Janie Valentine

Federal lawsuits related to public-sector unions: 2022 roundup

Since late 2019, Ballotpedia has tracked close to 200 federal lawsuits related to public-sector unions. Today, we’ll take a look at the state of litigation at the end of 2022 and highlight a selection of cases with recent activity in the district and circuit courts.

Background 

In 2018, the U.S. Supreme Court ruled in Janus v. AFSCME that public-sector unions may not require non-member employees to pay agency fees covering the costs of non-political union activities, overturning precedent established in 1977. Most of the lawsuits we’ve tracked since Janus have asked one or more of the following questions: 

• Whether public-sector unions can be held liable for refunding agency fees paid before Janus; 
• Whether public-sector unions may continue to collect union dues from an employee who leaves the union if there is a pre-existing agreement that membership or dues authorization may only be revoked during a certain window; 
• Whether exclusive bargaining representation laws violate non-union members’ First Amendment rights; 
• Whether mandatory bar association dues should be reconsidered in light of Janus.
  

We’re also tracking lawsuits in which public-sector unions challenge state or federal laws and policies. 

What we’ve seen

The map below shows the cases we’re tracking by the U.S. district court in which they originated. The three districts with the highest number of cases are the Middle District of Pennsylvania (18 cases), the Central District of California (16 cases), and the District of Oregon (15 cases). 

Here’s the breakdown by circuit and case status (pending cases are divided by court level, and cases that have been dismissed, settled, or otherwise resolved are counted together):

Finally, this chart shows the cases we’ve tracked since 2019 by the year each case was originally filed:

Case highlights

Wilson v. Lucas County Department of Job and Family Services

• U.S. District Court for the Northern District of Ohio
  • Filed: Dec. 8, 2022 (Case number: 3:22-cv-02221)

Three employees of the Lucas County, Ohio, Department of Job and Family Services sued their employer and the union representing department employees, AFSCME Council 8. The plaintiffs asked the court to “[i]ssue a declaratory judgment that Defendants violate Plaintiffs’ First Amendment right to free speech and association, as secured against state infringement by the Fourteenth Amendment and 42 U.S.C. § 1983, by seizing union payments from them without their consent and by maintaining [an indemnity clause in the collective bargaining agreement].” Attorneys from The Buckeye Institute and the National Right to Work Legal Defense Foundation represent the plaintiffs. 

Kumpf v. New York State United Teachers 

• U.S. District Court for the Northern District of New York
  • Filed: April 29, 2022 (Case number: 1:22-cv-00402)
  • Judgment: Nov. 22, 2022

Plaintiff Jennifer Kumpf, a second-grade teacher, sued the Buffalo City School District, Buffalo Teachers Federation, and New York State United Teachers, asking the court to declare that “Defendants’ actions in forcing Plaintiff, as a nonmember, to provide past and ongoing financial support to Defendant Unions  … violated and violates the First and Fourteenth Amendments of the United States Constitution,” and that “any taking and/or retention of union dues or fees from Plaintiff after her resignation of membership in Defendant Unions and without proper constitutional notice and waiver violates her rights under the First and Fourteenth Amendments of the United States Constitution.” Attorneys from The Fairness Center represented Kumpf. 

On Nov. 22, 2022, U.S. District Judge Brenda K. Sannes ruled in favor of the defendants, dismissing Kumpf’s lawsuit. Sannes wrote that “[Kumpf’s] argument that Defendants’ failure to obtain a constitutional waiver once she resigned her union membership before they could continue to deduct dues fails to state a plausible claim for relief under the First Amendment” and that “[Kumpf failed] to plausibly allege that Defendant District, in adhering to the signed authorization’s terms deprived [Kumpf] of a protected liberty or property interest in violation of the Fourteenth Amendment.”

Ramon Baro v. Lake County Federation of Teachers Local 504

• U.S. District Court for the Northern District of Illinois
  • Filed: April 3, 2020 (Case number: 1:20-cv-02126)
  • Judgment: March 28, 2022
• U.S. Court of Appeals for the Seventh Circuit
  • Appealed: April 28, 2022 (Case number: 22-1722)
  • Oral argument: Dec. 6, 2022

Plaintiff Ariadna Ramon Baro, an employee of the Waukegan Community Unit School District #60, sued the school district and Lake County Federation of Teachers Local 504, the exclusive representative for district employees. Ramon Baro asked the court to “[d]eclare that her signing of a union card cannot provide a basis for her affirmative consent to waive her First Amendment rights upheld in Janus because such authorization was given without knowing and intelligent waiver of her First Amendment rights” and to “[d]eclare that the Union and the District may not withhold union dues or fees from public workers unless those workers have been informed, and thus have knowledge of their right not to pay dues or fees to a union.” Attorneys from the Liberty Justice Center represent Ramon Baro. 

