Go On! Human trafficking conference

(Go On! is an occasional item on symposia and other events of interest)

"Which Way Home" -- a reference to the issue of human trafficking -- is the title of the 20th Annual Northern Illinois Law Review symposium to be held will be held April 14 and 15 in DeKalb.
The program will begin with a showing at 7:30 p.m. on April 14 of the Oscar-nominated film of the same name, about which IntLawGrrls posted a while back. The showing will be followed by a question-and-answer session with Sara McDowell, Senior Immigration Attorney for the National Center for Refugee and Immigrant Children, who represented the children in the film.
During the daylong symposium that will follow on April 15, speakers -- including IntLawGrrl Karen E. Bravo and keynote lecturer M. Cherif Bassiouni -- will identify key areas of human trafficking, use of the U.S. court system to combat trafficking, and future policy regarding trafficking. Symposium Editor Emily M. Martin writes:

Although human trafficking is often thought as a distant, international issue, in reality, it is right outside our backdoor. Chicago and Rockford are both human trafficking hubs and Illinois recently passed the strongest anti-trafficking laws in the country.

Details here.

Beyond Libya's Borders

With the news media focused on the estimated 180,000 migrants who have fled Libya in the past 10 days, it's a good moment to think about the impact of the crisis on migrants beyond Libya's borders.
To start, the unrest has cut off a World Food Programme supply chain used to feed tens of thousands of Darfurian refugees and displaced persons in Chad. Food supplies that had for many years been discharged at Benghazi port in Libya have been re-routed to Port Sudan, at great expense and with questionable outcomes, as aid convoys now must traverse Darfur to reach their intended recipients. The consequences for these refugees are sure to be dire.
The instability in Egypt may also obstruct efforts to protect migrants in that country against human rights abuses. Haaretz reports that the number of African migrants entering Israel through Egypt has dropped precipitously in the wake of the crisis. The concern here, given credible and frequent reports of abuse of African migrants by smugglers in the Sinai, is that many Africans are being held for ransom in the desert. Though the Egyptian government's efforts to crack down on organized crime in the Sinai were insufficient at the best of times, the current political situation has likely resulted in even less attention being paid to the situation of these migrants.
On the development side of the ledger, the loss of migrant worker jobs throughout North Africa will have global repercussions. The widely reported repatriation of many foreign workers in Libya will result in the loss of millions of dollars of remittances. Not only current but also future jobs are at stake; the Philippines and Indonesia have suspended the sending of their national workers to Bahrain, Egypt, Libya, and Yemen. Though this decision is to be applauded, it will come at great cost to families in need of remittance funds.
While there's much to celebrate in North Africa, and much assistance needed for migrants escaping the unrest in Libya, the impact of the crisis on migrants and their families will be felt far beyond Libya's borders.

Migration in the age of unemployment

How have migration flows responded to the recession?
The 2010 International Migration Outlook of the Organisation for Economic Co-operation and Development provides a comprehensive statistical assessment of migration developments in member nations in 2008. Unsurprisingly, most forms of migration are down, and unemployment is up, among the foreign-born. But there are some unexpected findings, and some findings of particular interest with respect to female migrants.
► While permanent legal migration and temporary migration fell throughout the OECD in 2008 and 2009, asylum applications are on the rise.
► Family ties continued to play a dominant role in permanent lawful migration to the United States, with 65% of permanent flows based on such ties. French and Swedish immigration policies similarly favored family migration; in contrast, in Italy, Portugal, Spain, and the United Kingdom, labor was the predominant migration rationale.
► The focus of OECD immigration policies continues to be on high-skilled migrants, with very few lawful migration opportunities for the less skilled.
Though one might expect the drop in permanent and temporary migration, the increase in asylum applications is more surprising; one would expect that the recession would make it more difficult for asylum seekers to find the financial means to flee their home country. As it turns out, asylum seekers have been arriving in OECD countries in increasing numbers since 2006, with the United States receiving nearly 40,000 asylum seekers and Canada, France, Italy, and the United Kingdom each receiving over 30,000 asylum seekers in 2008. Afghanistan, Iraq, and Serbia produced the largest numbers of asylum seekers in 2008.
It will be interesting to learn what has happened to student flows and migration-driven population growth in the wake of the recession. The report does not provide these numbers, but found that between 2000 and 2007, international student flows to the OECD doubled, with most studying in Australia, France, Germany, the United Kingdom, and the United States. An average of 21% of students stayed in their host country after completing their degree, remaining through lawful employment status.
The study also reports that migration played a central role in population growth in the OECD between 2003 and 2007, accounting for nearly 60% of population growth. Perhaps most surprisingly, France, New Zealand, and the United States were the only countries for which childbirth was the central cause of population growth. Indeed, in some OECD countries, 90% of population growth was due to migration. If policies to retain migrants are not put in place, these countries may suffer negative population growth in the wake of the recession.
As one would expect, the financial crisis hit immigrants harder: the foreign-born, particularly youth, lost jobs at higher rates than the native-born in nearly all OECD countries. Many countries implemented immigration policies specifically responding to the economic crisis, including provisions for unemployed migrants who couldn't renew their visas, arrangements for their return, and cut-backs in migration quotas.
Perhaps of most interest this readership, in nearly all OECD countries, immigrant women retained their jobs at higher rates than immigrant men. In some cases, immigrant women even increased their rate of participation in the labor market, presumably to account for loss of income from male family members. This of course mirrors the gender impacts of the financial crisis here in the United States; it remains to be seen whether this opportunity for increasing gender equality in the home will translate into real change once the recession has passed.

