, been fired “because of” sex.1

Crucially, Title VII of the federal Civil Rights Act maintains an identical prohibition on discrimination “because of . . . sex.” 42 U.S.C. 2000e-2. And a legion of federal authority provides that federal prohibition encompasses discrimination on the basis of sexual orientation and gender identity. For example, the federal Equal Employment Opportunity Commission (EEOC) has clarified that that Title VII’s prohibition on sex-based discrimination also prohibits discrimination based on sexual orientation. After all, the EEOC notes, “‘[s]exual orientation’ as a concept cannot be defined or understood without reference to sex.” Baldwin v. Foxx, EEOC Appeal No. 0120133080 at 6 (July 15, 2015). For similar reasons, EEOC has “clarifie[d] that claims of discrimination . . . based on gender identity are cognizable under Title VII’s sex discrimination prohibition.” Macy v. Holder, EEOC Appeal No. 0120120821 at 14 (April 20, 2012).

Many federal courts agree. The full United States Court of Appeals for the Seventh Circuit recently held that “discrimination on the basis of sexual orientation is a form of sex discrimination.” Hively v. Ivy Tech Cmty Coll., 853 F.3d 339, 341 (7th Cir. 2017) (en banc). The United States Court of Appeals for the Sixth Circuit—which maintains federal jurisdiction over Michigan—has held that a person who has “suffered discrimination because of his or her gender non-conformity” may maintain a “sex discrimination claim.” Smith v. City of Salem, 378 F.3d 566, 575 (6th Cir. 2004). Other federal courts, across the country, are in accord.2

To be sure, federal authority is “not binding on . . . our state statute.” Northville Pub. Sch. v. Michigan Civil Rights Comm’n, 118 Mich. App. 573, 576 (1982). But Michigan courts have repeatedly held that federal precedent is “highly persuasive” when determining the contours of Elliott-Larsen. Id., see also, e.g., Bedker v. Domino's Pizza, Inc., 195 Mich. App. 725, 728 (1992). In light of that—and in light of the robust line of federal authority discussed above— there is at least a serious question whether Elliott-Larsen’s sex-discrimination provision also encompasses sexual orientation and gender identity.

1 There are many additional arguments in support of Equality Michigan’s position. In the main, those arguments have already been submitted to the Commission. For brevity’s sake, we do not repeat them here. 2 See, e.g., Philpott v. New York, No. 16-cv-6778, 2017 WL 1750398 (S.D.N.Y. May 3, 2017); Winstead v. Lafayette Cty. Bd. of Cty. Comm’rs, 197 F. Supp. 3d 1334 (N.D. Fla. 2016); EEOC v. Scott Med. Health Ctr., P.C., No. 16-cv- 225, 2016 WL 6569233 (W.D. Pa. Nov. 4, 2016); Isaacs v. Felder Servs., LLC, 143 F. Supp. 3d 1190 (M.D. Ala. 2015); Videckis v. Pepperdine Univ., 150 F. Supp. 3d 1151 (C.D. Cal. 2015); Terveer v. Billington, 34 F. Supp. 3d 100 (D.D.C. 2014); Boutillier v. Hartford Pub. Sch., No. 13-cv-1303, 2014 WL 4794527 (D. Conn. Sept. 25, 2014).

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That question is not definitively answered by any pre- or post-enactment legislative history. There is (to the best of our knowledge) no historical evidence indicating how Elliott- Larsen’s enacting Legislature thought the phrase “because of sex” would apply to sexual orientation or gender identity.3 Attempting to fill that gap, some commenters have suggested that the failure of recent Legislatures to “add additional classifications . . . such as gender identity [and] sexual orientation” should be given conclusive weight. See Great Lakes Justice Center, Response to Equality Michigan’s Request for Interpretive Statement at 5 (July 28, 2017). We disagree. Such recent history is both inapposite and irrelevant. It is inapposite because the inaction of subsequent legislative actors sheds no light on the intent of the Legislature that enacted the law. And it is irrelevant because the question before the Commission has nothing to do with “adding additional classifications.” Rather, the question raised by Equality Michigan concerns the scope of a classification that already exists.