On March 28, 2022, Judge John F. Kness ruled in favor of the defendants. Kness wrote, “Plaintiff may now regret her earlier decision to join the Union, but that does not render her knowing and voluntary choice nonconsensual. Unlike the proscribed conduct by Janus’ employer, the District’s deductions of dues from Plaintiff’s earnings were made in compliance with Plaintiff’s explicit written instructions. … In the light of Plaintiff’s voluntary agreement to pay union dues, and in the absence of any legitimate claim of compulsion, Plaintiff has failed to state a First Amendment claim against Defendants.” 

Ramon Baro appealed to the Seventh Circuit on April 28, 2022. The oral argument for this case was held on Dec. 6, 2022. Click here for audio. 

What we’re reading

• CalMatters, “A new try for unionization of legislative staff,” Dec.14, 2022
• WRIC, “Richmond Public Schools’ teachers union approves collective bargaining contract,” Dec. 14, 2022
• WMAR, “Maryland Office of the Public Defender officially unionizes,” Dec. 14, 2022
• Government Executive, “FLRA Restores Pre-Trump Doctrine on When It Can Intervene in Ongoing Arbitration,” Dec. 12, 2022
• The Stand, “State Supreme Court rejects Spokane ‘open bargaining’ law,” Dec. 12, 2022) 
• Washington Policy Center, “State Supreme Court overturns voter-approved local collective bargaining transparency requirement,” Dec. 11, 2022 
• Daily Hampshire Gazette, “Right to strike among teachers union priorities,” Dec. 11, 2022

The big picture

Number of relevant bills by state

We are currently tracking 150 pieces of legislation dealing with public-sector employee union policy. On the map below, a darker shade of green indicates a greater number of relevant bills. Click here for a complete list of all the bills we’re tracking. 

Number of relevant bills by current legislative status

Number of relevant bills by partisan status of sponsor(s) 

Recent legislative actions

No public-sector union bills saw activity this week.

Thank you for reading! Let us know what you think! Reply to this email with any feedback or recommendations.

Missouri Court of Appeals upholds trial court ruling ordering state to resume payroll deductions for Department of Corrections employees

On Dec. 6, 2022, a three-judge panel of the Missouri Western District Court of Appeals upheld a September 2021 ruling by Cole County Circuit Court Judge Jon Edward Beetem in which Beetem ordered the Missouri Office of Administration to resume payroll deductions for Department of Corrections employees. The Office of Administration issued rules in 2019 and 2020 suspending and denying, respectively, payroll deductions for the Missouri Corrections Officers Association.

Background

The Missouri Corrections Officers Association (MOCOA) and two corrections officers filed a petition for declaratory judgment and injunctive relief against the Missouri Office of Administration in the Cole County Circuit Court on March 24, 2020. 

According to the St. Louis Post-Dispatch’s Kurt Erickson, “The state said it wouldn’t collect dues because the workers were no longer in a union since the contract had expired. The state also argued it was not recognizing the organization because it allowed about 100 retirees to be members.” 

On Sept. 27, 2021, Judge Jon Edward Beetem ordered the Office of Administration to “[resume] payroll deductions for any current employees who were having MOCOA dues deducted from their pay right before December 9, 2019, pursuant to the authorizations they had signed …” and to “accept new MOCOA dues deduction authorizations signed by employees in the future, and begin and continue deductions for those employees, pursuant to their authorizations.” 

The Office of Administration defendants appealed to the Western District Court of Appeals on Oct. 28, 2021. The Western District is the largest of three court of appeals districts. The court of appeals, Missouri’s intermediate appellate court, hears appeals from the state’s circuit courts. 

The oral argument for this case was held on Nov. 2, 2022. 