Mixed Migration in Southern Africa

This month, UNHCR released a report assessing its response to three African mixed migration movements: those from the Horn of Africa (pictured left), the Great Lakes region (pictured below right), and Zimbabwe to South Africa. These flows are "mixed" because they include both refugees and labor migrants, groups that can be nearly indistinguishable both facially and legally. Mixed migration movements raise questions about the adequacy of protection categories created by international refugee law and the need to address the interaction between asylum systems and restrictive labor migration policies.

The first two movements, encompassing migrants from Ethiopia, Somalia, Rwanda, the Democratic Republic of Congo, and Burundi, often pass through Malawi and Mozambique en route to South Africa. The migration management systems in Malawi and Mozambique, both signatories to the UN and OAU refugee conventions, are struggling to cope with the migration flows. Their response has been to accommodate most refugees in camps, an approach that is bound to fail. Many of these refugees have no interest in staying in camps; indeed, some are fleeing refugee camps in Kenya and Tanzania. They have come to Malawi and Mozambique so that they can get to South Africa, where they hope to find work, family, members and possibly transit onwards to North America or Europe. And of course, while all of the migrants arriving in Malawi and Mozambique face significant protection issues during their journeys -- including inadequate access to food, water and shelter; harassment; robbery; extortion; and exploitation -- only some of them are refugees entitled to the protection of UNHCR.
The report is critical of UNHCR and the International Organization for Migration for failing to engage with the "mixed migration issue" in Malawi and Mozambique, but it is difficult to know exactly where UNHCR should draw its boundaries. Should its mandate be extended to cover those who do not fall within the UN Refugee Convention definition? If not, which UN entity should bear responsibility for protecting non-refugee migrants -- the Office for the Coordination of Humanitarian Affairs, the Office of the High Commissioner for Human Rights, or even the UN Development Program or UN-HABITAT? More importantly, does it make sense to distinguish between refugees and other mixed migrants given the "poor governance and harsh economic circumstances" in their countries of origin? These flows are primarily composed of young men, the vast majority of whom are presumably seeking greater economic opportunity as well as greater political freedoms.
These questions are no more easily resolved in the case of Zimbabwean migration flows, which are characterized by increasingly blurred lines between labor migrants and refugees. The report suggests that most Zimbabwean migrants fall somewhere in between, in a category the authors describe as forced or 'survival' migration.
The migration management system in South Africa further contributes to the blurriness. In 2009, South Africa registered over 220,000 new asylum seekers (most from Zimbabwe). Part of the reason for these extremely high numbers is that the easiest and often only way for migrants to stay and work in South Africa is to apply for refugee status. Because the lawful immigration channels for non-refugees are inadequate to address the demand for labor migration, most migrants turn to the asylum system. Unsurprisingly, South Africa's asylum system has become overwhelmed; it suffers from severe backlogs and exceptionally poor quality decisions. (credit for map of South Africa above left).
These are problems faced by immigration systems around the world; as borders become tighter, pressure on asylum processes increases. It is folly to imagine that mixed migration flows can be stopped through higher fences. Those desperate for a better life will find a way around them. We might do better by designing programs that provide safe and legal means for labor migration, recognizing the humanity in the search for greater opportunity, whether economic, political, or both.

