CEQA—Admirable Goals, Bad Reputation

By: Caroline Lavenue


I.   CEQA—Admirable Goals, Bad Reputation

It is no surprise that the people most calling for CEQA reform are the developers, contractors, and those whose goals are impeded by the complex CEQA process. CEQA, like any law, is in place to dissuade potentially illegal action. It is procedurally complex, demanding time and labor in order to navigate. But is the fact that it is costly or time-intensive a reason for the law to be dropped? Is the fact that potentially fraudulent companies dislike the Sarbanes-Oxley Act because of the added cost of auditors a reason to reduce compliance measures?

CEQA holds developers accountable for their actions which, whether directly or indirectly, affect us all. It has objectively good goals; it was passed in an effort to balance policy considerations. It is a preventative, information-forcing statute that informs decision makers and the public about the potentially significant environmental effects of proposed projects before those projects are approved. For this reason, it is nearly inarguably and substantively good. Ideally, one should be able to refer to CEQA as a consistent guide to environmentally-conscious development because CEQA’s inherent goal of reducing impacts is beneficial.

Procedurally, however, it is problematic. CEQA procedural requirements come from three sources: implementing regulations, case law, and statutes. All three sources have begun to recognize the need for procedural change. Some examples are the ability of the Office of Planning Resources (OPR) to change guidelines because of Court of Appeal decisions, very short statutes of limitations (either 180 or 30 days) to file suit, the lack-of-compliance-requirements for ministerial approval, and–the ultimate white flag–approval despite environmental impacts by adopting a statement of overriding consideration.

II.  Areas for Improvement

While steps have been taken to trim the headache that is CEQA, more can be done. All three procedural sources have areas for improvement.

A.  Too Many Accountability Parties and Varying Exemptions

The CEQA process requires three distinct agencies with different roles: a lead agency, a responsible agency, and a trustee agency. While this serves to enhance accountability, it also creates regulatory burdens, for each agency has different roles and responsibilities.

The Lead Agency is the public agency that has the primary responsibility for carrying out or approving a project.[1] A Responsible Agency is a public agency with some discretionary authority over the project.[2] A Trustee Agency is a State agency having jurisdiction over natural resources for the public trust.[3] The Trustee Agency and the Responsible Agency roles should be collapsed into one. This will diminish confusion—communication between agencies requires time and resources–and reduce barriers to entry for proposing, lead agencies.

An added complication comes in the form of various exemptions. In regard to agencies, there are categorical exemptions prescribed by the Secretary of Resources.[4] Further complicating the matter is that there are exceptions to the exemptions. These categorical exemptions are in addition to statutory exemptions set by the Legislature. These layers of exemptions lead to variability and confusion. For this reason, there should be one list of statutory exemptions without waverability (except in extreme circumstances), and they should all be held to the same procedural requirements. In the case of a necessary exception to an exemption, the Legislature should provide courts with a concrete protocol to decide the matter.

B.  Inconsistent Court Decisions and Two Standards of Review

Courts’ decisions are inconsistent, and there is widespread abuse of CEQA lawsuits for non-environmental purposes.[5] Courts should implement a uniform, high-threshold standard of review that would emphasize the Trustee/Regulatory Agency’s (see above) ultimate substantive authority; thus, the substantial evidence standard. Courts should only use CEQA as a way to achieve the requirements stated in statutes and guidelines. This would substantially diminish variability in the court system.

As a preventative measure, courts should impose strict sanctions on plaintiffs for bringing frivolous NIMBY lawsuits. The positive results of this will be seen as sanctions are implemented.

C.  State-Wide Regulations from the Legislature

The above-mentioned areas for improvement can be solved with increased legislation surrounding CEQA. The Legislature must carve out more exceptions to CEQA to accommodate the categorical exemptions provided by the Agencies (see above).[6] Other suggestions include: different punishment for procedural versus substantive mishap delays; a pro/con net point valuation for projects that would result in a zero-sum game overall; different requirements for entrepreneurs versus giant corporations (based on size and/or anticipated profits); and assumption of property right guarantee before project commencement. There should be tiers of CEQA compliance and exceptions with information about potential environmental degradation being the priority.

III.  Conclusion

CEQA was enacted to protect the environment and ensure that voters are given all necessary information when casting a vote. In this way, the substantive goals and concept are simple; but bureaucracy has made the procedural process exceedingly difficult. There is work that needs to be done, but an efficient CEQA process is within sights if the legislature steps up and creates the necessary changes. All in all, California would rather have than have not, for the goals of CEQA are exceedingly important.