About the ruling

Chief Judge Gary D. Witt, Judge Mark D. Pfeiffer, and Judge Thomas N. Chapman affirmed Beetem’s ruling on Dec. 6, 2022. Witt wrote:

“The trial court … [found] that the Emergency Rule and Final Rule (collectively, “Rules”) issued by [the Missouri Office of Administration (“OA”)] were unconstitutional because they infringed on [Missouri Corrections Officers Association, Inc. (“MOCOA”)]’s constitutional rights to organize and to bargain collectively, freedoms of speech and association, and equal protection. The trial court also found that OA’s decisions in December 2019 to suspend payroll deduction and in March 2020 to deny payroll deductions for MOCOA were unlawful, arbitrary, capricious, and unreasonable. … We affirm the judgment of the trial court. …

“The record shows that OA’s interpretation of the regulations and its stated reasons for amending the regulations was a moving target, supporting the trial court’s determination that its rationale was pretextual and its decision to suspend MOCOA’s payroll dues deductions applied the regulation in an arbitrary and capricious manner. …

“The practical result of the Rule is to give OA an unfair advantage in the negotiations by starving the labor union for dues funding during the contract negotiations process. OA has failed to meet its burden of showing that its action was narrowly tailored to further a compelling governmental interest. 

“The Rules allowed employee associations that do not collectively bargain to benefit from payroll deduction, but prohibits employee associations that do collectively bargain from receiving the benefits of payroll deduction. And because the right to organize and to bargain collectively is a fundamental right protected by the Missouri constitution, laws that discriminate on the basis of the exercise of that right are subject to strict scrutiny.”

According to the Missouri Independent’s Rudi Keller, “The union did not seek, nor was it awarded, any tax money to replace the funds lost while dues have not been withheld.” 

A spokesman for the Missouri attorney general’s office said the state was “evaluating the decision and determining next steps.” Cases decided by the Western District Court of Appeals may be appealed to the Missouri Supreme Court. 

Gov. Jay Nixon (D) appointed Witt and Pfeiffer to the court. Gov. Mike Parson (R) appointed Chapman. Court of appeals judges are selected through the Missouri Nonpartisan Selection of Judges Court Plan.

What we’re reading

• Spokane Public Radio, “Washington State Supreme Court overturns Spokane collective bargaining charter amendment,”  Dec. 8, 2022
• The Buckeye Institute, “The Buckeye Institute and National Right to Work File Suit Demanding Union Return Wages Taken from Workers,” Dec. 8, 2022
• RealClearInvestigations, “Illinois Is Pushing Back Against the Anti-Union Tide,” Dec. 8, 2022
• JD Supra, “Unionization of Public-Sector Jobs in Colorado: The Collective Bargaining by County Employees Act,” Dec. 6, 2022
• Government Executive, “Feds Working During Shutdowns Not Entitled to Bonus Pay, Appeals Court Rules,” Dec. 1, 2022

The big picture

Number of relevant bills by state

We are currently tracking 150 pieces of legislation dealing with public-sector employee union policy. On the map below, a darker shade of green indicates a greater number of relevant bills. Click here for a complete list of all the bills we’re tracking. 

Number of relevant bills by current legislative status

Number of relevant bills by partisan status of sponsor(s) 

Recent legislative actions

No public-sector union bills saw activity this week.

Thank you for reading! Let us know what you think! Reply to this email with any feedback or recommendations.

Wisconsin Employment Relations Commission issues decision on collective bargaining for UW Health nurses 

The Wisconsin Employment Relations Commission (WERC) ruled on Nov. 25 that the University of Wisconsin Hospitals and Clinics Authority (UW Health) is not legally required to collectively bargain with UW Nurses United, a chapter of SEIU Healthcare Wisconsin.  

Background

SEIU Healthcare Wisconsin and UW Health filed a joint petition on Sept. 20, 2022, asking the commission for a declaratory ruling on whether Wisconsin Statutes chapter 111, subchapter 1—called the Wisconsin Employment Peace Act—applied to UW Health and its employees.

The Peace Act says, “Employees shall have the right of self-organization and the right to form, join or assist labor organizations, to bargain collectively through representatives of their own choosing, and to engage in lawful, concerted activities for the purpose of collective bargaining or other mutual aid or protection.” 