Migrant labor treaty campaign

A Brussels-based nonprofit is working to secure ratification of the 1999 International Convention on the Rights of All Migrant Workers and Members of their Families throughout the European Union no later than the 20th anniversary of the treaty's adoption via U.N. General Assembly resolution 45/158. That date, like the name of the organization, is December 18, a date also known as International Migrants Day. (hat tip: Immigration Prof Blog)
The migrant workers treaty, which entered into force in 2003, now has 43 states parties throughout the world. A glance at the list reveals very few countries in the developed world. Hence the efforts of the December 18 group -- including a petition to pressure the EU's 27 members to become states parties.

Coming to America

Given the harsh immigration law enacted in Arizona last week, it seems an appropriate time to reflect on the toll that our border enforcement policy levies on migrants journeying from Central America to the United States. On Wednesday, Amnesty International released a report, Invisible Victims: Migrants on the Move in Mexico, that documents the serious human rights violations suffered by migrants traveling through the states of Chiapas, Oaxaca, Tabasco, and Veracruz en route to the United States. At the margins of society, these Central American migrants are kidnapped, threatened, and assaulted by criminal gangs, other migrants, and corrupt officials, yet these crimes are rarely acknowledged, let alone prosecuted.
It is a challenge to gather reliable data on these abuses, but human rights organizations, academics, and shelters have conducted surveys that suggest that these migrant populations suffer high levels of violence and other wrongdoing, including arbitrary detention, extortion, beatings, robbery, sexual assault, and even murder. Some highlights:

• A report published last year by Mexico's National Human Rights Commission estimated that between September 2008 and February 2009 nearly 10,000 migrants were kidnapped by criminal gangs, often in collusion with the police. The study suggested that the vast majority of these migrants were threatened with guns and knives and received death threats against them and their relatives.
• Women and girl migrants are particular risk of sexual violence. Local and international NGOs and health professionals working with migrant women suggest that as many as six in ten migrant women and girls are raped -- many at the hands of state officials.
• Many migrants are killed or disappear in Mexico. Very few of these deaths are investigated by state law enforcement and attorney generals, and federal and state authorities do not systematically gather data collection on these abuses. As a result, the families of these migrants often do not know the fate of their loved ones who've journeyed northwards.

As the Mexican government plays an increasing role in protecting its nationals in the United States, it's sadly ironic that it fails to uphold its international commitments to protect migrants within its borders. But while the Mexican authorities must make greater efforts to prevent human rights abuses against migrants, the U.S. government also bears responsibility for immigration laws and policies that push migrants to embark on these risky journeys in the first place. A more humane immigration system would enable migrants to travel lawfully and safely to the United States, respecting their dignity as human beings. In the words of a Mexican man who provides shelter and food to migrants in need,

The train carries hundreds of lives, human beings who have suffered. They leave their homes because of the extreme poverty of where they come from, the journey north is a nightmare for them but they do it for the families they have left behind.

'Nuff said

(Taking context-optional note of thought-provoking quotes)

We as a nation should be humbled that the Haitian people, a people who rose above slavery, a people of great resilience and survival, wish to become part of our community. They want only the basics: education, food and shelter. In return they offer their cultural riches – their resilience, their art, their music, their beloved food and their beautiful laughter. The United States government should grant humanitarian parole to the Haitians in need ....

-- My colleague Holly Cooper (above left), Lecturer in the Immigration Law Clinic at the University of California, Davis, School of Law (Martin Luther King, Jr. Hall), in an op-ed in London's Guardian, entitled "How the US can help Haiti: Thousands of Haitians lost everything in the earthquake. The US should open its borders and start granting humanitarian parole." Holly's essay deftly invokes the Greek myth of Persephone in recounting her experiences earlier this month in Haiti, where she was part of "a human rights delegation intent on finding individuals for whom we could request humanitarian parole into the US."