[1] CEQA Guidelines 15367.

[2] CEQA Guidelines 15051.

[3] CEQA Guidelines 15386.

[4] Pub. Res. Code § 21084(a).

[5] Jennifer Hernandez, California Environmental Quality Act Lawsuits and California’s Housing Crisis, Hastings Environmental Law Journal 24 (2017).

[6] CEQA Guidelines 15260-15285.

Cowboy Culture & Sagebrush Rebellions: Who Should Regulate the Wild Wild West?

Cowboy Culture & Sagebrush Rebellions: Who Should Regulate the Wild Wild West?

By: Lauren Marshall

The mythos of the American cowboy, homesteading, tending to the land, and early mornings running cattle, isn’t quite as bygone as the lawless days of the wild wild west. Though a rare breed in our rapidly urbanizing culture, the American cowboy is alive and well in some small pockets of Bureau of Land Management (“BLM”) lands. Cowboy mythology as a political movement most often plays out in conflicts about grazing rights, conflicts that have now been colloquially referred to as Sagebrush Rebellions.

The pervasiveness of the cowboy mythos, as it pertains to land use regulation, is best understood through the lens of the philosophies that motivate it. Cowboy iconography promotes the idea that ranches are the best stewards of the land, taking good care of and perhaps even improving the quality of public lands.[1] It is the belief that grazing is integral to the economy of the west, and without it the west would be valuable to development and urban sprawl.[2] And perhaps the most romanticized and disillusioned component, the idea that cowboys embody everything that is great about America: hard-work, self-reliance, chivalry, and courage.[3]

None of these mythologies are in and of themselves a threat to public lands. However, the political movements they have inspired have led to violence and criminal activity. The west has now weathered three distinct Sagebrush Rebellions. These movements are motivated by similar philosophies: the belief that private or local control of western lands is preferable to federal control. Some rebels are emboldened by god himself[4] and others the belief that federal regulation of these lands is unconstitutional and contrary to framer intent.[5]

Most actions taken by Sagebrush Rebels have focused on attempts to pass statutes that transfer ownership of federal lands to states and localities.[6] These attempts have been generally unsuccessful.[7] However, these movements have also resulted in dangerous criminal activity that threatens public lands that belong to the nation as a whole. Criminal behavior has included bomb attacks on U.S. Forest Service Employees[8], bulldozing a U.S. Forest Service Road[9], and culminating in an armed standoff between the Bundy family and federal agents, resulting in the death of one activist.[10]

Though perhaps questionable in their motivations and methodologies, these political movements do pose important questions about how we have decided to regulate public lands. Would private parties who live on, care deeply for, and intimately depend on the health of the land do a better job caring for it? Can an “absentee landlord”[11] like the BLM or the U.S. Forest Service appropriately regulate a west he’s never seen or experienced? Perhaps there is a place for cowboys in modern culture.

[1] Ann Brower, John Page, Amanda Kennedy & Paul Martin, The cowboy, the southern man, and the man from the snowy river: the symbolic politics of property in Australia, the United States, and New Zealand, 21 Geo. Int’l Envtl. L. Rev. 455, 466 (2009).

[2] Id.

[3] Id.

[4] Matt Canham, Mormon Cliven Bundy says God showed him path to avoid civil war, The Salt Lake Tribune, Aug. 8, 2014

[5][5] Jaime Fuller, The long fight between the Bundys and the federal government, from 1989 to today, The Washington Post, Jan. 4, 2016.

[6] Johnathan Thompson, The first Sagebrush Rebellion: what sparked it and how it ended, High Country News (Jan. 14, 2016)


[8] Timothy Egan, Court puts down rebellion over control of federal land, New York Times (Mar. 16, 1996)

[9] Id.