According to the Wisconsin Examiner’s Erik Gunn, SEIU lawyers “[contended] that UW Health is covered by the Peace Act and as such its employees have full collective bargaining rights,” while UW Health attorneys argued the Peace Act no longer applied to UW Health after former Gov. Scott Walker (R) signed 2011 Wisconsin Act 10 into law. Act 10 limited collective bargaining rights for public sector workers.

The joint petition was part of an agreement between the parties to call off a planned nurses’ strike. To read more about the agreement in an earlier edition of Union Station, click here. 

WERC ruling 

WERC issued its decision on Nov. 25, finding that the Peace Act does not apply to UW Health employees. The commission’s decision said:

“The parties disagree as to whether statutory history is always to be considered when seeking the ‘plain meaning’ of a statute. SEIU asserts that it is only appropriate to look at statutory history if it confirms the ‘plain meaning’ derived from an analysis of the statutory language itself. UWHCA argues that statutory history is always to be considered. The Commission concludes that UWHCA is correct. …

“While the current version of Wis. Stat. § 111.02(7)1 is certainly susceptible to the interpretation given it by SEIU, the statutory history summarized in Findings of Fact 3 – 6 provides clear determinative evidence of the Wisconsin Legislature’s intent. Act 10’s specific deletion of all statutory references related to the UWHCA as a Peace Act ‘employer’ clearly establishes that the UWHCA is not an ‘employer’ within the plain meaning of Wis. Stat. §111.02(7). Contrary to the argument of SEIU, there are no plausible alternative explanations for the legislative deletions reflected in Act 10. 

“Given the foregoing, the Commission declares that the Wisconsin Employment Peace Act, Wis. Stat. ch. 111, subch. 1 (WEPA) does not apply to the University of Wisconsin Hospitals and Clinics Authority and its employees and their chosen representatives, if any.”

The Cap Times’ Jessie Opoien reported that it “remains unresolved … whether UW Health can voluntarily recognize the union.”

What comes next

According to the Milwaukee Journal Sentinel’s Jessica Van Egeren, “Since a ruling by the commission is not the same as a ruling by the courts, neither side ever viewed a decision by WERC as the final answer.” Representatives for both parties have said that they plan to appeal the commission’s decision.

UW Health says it will appeal to the Wisconsin Supreme Court. Press secretary Emily Kumlien said, “WERC’s decision is an important first step toward obtaining definitive answers from the Wisconsin legal system on both the question WERC addressed and whether UW Health could voluntarily recognize a union and bargain collectively. … We believe that an expedited decision on these important legal issues will best allow us to move forward.” 

UW Health nurses Mary Jorgensen, Colin Gillis, and Sarah Langland said, “We will be appealing WERC’s decision through the courts and petitioning for an election with the National Labor Relations Board (NLRB). … This is the first round in a multi-step process for nurses achieving collective bargaining rights, either through the courts, the NLRB, or through voluntary recognition by UW Health.” 

Jorgensen, Gillis and Langland also said, “Hundreds of us have already signed up to become union members and we are meeting directly with the administration to raise critical issues and create real solutions. … The opinion by the Wisconsin Employment Relations Commission (WERC) does not impact our union membership or the Meet and Discuss process at UW Health.”

What we’re reading

• Illinois Policy, “Illinois Labor Board Says Government Unions Cannot Discriminate Against Nonmembers,” Nov. 30, 2022
• Los Angeles Times, “UC postdoctoral scholars and researchers reach tentative deal but strike continues,” Nov. 29, 2022
• The Center Square, “Workers’ rights case appealed to Supreme Court by Washington think tank,” Nov. 28, 2022 
• Jacobin, “Come January, Federal Workers Might Not Have a Functioning Labor Board,” Nov. 28, 2022
• Las Vegas Review-Journal, “Metro officer asks US Supreme Court to hear suit over union fees,” Nov. 28, 2022 
• The Washington Times, “ICE employees say agency canceled their union but still collected dues,” Nov. 28, 2022
• The Washington Post, “Va. public employees begin union contract talks for first time in decades,” Nov. 23, 2022
• Federal News Network, “Federal appeals court latest stop for immigration judges union to get recertified,” Nov. 22, 2022 

The big picture

Number of relevant bills by state

We are currently tracking 150 pieces of legislation dealing with public-sector employee union policy. On the map below, a darker shade of green indicates a greater number of relevant bills. Click here for a complete list of all the bills we’re tracking. 