Indeed, faced with a very similar issue, the United States Supreme Court expressly rejected reliance on post-enactment legislative history. In Massachusetts v. EPA, the Court was charged with determining whether the phrase “air pollutant” in the Clean Air Act included greenhouse gases. In years since the Clean Air Act was enacted, Congress had repeatedly rejected proposals to regulate greenhouse-gas emissions. Yet the Court held that post-enactment history irrelevant. Ruling that the phrase “air pollutant” in the Clean Air Act does, in fact, encompass greenhouse gases, the Court dismissed the argument that more recent Congressional inactivity could shed any light on the original legislative intent. “That subsequent Congresses have eschewed enacting binding emissions limitation to combat global warming,” the Court emphasized, “tells us nothing about what Congress meant when it [enacted the Clean Air Act] in 1970 and 1977.” 549 U.S. at 529-30 (2007) (emphasis added). The same principle applies here.

None of this is to say, one way or the other, whether Elliott-Larsen’s sex-discrimination provision covers discrimination on the basis of sexual orientation or gender identity. It is the Commission’s job to answer that question—and that is what Equality Michigan has asked it to do. Our point is simply that Elliott-Larsen’s sex-discrimination provision ineluctably constitutes “ambiguous or doubtful statutory language.” Conlara, 442 Mich. at 241. The Michigan Supreme Court has held that is precisely the situation in which an interpretive statement is warranted. Id. The Commission is thus well within its authority to issue an interpretive statement regarding the phrase “because of sex” in the Elliot-Larsen Civil Rights Act.

3 Some news reports indicate that activists attempted (unsuccessfully) to convince the Legislature to include sexual orientation as a protected classification when Elliott-Larsen was first adopted. See Tim Skubick, Who is Elliott and who is Larsen? Groundbreakers, that’s who. MLIVE.COM (Nov. 23, 2014), available at http://www.mlive.com/lansing-news/index.ssf/2014/11/tim_skubick_who_is_elliott_and.html. Those articles, however, say nothing about how the enacting Legislature believed the phrase “because of sex” would be applied.

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II. The Assistant Attorney General’s “Informal” Opinion About Elliot-Larsen Does Not Usurp The Commission’s Authority To Interpret The Statute In The First Instance

Yet just as the Commission stood ready to vote on an interpretive statement, the attorney general’s office intervened. For months, the attorney general’s office offered assurances that it would not interfere with the Commission’s exercise of its interpretive authority. Following public hearing on the proper scope of Elliott-Larsen’s sex-discrimination provision, however, Assistant Attorney General Ron Robinson announced a changed course. Mr. Robinson informed the Commission that—in his “informal” view “at the divisional level”—the interpretive statement requested by Equality Michigan “would cross the realm into legislative [decision] making.” Thus, he concluded, the Commission lacked “the authority to make that interpretation.” Mr. Robinson’s statement also came with a warning. If the Commission issued an “interpretation contrary to the advice of the Attorney General’s Office,” Mr. Robinson cautioned, the Commission would “waive its right to governmental immunity and be subject to lawsuit.”

The assistant attorney general cited neither caselaw nor statute in support of his “informal opinion” as to the scope of the Commission’s authority. Instead, he simply stated that the Equality Michigan request for an interpretive statement raised a “threshold” issue: “whether or not this Commission has the authority to make that interpretation.” “As the law currently states,” he continued, “they [LGBT people] are not protected under [Elliott-Larsen].” Thus, Mr. Robinson concluded that the Commission does not maintain the “authority” to issue the interpretive statement requested by Equality Michigan—i.e., that Elliott-Larsen’s prohibition on sex discrimination encompasses discrimination based on sexual orientation and gender identity.

Boiled down to its essence, the attorney general’s position appears to be that an agency may not exercise its interpretive authority if a “divisional level” attorney general so much as “informally” disagrees with a prospective interpretation. Mr. Robinson thinks that “the law currently states” that LGBT people “are not protected.” And because the assistant attorney general believes that is what the law says, it follows (at least in his view) that any deviation from that position would constitute an amendment to the law—and thus “cross the ream into legislative [decision] making.”

Notwithstanding the assistant attorney general’s assertions, there are at least three reasons why the Commission can and should issue an interpretive statement as to the scope of the Elliott- Larsen Civil Rights Act. First, contrary to the assistant attorney general’s view, it is far from clear that that Elliott-Larsen is silent as to discrimination on the basis of sexual orientation and gender identity. As noted above, a deep line of federal authority—authority that is “highly persuasive” in Michigan—provides that discrimination “because of sex” encompasses discrimination based on sexual orientation and gender identity. The assistant attorney general

5 may disagree. But at the very least, the existence of such federal authority makes it “ambiguous” whether Elliott-Larsen prohibits discrimination on the basis of gender identity and/or sexual orientation. See Clonlara, 442 Mich. at 241. That, in turn, makes Elliott-Larsen’s sex- discrimination provision appropriate for an interpretive statement. Id.