[10] Rick Bass, Public lands and the Bundy family’s lost cause, Chicago Tribune (May 12, 2017)

[11] William P. Pendley, The Federal Government Should Follow the Constitution and Sell Its Western Lands, National review, Jan. 19, 2016,

“Ag-Gag” Laws

“Ag-Gag” Laws

By: Kellen Miller

This past September the United States Court of Appeals for the 10th Circuit handed down a decision which has the potential to mark a shift in the trajectory of “ag-gag” laws. The term “ag-gag,” which was made popular in 2011 in an opinion piece by food journalist and former columnist for the New York Times Mark Bittman, originally referred specifically to anti-whistleblowing legislation which suppressed the work of photographers and videographers seeking to expose cruel and inhumane treatment of animals by factory farmers.[1] The American Society for the Prevention of Cruelty to Animals (ASPCA) submits that the animal-agriculture industry has been behind the introduction of “ag-gag” bills in more than half of all state legislatures across the U.S. and that eight states currently have some form of “ag-gag” on the books.[2]

Over time, however, the use of the term “ag-gag” has expanded. While many ag-gag laws make it illegal to enter factory farms for the purpose of collecting data and documenting legal violations, in other states the law is not limited simply to farms. There, the laws criminalize the collection and gathering of any data regarding environmental conditions from public lands, even if one accidentally touches private land on the way to that public land.[3] To ecologists and other life scientists, this data is invaluable. It reduces procedural uncertainty by tracking, monitoring, and evaluating the effectiveness of environmental management choices.[4] It can also pinpoint new environmental problems that require the attention of regulators, creating political or legal pressure for the implementation of new standards.[5]

The latest and perhaps most potent illustration of this conflict emerged recently in Wyoming in case entitled Western Watersheds Project v. Michael. Backed by Wyoming livestock interests, the Wyoming legislature adopted what are now known as Data Censorship Statutes (basically “ag-gag” laws), which, according to Western Watersheds Project, an environmental watchdog organization and lead plaintiff in the case, was done specifically to deter and punish persons who gather such environmental data without express authorization.[6] In reality, these laws–even after certain revisions–became so broad that the practical effect was, for example, to criminalize the behavior of recreationists taking pictures on public lands if they had crossed private lands to get there.[7]

In response, Western Watersheds, Natural Resources Defense Council, the National Press Photographers Association, and others joined together to challenge the constitutionality of the revised Wyoming Data Censorship Statutes, claiming First Amendment violations.[8]

At trial, defendants moved to dismiss on the basis that plaintiffs failed to state a claim that data collection[9] is an activity protected by the First Amendment.[10] The United States District Court for the District of Wyoming agreed, granting defendants’ motion to dismiss and concluding that even the revised versions of the statutes did not implicate protected speech because no constitutional right exists that would allow plaintiffs or other similarly situated parties to trespass upon private property to collect resource data.[11] Put simply, the District Court found that plaintiffs could not be granted free speech protections on public lands if they first illegally trespassed onto private land in order to reach that public land.

On appeal, however, the 10th Circuit reversed and remanded, holding that the revised statutes do apply specifically to the creation of speech because the creation and dissemination of information–here, collecting and circulating resource data–constitutes speech within the meaning of the First Amendment.[12] Jonathan Ratner, the lead attorney for Western Watersheds Project, hailed the ruling as “a victory for citizen science and for conservation groups who enforce environmental protection standards when agencies turn a blind eye, and a resounding defeat for the State of Wyoming’s efforts to shield special interests from public scrutiny, oversight, and accountability.”[13]

While it remains up to the District Court to determine the fate of Wyoming’s Data Censorship Statutes on remand, Western Watershed appears to illustrate that opponents can utilize the constitution–specifically the First Amendment–as a legal basis to fight “ag-gag” legislation in court. In the future, it seems likely that these disputes will be framed in the same free speech versus right to privacy debate typified by Western Watershed. If other courts calculate, as the 10th Circuit did, that plaintiffs’ first amendment rights outweigh defendants’ rights to exclude, it could spell trouble for “ag-gag” backers, possibly opening the door for the stripping away and repeal of “ag-gag” legislation.

The fun, it seems, has only just begun!


[1] Mark Bittman, Who Protects the Animals?, N.Y. Times (Apr. 26, 2011), https://opinionator.blogs.nytimes.com/2011/04/26/who-protects-the-animals/.

[2] What is Ag-Gag Legislation? American Society for the Prevention of Cruelty to Animals, https://www.aspca.org/animal-protection/public-policy/what-ag-gag-legislation#Ag-Gag%20by%20State.

[3] Wyoming Data Censorship Laws Entitled to First Amendment Review, National Press Photographers Association, https://nppa.org/news/wyoming-data-censorship-laws-entitled-review.

[4] Eric Biber, The Challenge of Collecting and Using Environmental Monitoring Data, 18 Ecology and Society, 68 (2013), https://www.ecologyandsociety.org/vol18/iss4/art68/.