Number of relevant bills by current legislative status

Number of relevant bills by partisan status of sponsor(s) 

Recent legislative actions

No public-sector union bills saw activity this week.

Thank you for reading! Let us know what you think! Reply to this email with any feedback or recommendations.

Checking in on public-sector union cases appealed to the Supreme Court 

Note: In observance of the Thanksgiving holiday, we will not be publishing Union Station on Nov. 25. The next edition of Union Station will arrive on Dec. 2.

So far this month, the Supreme Court has rejected three petitions in public-sector union cases we’ve been tracking and requested responses in three other cases. We’ll outline the details of both sets of cases below. 

But first, an update on our last edition. Illinois voters approved Amendment 1 on Nov. 8, establishing the right to collective bargaining in the state constitution and making Illinois the first state to ban right-to-work laws in its constitution. The measure passed 58.4% to 41.6%. 

Now, back to the Supreme Court: 

Denied petitions

The Supreme Court receives 7,000 to 8,000 petitions every year. In order for a petition to be granted, at least four of the nine justices must vote to hear the case. Between 2007 and 2021, the court issued opinions in an average of 75 cases per year. 

Since the Supreme Court’s 2018 ruling in Janus v. AFSCME, Ballotpedia has tracked close to 200 public-sector union lawsuits in federal and state courts, over 60 of which have been appealed to the Supreme Court since the 2018-2019 term. Earlier this term, the court agreed to hear a case challenging the Federal Labor Relations Authority’s jurisdiction to regulate a collective bargaining dispute between the Ohio National Guard and the American Federation of Government Employees. Aside from that case, none of the petitions we’ve tracked since Janus have been granted. 

The Supreme Court denied the following petitions in public-sector union cases on Nov. 7 and Nov. 14: 

Cooley v. California Statewide Law Enforcement Association

• Appealed from the Ninth Circuit. 
  • Original complaint: Nov. 13, 2018
  • District court ruling: July 9, 2019 
  • Ninth Circuit ruling: April 28, 2022
  • Ninth Circuit en banc rehearing denied: June 8, 2022
• Appeal docketed Sept. 9, 2022. Respondents waived the right to respond. Distributed for conference on Nov. 4, 2022.
• Question presented in the petition: “Does the Constitution allow a public-sector union to enter into a contract with a state employer that restricts a public employee’s constitutional right to resign his union membership?”
• Petition denied Nov. 7. 

Polk v. Yee (And Quirarte v. United Domestic Workers AFSCME Local 3930, consolidated in the appellate court)

• Appealed from the Ninth Circuit. 
  • Original complaints: Nov. 1, 2018 (Polk); July 11, 2019 (Quirarte)
  • District court rulings: Oct. 14, 2020 (Polk); Feb. 10, 2020 (Quirarte)
  • Ninth Circuit ruling: June 8, 2022
• Appeal docketed Sept. 8, 2022. Respondents waived the right to respond. Distributed for conference on Nov. 4, 2022. 
• Questions presented in the petition: 
  • “Do states and unions need clear and compelling evidence that nonmembers of a union waived their First Amendment right to refrain from subsidizing union speech in order to constitutionally seize payments for union speech from those individuals?” 
  • “When a union acts jointly with a state to seize union payments from nonmembers’ wages, is that union a state actor participating in a state action under 42 U.S.C. § 1983?”
• Petition denied Nov. 7. 

Schaszberger v. AFSCME Council 13

• Appealed from the Third Circuit. 
  • Original complaint: Nov. 7, 2019
  • District court ruling: May 20, 2021
  • Third Circuit ruling: July 20, 2022
• Appeal docketed Oct. 20, 2022. Respondents waived the right to respond. Distributed for conference on Nov. 10, 2022. 
• Question presented in the petition: “Is there a ‘good faith’ defense under 42 U.S.C. § 1983 that shields a defendant from damages liability for depriving citizens of their constitutional rights if the defendant acted under color of a state law before this Court held the law was unconstitutional?” 
• Petition denied Nov. 14. 

Response requested

According to the clerk of the Supreme Court’s office, “The Court will sometimes schedule a case for conference, but then request a response from the respondent(s) before the petition is actually considered at conference. Such a request will be noted on the docket, and will generally give the respondent 30 days to submit the response. Once the response is received, the Clerk’s Office will place the case on the next relevant conference list that is at least 14 days after the date that the last response is filed.”