Second, and more fundamentally, the assistant attorney general’s unsolicited decision to make a “threshold” determination about Elliott-Larsen conflicts with the statutory and administrative scheme. Nothing in the Administrative Procedures Act, or in Elliott-Larsen itself, contemplates attorney-general involvement in the issuance of interpretive statements. The Administrative Procedures Act provides agencies the authority to issue an “explanatory” interpretive statement. MCL 24.207(h). Elliott-Larsen, in turn, provides the Commission sole responsibility for making such interpretive statements. MCL 37.2601(f). For good measure, the Commission’s own rules set the procedures under which the Commission may issue “interpretive guidelines.” R. 37.23. The attorney general is never mentioned.4

If Michigan’s legislature—or the Commission—intended for the attorney general to make a “threshold” judgment as to whether an interpretive statement is appropriate, surely there would be some hint in the governing statutes, or in the Commission’s rules. That there is no such indication compels the conclusion that the assistant attorney general’s insertion into the matter was unwarranted.

Third, even putting aside the dubious nature of the assistant attorney general’s “threshold” determination, there is no support for the notion that “informal” division-level guidance can displace an agency’s interpretive authority. In fact, even a formal opinion, by the actual Attorney General, probably cannot bar an agency from issuing an interpretive statement. “Informal” guidance by an assistant attorney general thus plainly cannot tie the Commission’s hands.

As a preliminary matter, the Michigan Supreme Court has recently indicated that an Attorney General’s interpretation of a law—even if contained in a formal written opinion—does not bind an administrative agency. In 2002, citing two conflicting lines of authority, the Court recognized that “it is open to question . . . the extent to which a governmental agency is even bound by an opinion of the Attorney General.” Danse Corp. v. City of Madison Heights, 466 Mich. 175, 182 n. 6 (2002). Five years later, that Court waved aside, as non-precedential “dictum,” the line of cases which suggested “formal” attorney general opinions are “binding upon state agencies.” In re Request for Advisory Opinion Regarding Constitutionality of 2005

4 The sole mentions of the attorney general in the Administrative Procedures Act provide that (1) an attorney general opinion is not a “rule,” MCL 24.207; and (2) the “Michigan register shall contain . . . attorney general opinions.” MCL 24.208. The sole mentions of the attorney general in Elliott-Larsen provide (1) for attorney-general representation of the Commission, MCL 37.2602; and (2) that final orders in a hearing on a civil rights complaint shall be provided to the attorney general, MCL 37.2604-05.

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PA 71, 479 Mich. 1, 8 n. 5 (2007) (discussing Traverse City School Dist. v. Attorney General, 384 Mich. 390, 410 n.2 (1971)). It thus appears the Court has tacitly rejected those cases, and instead endorsed the conclusion that “an opinion of the Attorney General . . . does not compel agreement by a governmental agency.” Sch. Dist. of City of E. Grand Rapids, Kent Cty. v. Kent Cty. Tax Allocation Bd., 415 Mich. 381, 394 (1982) (emphasis added). And that makes sense. After all, Michigan’s legislature provided agencies the authority to interpret statutes in the first instance. MCL 24.207(h). It would be passing strange if the Attorney General could displace that entire administrative scheme simply by issuing a “formal” opinion.

All of this is somewhat beside the point, however, because the assistant attorney general’s statement regarding the scope of Elliott-Larsen was not a “formal” opinion by the Attorney General. Far from it. When speaking to the Commission, the assistant attorney general went out of his way to emphasize, repeatedly, that he was speaking only from the “divisional level,” and that his opinion was only “informal.” Those disclaimers were correct. Indeed, it is worth noting that formal opinions by the Attorney General are typically rendered only after questions of law are “submitted to him” by state officers. MCL 14.32. No official request for an interpretation of Elliott-Larsen’s sex-discrimination provision has ever been “submitted to” the Attorney General. Cf. id.