Expulsion repulsion

Causing concern in France these days are cases in which the government's kicked out of the country women who've cried for help.
Among them is Najlae Lhimer (left (credit)), a 19-year-old student who resided in the north-central département of Loiret. As reported in Le Monde, she'd fled her home in Morocco in 2005 in order to escape from forced marriage -- only to end up living with a brother who "mistreated her regularly."
A few weeks ago Lhimer filed an official complaint alleging that she was the victim of domestic violence. Police responded quickly. But not as she'd hoped. Within days, she was sent back to Morocco.
Hers is not a unique case. It's reported that 4 battered women in Loiret have been threatened with expulsion or actually expelled. As a result, legislator Danielle Bousquet (below right (credit)) has urged

'a moratorium on the expulsions of foreign women who are the victims of violence.'

Protests have been ongoing, and more are planned for this weekend in the runup to International Women's Day, which as we've posted, is this Monday, March 8.

Maria's Choice

I've been haunted all week by an immigration horror story. Maria is an undocumented immigrant living in the United States. She has five children, and as a single mother, works hard to support them. Last week, Maria learned that her oldest child, Jose, who is also undocumented, was picked up by Immigration and Customs Enforcement and placed in detention. Jose is eligible for release from detention, but ICE informed Maria's lawyer that they will release him only to the custodial parent, which in this case is only Maria. But if Maria goes in to let her child out of jail, ICE will arrest her and place her in removal proceedings, leaving her other four children without a parent. ICE tells her lawyer that this is their policy, and they've no discretion to act otherwise.
This lack of discretion is key to the overloaded immigration courts and burgeoning immigration detention system. Over the past decade and a half since the 1996 immigration reform act, prosecutorial discretion in immigration cases has been on the wane. As a result, immigration courts have been swamped with cases. And in 2010, for the first time, the detained docket in immigration court will exceed the non-detained docket. In other words, most of the immigrants in removal proceedings will be locked up. It is of course an impossible task to catch, detain, and remove all of the undocumented immigrants in the country, and it makes no sense to jail those who pose no threat to society -- unless you're a state that receives federal funds to do so. But from a humanitarian perspective, the cost to individuals and families is simply too high.
International human rights law, drafted by sovereigns with an interest in controlling their borders, is less protective than one might hope of the rights of undocumented immigrants. As I've blogged before, home states can play an important role in protecting their citizens abroad; moreover, the humanitarian spirit of human rights law can and should animate interpretations of domestic immigration law. In any case, it doesn't take a moral philosopher to understand the problems with our current treatment of the undocumented population within our borders. It's imperative that Congress and the Obama Administration, particularly Secretary of Homeland Security Janet Napolitano, enable the principled and humane exercise of prosecutorial discretion in immigration cases before we become a police state that would make Eichmann proud.

On February 27

On this day in ...
... 1888, Lotte Lehmann (right) was born in Perleberg, a German city near Berlin. In her early 20s she made her opera début, as a page in a Hamburg production of Lohengrin. She would go on to perform as a soprano in many stage productions throughout Europe and in hundreds of recordings, winning renown for her work in Germany opera. (credit for photo from 1930s opera, courtesy of the Lotte Lehmann Foundation) She's credited with discovering, in 1936 in Salzburg, the Trapp Family Singers, who'd become world-famous via The Sound of Music. Two years later, just before Nazi Germany annexed Austria, Lehmann immigrated to the United States, where she continued her career, 1st as an opera singer and eventually an opera teacher. Honored here as an Immigrant of the Day, she became a naturalized U.S. citizen. In 1976 she died at age 88 in Santa Barbara, California, where a concert hall is named in her honor.


(Prior February 27 posts are here, here, and here)

Law & migration & mothers & children

What a treat to have moderated the opening session of Uprooted: The International Migration of Children, the symposium that 2 student journals here at the University of California, Davis, School of Law (Martin Luther King, Jr. Hall) -- our Journal of Juvenile Law and Policy and our Journal of International Law and Policy -- cosponsored on Friday. (prior post)
Titled "The International Context that Pushes Migration," the session provided a rich overview of the causes, conditions, and effects on families of transnational migration trends.
1st up was our colleague Chivy Sok (right), whose career in human rights advocacy includes current service as a member of the Steering Committee of the Ginetta Sagan Fund of Amnesty International USA, as well as prior human rights center leadership at Columbia University and the University of Iowa. Chivy told of her own childhood picking onions for hours in U.S. fields alongside others in her Cambodian refugee family. Chivy then placed her experience in context. More than 200 million children labor worldwide, she said. Three-quarters work in agriculture. Agricultural hazards -- injuries from equipment, harms from pesticides -- constitute a leading cause of death among children. Many of these children have no access to education, to health care, even to basic hygiene. Sok pointed to the Children’s Act for Responsible Employment, legislation that U.S. Rep. Lucille Roybal-Allard (D-Calif.) introduced in Congress last fall, as a potential means to address these problems.
Following Chivy was Jayne E. Fleming (left), Pro Bono Counsel at Reed Smith in San Francisco and the subject of a recent profile in the National Law Journal. (photo credit) Jayne recounted the forces of migration through stories about clients who live and work at a garbage dump in Guatemala. Economic forces of course play a role, she said, adding:

Extreme poverty is absolutely a human rights violation.

Other forces of migration emerged during the session, among them: implementation of the Central American Free Trade Agreement; political violence and armed conflict; family disintegration; sexual exploitation or incest.
Yet another force was at the center of remarks by the session's 3d speaker, Dr. Rhacel Salazar Parreñas (right). Some women migrate not out of sheer desperation, she said, but out of desire to improve their family's economic and social mobility. Professor of American Studies and Sociology at Brown University, Rhacel told what she'd learned her ethnographic research on globalized domestic workers. She focused on how laws break up families, compelling mothers to leave their children behind when go abroad to work. Once there, mothers find themselves infantilized by law -- assigned the legal status not of an employee, but rather of a member of the employer's family. They must depend on employers to treat them well, and they discover, when employers do not, that national labor laws do not protect them. This vulnerable status prevails in countries that pride themselves on human rights records -- Rhacel named Denmark and Sweden in particular -- as well as in those that do not. One reason? A "maternalist ideology" by which "various states are in denial that mothers are leaving the home," and so fail to take measures to protect the migrant domestic workers who care for the home in their stead.

Kudos to these excellent speakers, to journal editors Eve Epstein and Monica Feltz and their staffs, and responsible for putting together this stimulating panel.

(Cross-posted at California-Davis Law Faculty Blog)

Go On! Migrant Children

(Go On! is an occasional item on symposia and other events of interest)

This Friday, February 5, the Journal of Juvenile Law and Policy and the Journal of International Law and Policy at the University of California, Davis, School of Law (Martin Luther King, Jr. Hall) will cohost "Uprooted: The International Migration of Children," a conference exploring the effects of immigration on youth and transnationalism among families. The symposium aims to examine both national and international convoluted legal webs affecting the transnational family. Cosponsoring the event is the California International Law Center at King Hall, for which yours truly serves as director.

Session topics include "The International Context that Pushes Migration," "Global Paths to the United States: The Migration Process," "Status in the United States."

The all-day event is free; details here.

Read On! Black and Green Atlantic

(Read On! ... occasional posts on writing worth reading) It's my great pleasure to announce a new work hot off the presses, available just in time for holiday giving. It's The Black and Green Atlantic: Cross-Currents of the African and Irish Diasporas, published this month by Palgrave Macmillan.

Co-edited by up-and-coming scholar Peter D. O'Neill (my dearest), Ph.D. candidate in Literature at the University of Southern California, and David Lloyd, Professor of English at USC, the book collects truly interdisciplinary explorations of the transoceanic experiences of women and men who migrated from Africa and Ireland. As the publisher puts it:

For centuries, African and Irish people have traversed the Atlantic, as slaves, servants, migrants, exiles, political organizers and cultural workers. Their experiences intersected; their cultures influenced one another. These essays explore the connections that have defined the 'Black and Green Atlantic' in culture, politics, race and labour.

Experts in this discourse will recognize that in undertaking these examinations, the collection builds upon the "extraordinarily influential" book The Black Atlantic: Modernity and Double Consciousness, published in 1992 by Paul Gilroy, since 2005 holder of a chair in social theory at the London School of Economics.

Peter and David each contributed an essay, both of much interest to anyone who studies theories of the state or issues of race and gender: Peter's is entitled "Laundering Gender: Chinese Men and Irish Women in Late Nineteenth-Century San Francisco"; David's, "Black Irish, Irish Whiteness and Atlantic State Formation."