The court requested responses in the following cases: 

File v. Hickey (formerly File v. Brost)

• Appealed from the Seventh Circuit.
  • Original complaint: July 25, 2019
  • District court ruling: June 29, 2020
  • Seventh Circuit ruling: April 29, 2022
• Appeal docketed Aug. 1, 2022. Distributed for conference on Nov. 4, 2022.
• Question presented in the petition: “Whether membership in a mandatory state bar is subject to heightened scrutiny under the First Amendment.”
  • Amici curiae: Mackinac Center for Public Policy, Alliance Defending Freedom, Goldwater Institute, Americans for Prosperity Foundation, National Right to Work Legal Defense Foundation, Pelican Institute for Public Policy, First Liberty Institute. 
• Respondents’ brief filed Sept. 29, 2022. Question presented: “Petitioner has chosen to limit the question presented to the applicable standard of review, rather than the ultimate question of whether a mandatory bar is constitutional. The decision below did not break new ground on the standard of review, but merely held that Petitioner’s free speech claim was foreclosed by this Court’s precedent. As a result, the only question presented by the petition is as follows: Whether membership in a mandatory state bar is subject to heightened scrutiny under the First Amendment.” 
• Petitioner’s reply filed Oct. 13, 2022. 
• The court requested a response on Oct. 28 and granted the respondents’ request to extend the deadline to Dec. 28. 

O’Callaghan v. Drake

• Appealed from the Ninth Circuit. 
  • Original complaint: March 27, 2019
  • District court ruling: Sept. 30, 2019
  • Ninth Circuit ruling: April 28, 2022
  • Ninth Circuit panel and en banc rehearings denied: June 6, 2022 
• Appeal docketed Sept. 9, 2022. Respondents waived the right to respond. Distributed for conference on Nov. 4, 2022. 
• Question presented in the petition: “Whether a union can trap a government worker into paying dues for longer than a year under Janus[.]” 
• The court requested a response on Nov. 2 and granted the respondents’ request to extend the deadline to Jan. 3, 2023. 

Savas v. California State Law Enforcement Agency

• Appealed from the Ninth Circuit. 
  • Original complaint: Jan. 6, 2020
  • District court ruling: Sept. 8, 2020 
  • Appellate ruling: April 28, 2022
  • Ninth Circuit en banc rehearing denied: June 8, 2022
• Appeal docketed Sept. 8, 2022. Respondents waived the right to respond. Distributed for conference on Nov. 4, 2022. 
• Questions presented in the petition: 
  • “Does it violate the First Amendment for a state and union to compel objecting employees to remain union members and to subsidize the union and its speech?”
  • “To constitutionally compel objecting employees to remain union members and to subsidize the union and its speech, do states and unions need clear and compelling evidence the objecting employees waived their First Amendment rights?” 
  • Amici curiae: Goldwater Institute, Americans for Fair Treatment, Alaska, et al.
• The court requested a response on Nov. 2 and granted the respondents’ requests to extend the deadline to Jan. 3, 2023. 

What we’re reading

• Chicago Tribune, “‘Fundamental right’ of workers to organize being added to Illinois constitution,” Nov. 15, 2022
• The Washington Post, “Michigan Democrats can reignite their state’s vaunted labor tradition,” Nov. 17, 2022
• The Center Square, “Advocate warns about consequences of repealing Michigan’s Right to Work law,” Nov. 15, 2022 
• Virginia Mercury, “Labor organizers push for stronger collective bargaining in Prince William,” Nov. 16, 2022 
• Americans for Fair Treatment, “SCOTUS should rein in rogue federal labor board in Ohio National Guard case,” Nov. 16, 2022
• The New York Times, “U.C. Workers Strike on All 10 Campuses,” Nov. 15, 2022 

The big picture

Number of relevant bills by state

We are currently tracking 150 pieces of legislation dealing with public-sector employee union policy. On the map below, a darker shade of green indicates a greater number of relevant bills. Click here for a complete list of all the bills we’re tracking. 

Number of relevant bills by current legislative status

Number of relevant bills by partisan status of sponsor(s) 

Recent legislative actions

No public-sector union bills saw activity this week.

Thank you for reading! Let us know what you think! Reply to this email with any feedback or recommendations.