[5] Id.

[6] Complaint for Declaratory and Injunctive Relief, W. Watersheds Project v. Michael, 196 F. Supp. 3d 1231 (D. Wyo. 2106) (No. 15-Dv-169).

[7] Erik Molvar, Court Smacks Down Wyoming Efforts to Suppress Science, The Hill (Sept. 9, 2017) http://thehill.com/blogs/pundits-blog/energy-environment/349863-court-smacks-down-wyoming-efforts-to-suppress-science.

[8] Complaint for Declaratory and Injunctive Relief, W. Watersheds Project v. Michael, 196 F. Supp. 3d 1231 (D. Wyo. 2106) (No. 15-Dv-169).

[9] Under the Wyoming statute, the term “collect” means: (1) “to take a sample of material” or “acquire, gather, photograph or otherwise preserve information in any form”; and (2) “recording . . . a legal description or coordinates of the location of the collection.” See Wyoming Statutes Title 6 §§ 6-3-414(e)(i); 40-27-101(h)(i).

[10] W. Watersheds Project v. Michael, 196 F. Supp. 3d 1231 (D. Wyo. 2106).

[11] W. Watersheds Project v. Michael, No. 16-8083 (10th Cir., entered September 7, 2017)

[12] Victoria Prieskop, Tenth Circuit Won’t Give Wyoming’s Ag-Gag Law a Free Pass, Courthouse News Service, https://www.courthousenews.com/tenth-circuit-wont-give-wyomings-ag-gag-law-free-pass/.

[13] Id.

“Clean Meat” Soon to be on the Table

“Clean Meat” Soon to be on the Table

By: Axl Kaminski

Is this the answer for environmentally concerned citizens, not yet ready to give up their carnivorous ways for a more eco-friendly, plant-based diet? The term “clean meat” can mean a variety of products which may be synthesized from pea-protein-derived heme (the non-protein component of hemoglobin) or grown from the cultured cells of live animals.[1] Environmentalist and animal welfare groups are touting clean meat as the next great technological innovation, however, consumer bias for conventional meat will be challenging to overcome.

In the U.S. alone, 10 billion land animals are slaughtered each year,[2] and globally 30% of the earth’s surface is devoted to raising livestock.[3] The size and scale of modern factory farming is a far cry from the rural pastoral family farm, but then again, so is meat grown in a Petri dish. The effects of the factory farming system currently in place are felt globally, but the clean meat movement’s epicenter is local, with most of the research undertaken by Silicon Valley-funded scientists.[4] Cost is key in the clean meat industry. Clean meat endeavors are competing with centuries of technological developments that have contributed to the industrialization and mechanization of the modern factory farm.

The challenges are not only monetary for the clean meat industry; the preferences of the American palate also have to be challenged. The idea of meat grown in a lab is not exactly appetizing to most Americans, and will prove to be one of the biggest obstacles to the industry. A 2014 Pew research study confirmed this sentiment, out of 1,000 people asked if they would eat meat “grown in a lab”, 80% responded no.[5] However, this has not stopped billionaires like Bill Gates and Richard Branson from supporting the industry.[6] Demand for meat is steadily rising alongside the global population, all while the finite amount of land suitable for raising animals declines. With an expected population growth of 9 billion by 2050, meeting the population’s demand for meat will require innovation.[7]

A vegetarian diet requires only 35% as much water and 40% as much energy as that of a meat based diet. The problem is that vegetarians only represent a small fraction of the population. Clean meat could help bridge the gap for the environmentally conscientious carnivore. Future clean meat eaters could tout similar number because much of the waste associated with conventionally produced meat is cause by inefficiencies in the factory farming industry.[8] Clean eating has the potential to make a huge difference in the amount of pollution and waste produced by factory farming operations.

Uma Valeti, Co-founder and CEO of Memphis Meats (a leader in the clean meat market), said in an interview with Modernfarmer.com that his company’s methods of producing animal protein would require less than a tenth of the land and water, and half of the energy needed for conventionally produced meat.[9] Although, the cost of producing clean meat is prohibitively high at this time, Valeti believes that in four-years clean meat production will be cost effective enough to bring the product to market, and that it will eventually be cheaper to produce than conventional meat.

With technology developing so rapidly and the big financiers finally behind clean meat, it won’t be long before meat grown in a lab is on the shelf at your local supermarket. Therefore, it is critical that the clean meat industry provide consumer education to expand awareness and demystify clean meat. This is a product that could truly revolutionize the way we eat and help save our planet—one bite at a time.