We are unaware of any authority which so much as hints that an assistant attorney general, in an “informal” oral statement, can dictate to an agency the “correct” interpretation of a statute. To the extent Michigan courts have considered the effect of informal attorney-general advice, they have suggested that such advice is not binding. That is true even where (unlike here) the advice comes in written form, and is signed by the Attorney General himself. See Michigan ex rel. Oakland Cty. Prosecutor v. Dep’t of Corr., 199 Mich. App. 681, 691 (1993) (distinguishing between “a formal opinion” by the Attorney General, and “an unpublished letter” by the Attorney General, and concluding that the latter is only “evidence” of the correct interpretation of a statute).

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All of this—the plain ambiguity in Elliott-Larsen; the lack of statutory authority for a “threshold” determination by the Attorney General; and the non-binding, expressly “informal” divisional-level advice—indicates that the Commission should proceed with an interpretive statement. If and when the Commission does so, its interpretation should stand “unless and until the statute is otherwise authoritatively interpreted by the courts.” Clonlara, 442 Mich. at 241 (emphasis added).

That, at the end of the day, is how administrative law in Michigan is supposed to work. Agencies “generally have special competence in interpreting and applying specialized legislation in their field of expertise.” Reinelt v. Michigan Pub. Sch. Emp. Ret. Bd., 87 Mich. App. 769, 774 (1979). Accordingly, where statutory text is ambiguous or uncertain, agencies are granted the

7 initial authority to interpret it. See MCL 24.207. To be sure, agencies sometimes get it wrong. Occasionally, an agency will issue an interpretation that exceeds the scope of the statute. But the question whether an agency’s interpretation was consistent with the statute should be decided by a reviewing court—not by an assistant attorney general before the interpretation has even been issued.

A quick spin through Michigan caselaw indicates that courts are perfectly capable of rendering judgments as to the legality of agencies’ interpretive statements. To take just a few examples:

• In Clonlara v. State Board of Education, the Michigan Supreme Court upheld an interpretive statement requiring home-schooled children to take science and social studies. 442 Mich. at 252. At the same time, however, the Court concluded that an agency requirement that “home schools have school years that last a minimum of 180 days . . . goes beyond the enabling statutes and is therefore an invalid interpretation.” Id. at 251. • In Faircloth v. Family Independent Agency, the Court of Appeals upheld an interpretive statement as to what qualifies as “incapacitated and unavailable for work” under Michigan’s welfare statutes. 232 Mich. App. 391, 396 (1998). • In Boyd v. Civil Service Commission, the Court of Appeals held that an interpretive statement which authorized the strip search of a prison worker did not “contravene[ ]” the relevant statutory provisions. 220 Mich. App. 226, 237 (1996).

The well-trodden path taken in those cases should be followed again here. Notwithstanding the assistant attorney general’s “informal” intervention, the Commission should issue an interpretive statement about Elliott-Larsen’s sex-discrimination provision. If that interpretive statement is challenged in court (by, for example, a business accused of discrimination) the definitive answer as to Elliott-Larsen’s scope will properly come from the judiciary, not from the Attorney General.

III. The Commission Will Not Forfeit Governmental Immunity If It Issues An Interpretive Statement

Contrary to the assistant attorney general’s statement, we think it is improbable that the Commission or its officers could forfeit governmental immunity by issuing the requested interpretive statement. Michigan law provides that the Commission “is immune from tort liability” so long as it is engaged in a “governmental function.” MCL 691.1407. A “governmental function,” in turn, is defined as “an activity expressly or impliedly mandated or authorized by constitution, statute . . . or other law.” MCL 691.1401(b).

The act of issuing an interpretive statement—even one with which an assistant attorney general disagrees—is plainly a “governmental function.” The Commission is expressly

8 authorized, by statute and by caselaw, to issue an interpretive statute about a statute it deems ambiguous. MCL 24.207(h) (authorizing agencies to issue interpretive statements); MCL 37.2601(f) (authorizing Commission to issue interpretive statements); Clonlara, 442 Mich. at 240-241 (affirming agencies’ authority to interpret statutes “unless and until the statute is otherwise authoritatively interpreted by the courts”). The Commission has, moreover, issued such interpretive statements in the past. Michigan Civil Rights Commission, Interpretive Statement 2012-1. And it blinkers belief to think that the act of issuing an interpretive statement would lose its status as a “governmental function” because the contents of that statement differ from the “informal” view of an assistant attorney general. Indeed, the assistant attorney general provided no authority in support of that conclusion.