Also of note are the many contributions by women scholars; specifically, "Fenian Fever: Circum-Atlantic Insurgency and the Modern State" by Amy E. Martin; "Green Presbyterians, Black Irish and Some Literary Consequences" by Nini Rodgers; "How Irish Maids are Made: Domestic Servants, Atlantic Culture, and Modernist Aesthetics" by Marjorie Howes; "Freeing the Colonized Tongue: Representations of Linguistic Colonization in Marlene Norbese Philip's and Eavan Boland's Poetry" by Stacy J. Lettman; "Beyond the Pale: Green and Black and Cork" by Lee Margaret Jenkins; "To redeem our colonial character: Slavery and Civilization in R. R. Madden's A Twelvemonths Residence in the West Indies" by Fionnghuala Sweeney; and "Declaring Differently: The Transatlantic Black Political Imagination and Mid-Twentieth Century Internationalisms" by Anne W. Gulick.

Rounding out the collection are: "White Skin, Green Face: House of Pain and the Modern Minstrel Show" by Mark Quigley; "Samuel Beckett and the Black Atlantic" by Jonathan Tadashi Naito; "Transatlantic Fugue: Self and Solidarity in the Black and Green Atlantics" by Michael Malouf; "Martyrs for Contending Causes: David Walker, John Mitchel and the Limits of Liberation" by Anthony R. Hale; "Embodied Perception and Utopian Movements: Connections Across the Atlantic" by Denis O'Hearn; and last but by no means least, "Ventriloquizing Blackness: Eugene ONeill and Irish-American Racial Performance" by Cedric J. Robinson.

Heartfelt congratulations!

On April 14

On this day in ...
... 1939 (70 years ago today), John Steinbeck's novel The Grapes of Wrath was published. Sold at $2.75 a copy, it became both an immediate bestseller and an immediate target for banning and burning. But the timeless Depression-era story of the Joad family, driven from their dust-bowled home in Oklahoma into unwelcoming migrant labor camps in California, outlasted critics. These seem good economic times to (re)read Grapes -- or, for that matter, the excellent nonfiction account of the same phenomenon, Factories in the Field, written by Carey McWilliams the very same year.
... 2009 (today), are celebrated New Year's festivals in Thai and Cambodian cultures. (credit for 2003 photo of Thai New Year festivities in Australia)

(Prior April 14 posts are here and here)

A better way to combat trafficking?

I'd lke to thank Janie Chuang for her excellent post yesterday and follow up by promoting the work of my friend Johanne Vernier (photo at right), currently a doctoral student at the University of Paris I and intern at Echanges et Partenariat in Amsterdam. Johanne's work focuses on the relationship between trafficking, migration and prostitution and the fact that criminal laws in these three areas are at cross purposes and tend to punish the foreign victims of trafficking instead of protecting them from exploitation. According to Johanne, shifting the focus to preventing and punishing exploitation while protecting human dignity would help create a better balance between protected interests and criminal repression. Johanne will be discussing the results of her research at the upcoming 11th Joint Stanford-University of California Law and Colonialism in Africa Symposium, which this year will focus on Trafficking Women and Children after the End of Slavery: Historical and Contemporary Perspectives from Africa and Beyond (at Stanford, March 19-21). Johanne's work is based on models developed by Mireille Delmas-Marty to describe who in society responds to crime and/or social deviance in light of the interests protected and shows, as Janie's post highlights, that with respect to trafficking, states are often focusing on the wrong behavior for the wrong reasons.

Happy birthday to us!

Hard to believe it's been a year since I whined to our intrepid founder Diane Marie Amann about the dearth of international law blogs and got back an email saying, "now you've done it!" What? Done what? and lo! and behold, she had launched IntLawGrrls. Since then, Diane's managed to convince more than 20 outstanding women to join in on this crazy adventure that has definitely been keeping me on my toes keeping up to date with what's going on around the globe. I've not only learned a lot from my co-contributors, I've also come to read the newspaper with an eye toward blogging: today I'd like to draw your attention to a one-woman blog, Migration Information Source (which has been added to our list of links to the right), described here by Ruben Rumbaut, UC Irvine sociologist and authority on the children of immigrants to the US, as "the best online source of information on migration" he's seen "worldwide". Not surprising, perhaps, since no migration topic is too obscure for the blog's editor, Kirin Kalia, who describes herself as, among other things, a "total migration geek". Kudos Kirin, bravo Diane and happy birthday, IntLawGrrls.