[1] James McWilliams, Meat, Without All of the Blood and Guts, Pacific Standard (Nov. 6 2017), https://psmag.com/environment/meat-without-all-of-the-blood-and-guts.

[2] Id.

[3] Olive Heffernan, A Meaty Issue, 544 Nature 18 (2017).

[4] McWilliams, see supra note 1.

[5] Aaron Smith, U.S. views of Technology and the Future, Science in the Next 50 Years, Pew Research Center (April 17 2014), http://www.pewinternet.org/2014/04/17/us-views-of-technology-and-the-future/.

[6] Dave Sjeklocha, Clean Meat? It’s not that simple, Beef Magazine (Oct. 30 2017), http://www.beefmagazine.com/beef-quality/clean-meat-its-not-simple.

[7] Patrick Gerland, et al., World Population Stabilization Unlikely This Century, 346 Science 234 (2014).

[8] Harold Marlow, Diet and the Environment: Does What You Eat Matter, 89 Am. J. Clin. Nutr. 1699 (2009).

[9] Andrew Amelinckx, Would You Eat Chicken Grown in a Lab?, Modern Farmer (Mar. 21 2017), https://modernfarmer.com/2017/03/eat-chicken-grown-lab/.


Climate Change Refugees: Regional Agreements Can Better Fill the Gap in Legal Protection

Climate Change Refugees: Regional Agreements Can Better Fill the Gap in Legal Protection

By: Kelsey Moe

Current estimates suggest that climate change could cause over 200 million people to be displaced by 2050.[1] In a report introduced by the UNHCR, it found that “climate change exposes people to increased vulnerability and creates impetus in driving them into areas of conflict and ultimately across borders into exile.”[2] Climate change displacement is a reality, and it will cause an increased flow of migrants, due to its accelerated affects.[3] The effects of climate change are already contributing to migration and the displacement of people.[4] Climate change effects can be linked to impacts on agriculture, the economy, food shortages, extreme weather events, and access to water.[5] Parts of the world will no longer be habitable, able to support agriculture, or produce clean water, and people will be forced to relocate in order to survive.

This is a major problem primarily because of the lack of legal framework and protection for individuals vulnerable to climate change displacement. The 1951 Refugee Convention, and 1967 Protocol defines a refugee as, “person who is outside his or her country of nationality or habitual residence; has a well-founded fear of persecution because of his or her race, religion, nationality, or membership in a particular social group or political opinion; and is unable or unwilling to avail himself or herself of the protection of that country, or to return there, for fear of persecution.”[6] The 1951 Convention definition does not cover individuals displaced by climate change, which leaves a gap in the legal protection for climate change refugees.[7]

Many solutions have been suggested to address the lack of protection for climate change refugees. One solution is the development of a new international treaty, specifically to address climate refugees. In the Harvard Environmental Law Review, authors Tyler Giannini and Bonnie Docherty propose the idea of a new independent international convention.[8] The authors believe current legal instruments are unable to protect climate change refugees, and that a new international treaty is the only adequate solution.[9] Another argument is the proposal for a regional treaty to protect climate change refugees.[10] The author suggests the development of a regional treaty over a new international treaty, because a new global agreement would be problematic.[11] Williams concludes that efforts could be better coordinated through regional agreements under the international umbrella of the Kyoto Protocol and the UNFCCC.[12]

Current international and domestic laws are unlikely to provide the needed legal protection for climate change refugees. Regional agreements can better fill the gap in legal protection for climate refugees because of similar cultural, geographical, and family ties within regions, adaptation capabilities of countries, and the likelihood of internal and migration to nearby countries.[13] Cultural norms vary widely across countries, regions, and social groups; and regional agreements help countries communicate how they want to be perceived both in terms of climate change and with migration and displacement. International movement in the context of climate change is “conceived of differently because of particular geographical, demographic, cultural, and political circumstances, and it may be that localized or regional responses are better able to respond to their needs.”[14] Ultimately, regional agreements focus attention on culturally-sensitive outcomes for people in particular contexts, and respond to the nature, timing and location of predicted movement within, from, and to particular countries, and their views on how they want to be perceived.[15]