A similar analysis attaches to the members of the Commission. A government official is immune from tort liability so long as that official “reasonably believes he or she is acting within the scope of his or her authority.” MCL 691.1407(2). Members of the Commission quite plainly act “within the scope of [their] authority” when they issue interpretive statements that are expressly permitted by law. There is, again, no support for the proposition that Commission members act outside the scope of their authority simply because they happen to disagree with the “informal” view of an assistant attorney general.

* * * A final point. We are aware that the interpretive statement requested by Equality Michigan is a high-profile one. We are also aware that the issuance of an interpretive statement could have a significant practical effect—allowing LGBTQ Michiganders to file complaints, for the first time, alleging discrimination on the basis of sexual orientation or gender identity. But neither of those considerations renders the instant question any less appropriate for an interpretive statement. Indeed, the Michigan Court of Appeals has rejected the notion that an interpretive statement is inappropriate where it “alter[s] the status quo and substantially affect[s] the rights of the general public.” Faircloth, 232 Mich. App. at 403.

We believe, in fact, that the high-profile nature of this matter makes it particularly important for normal administrative processes to be followed. Through its Administrative Procedures Act, Michigan’s legislature has provided neutral procedures for resolving ambiguity in the law. Those procedures should apply with equal force to matters high and low profile; politically charged and mundane; famous and obscure. When special rules are applied in the most prominent, political cases, it undermines both the appearance and actuality of the rule of law. It undercuts Michiganders’ confidence in government. And here, allowing the Commission’s authority to be usurped by a division-level attorney general—one whose unilateral involvement is nowhere contemplated in the law—would leave hundreds of thousands of LGBTQ citizens in the dark about whether Elliott-Larsen actually protects their civil rights.

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For the foregoing reasons, we urge the Commission to vote on Equality Michigan’s request for an interpretive statement at its earliest convenience.

Sincerely,5

Mohammed Abdarabboh Member, Michigan Civil Rights Commission (2003-2007)

Nicholas Bagley Professor of Law University of Michigan Law School

Jocelyn Benson Dean Wayne State University School of Law (2012-2016)

Mark Bernstein Member, Michigan Civil Rights Commission (2004-2012)

Khaled Beydoun Associate Professor of Law University of Detroit Mercy School of Law

Kristina Daugirdas Professor of Law University of Michigan Law School

Kathryn Fort Adjunct Professor Michigan State University College of Law

Richard Friedman Professor of Law University of Michigan Law School

Catherine Grosso Associate Professor of Law Michigan State University College of Law

Peter Hammer Director, Damon J. Keith Center for Civil Rights Wayne State University School of Law

5 Titles and institutional affiliations are provided for identification purposes only. Signatories to this letter do not purport to speak for the institutions with which they are affiliated.

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Margaret Hannon Clinical Assistant Professor of Law University of Michigan Law School

Peter Henning Professor of Law Wayne State University School of Law

Joan W. Howarth Dean Emerita and Professor of Law Michigan State University College of Law

Mae Kuykendall Professor of Law Michigan State University College of Law

Michael Lawrence Professor of Law Michigan State University College of Law

Sammy Mansour Clinical Assistant Professor of Law University of Michigan Law School

Julian Davis Mortenson Professor of Law University of Michigan Law School

Richard Primus Theodore J. St. Antoine Collegiate Professor of Law University of Michigan Law School

Portia Roberson Attorney Detroit, Michigan

Noel Saleh Attorney Ann Arbor, Michigan

Michael Sant'Ambrogio Professor of Law and Assistant Dean for Research Michigan State University College of Law

Eli Savit Adjunct Professor of Law University of Michigan Law School

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Gil Seinfeld Professor of Law and Associate Dean for Academic Programming University of Michigan Law School

Richard Soble Attorney Ann Arbor, Michigan

Khalilah V. Spencer Attorney Honigman, Miller, Schwartz and Cohn

Glen Staszewski Professor of Law & the A.J. Thomas Faculty Scholar Michigan State University College of Law

Mark Totten Associate Professor of Law Michigan State University College of Law

Beth Wilensky Clinical Assistant Professor of Law University of Michigan Law School

Amer Zahr Adjunct Professor of Law University of Detroit Mercy School of Law

Sarah Zearfoss Senior Assistant Dean University of Michigan Law School

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