Regional agreements are also better for adaptation because they can take into account commonalties between countries, and their specific capabilities and priorities regionally. Regional agreements can appeal to both host and home countries, because they consider the different aspects of the affected communities, and how and when people should migrate.[16] Certain countries may wish to remain in their home countries as long as possible, while others are concerned with immediate relocation, or gradual migration over time. Countries have different priorities for climate change and displacement. This is the case in Tuvalu and Kiribati.[17] Kiribati is interested in including an international agreement for relocation, while Tuvalu is against it, because of their fear of the power of industrialized nations to force relocation.[18]

For example, the country of Kiribati is concerned with unemployment and sanitation issues.[19] The President of Kiribati is responding to climate change displacement by prioritizing options for labor migration in New Zealand and Australia.[20] Tuvalu is concerned with unemployment as well, but is also dealing with pollution and a lack of resources.[21] When formulating policy on climate change and displacement, different relocation priorities may depend on these issues, and concerns like the right to work, access to public services, and the right to citizenship or territory in host countries. Migration will also depend on unknown factors such as when people are forced to migrate, if migration is an accepted adaptation strategy, and other types of assistance available in particular communities. Regional agreements are better for adaptation because they can take into account these different capabilities and priorities.

Regional agreements are also preferred because of the likelihood of internal migration, and migration to neighboring countries. International treaties may be inappropriate because current evidence shows that most movement from climate change will be internal and gradual.[22] The basis of an international treaty is international movement and regional responses are a better platform for more community specific responses.[23] They are also preferable because of the likelihood of family or friends living in nearby countries within the region. Regional agreements also benefit from proximity, and the likelihood of shared interests regionally, because the majority of migration will be internal or to nearby countries.

Lastly, regional agreements are more effective because of their ability to influence behavior and ensure compliance differently than international systems.[24] Regional agreements benefit from the proximity of nearby countries, and can complement existing international frameworks. They are also preferable for enforcement because they resonate with local conditions better than a global system can.[25] For example, a more judicial approach to enforcement may be appropriate in some regions, while a non-judicial approach like commissions or peer review may be more appropriate in others. In general, regional agreements are a better platform for listening to the concerns of different countries, and formulating solutions based on each country’s priorities.

[1] Oli Brown, Climate change and forced migration: Observations, projections and implications, Human Development Report Office, (2007).

[2] UN High Commissioner for Refugees (UNHCR), Climate Change, Vulnerability and Human Mobility: Perspectives of Refugees from the East and Horn of Africa, (June 2012), www. unhcr.org.

[3] UN High Commissioner for Refugees (UNHCR), Frequently asked questions on climate change and disaster displacement, (Nov. 2016), www.unhcr.org.

[4] UN High Commissioner for Refugees (UNHCR), Summary of Deliberations on Climate Change and Displacement, (Apr. 2011), www.unhcr.org.

[5] Id.

[6] UN General Assembly, Convention Relating to the Status of Refugees, (July 28, 1951), 189 U.N.T.S. 137., www.unhcr.org.

[7] Id.

[8] Tyler Giannini and Bonnie Docherty, Confronting a Rise Tide: A Proposal for a Convention of Climate Change Refugees, 33 Harv. Envtl. L. Rev. 349, (2009).

[9] Id.

[10] Angela Williams, Turning the Tide: Recognizing Climate Change Refugees in International Law, 30, Law Policy (2008).

[11] Id.

[12] Id.

[13] Jane McAdam, Swimming against the Tide: Why a Climate Change Displacement Treaty is Not the Answer, 23 International Journal of Refugee Law No. 1 p. 2–27, (2011).

[14] Jane McAdam, Climate Change, Forced Migration, and International Law, Oxford University Press, (2012).

[15] Jane McAdam, Swimming against the Tide: Why a Climate Change Displacement Treaty is Not the Answer, 23 International Journal of Refugee Law No. 1 p. 2–27, (2011).

[16] McAdam at 4.

[17] Jane McAdam and Maryanne Loughry, We Aren’t Refugees, (June 30, 2009).

[18] We Aren’t Refugees, (June 30, 2009).

[19] We Aren’t Refugees, (June 30, 2009).

[20] Id.

[21] Id.

[22] Jane McAdam, Swimming Against the Tide (2011).

[23] Jane McAdam, Swimming Against the Tide, at 8, (2011).

[24] Christof Heyns, David Padilla, and Leo Zwaak, Schematic Comparison of Regional Human Rights Systems: an update, Sur, Rev. int. direitos human. vol.3 no.4 São Paulo, (June 2006).

[25] Id.

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