* Staff Writer, Boston College Third World Law Journal (2000–2001).
1 See generally Eleanor Clift & Tom Brazaitis, Madam President: Shattering the Last Glass Ceiling (2000).
2 See id. at 62–84, 143–61.
3 See id. at 19, 141–42, 176–77.
4 See id. at 24–25, 87.
5 See id. at 86–87. The authors note that “party leaders had so little confidence in [Senate candidate Harriett Woods] that she received only token financial help. A woman running for the Senate was such an oddity in 1982 that the mostly male leadership could get away with their cavalier attitude.” Id. at 87.
6 See Clift & Brazaitis, supra note 1, at 108–09; Elizabeth Schwinn, Lobby Laws: Women May Win an Exemption, The Times-Picayune (New Orleans), Oct. 31, 1993, at A10. Clift and Brazaitis explain that the decision by Emily’s List in 1992 to back Ferraro over another female candidate, Elizabeth Holtzman, for the Democratic party’s Senate nomination in New York was a huge boon for Ferraro and a damaging setback for Holtzman. See Clift & Brazaitis, supra note 1, at 108–09.
7 See generally Clift & Brazaitis, supra note 1.
8 See Hans Johnson, Cleaning Up: Missouri, Oregon Consider Campaign Finance Initiatives, In These Times (Chi.), Sept. 4, 2000, at 3 (detailing plans for major campaign finance initiatives in two states that would establish public funding similar to the system already established in Maine); Proposals at a Glance, Roll Call (Washington, D.C.), May 28, 1998 (detailing numerous bills that deal with campaign finance reform). See generally Clift & Brazaitis, supra note 1. Given the fact that campaign finance reform proposals exist on a state and national level, it seems as though a book focusing on elective office and the difficulty of raising money would mention such reform proposals. See generally Clift & Brazaitis, supra note 1.
9 S. 27, 107th Cong. (2001); S. 2941, 106th Cong. (2000); S. 26, 106th Cong. (1999); S. 1816, 106th Cong. (1999); H.R. 4037, 106th Cong. (2000); H.R. 417, 106th Cong. (1999); H.R. 1739, 106th Cong. (1999); H.R. 2866, 106th Cong. (1999); Proposals at a Glance, supra note 8 (detailing numerous bills that deal with campaign finance reform).
10 See S. 27; Stephen Ansolabehere & James M. Snyder, Jr., Soft Money, Hard Money, Strong Parties, 100 Colum. L. Rev. 598, 608 (2000); Richard Briffault, The Political Parties and Campaign Finance Reform, 100 Colum. L. Rev. 620, 652 (2000); Fred Wertheimer & Susan Weiss Manes, Campaign Finance Reform: A Key to Restoring the Health of Our Democracy, 94 Colum. L. Rev. 1126, 1128 (1994). Soft money is money that can be collected by political parties and is not subject to a cap; bundling involves a group soliciting donations on behalf of a candidate and then presenting the money to the candidate in a lump sum. See id. at 1140–41, 1144; Geoffrey M. Wardle, Note, Political Contributions and Conduits after Charles Keating and EMILY’s List: An Incremental Approach to Reforming Federal Campaign Finance, 46 Case W. Res. L. Rev. 531, 573 (1996); Gail Collins, Why the Women Are Fading Away, N.Y. Times, Oct. 25, 1998, 6 (Magazine), at 54; Proposals at a Glance, supra note 8.
11 Mary Lynn F. Jones, A Big Leap Year; Women Candidates Capture Greatest Number of Seats Since 1992, Chi. Trib., Nov. 15, 2000, at 3 [hereinafter Jones, Leap Year]; Mary Leonard, Transfer of Power/The Female Contingent; Women’s Status Grows in Senate, Legislators Hope Influence Expands with Larger Presence, Boston Globe, Jan. 19, 2001, at A28. After the 2000 election, there were a total of five female governors, thirteen female senators and sixty-one House members, which includes fifty-nine voting members, and two non-voting delegates from the District of Columbia and the U.S. Virgin Islands. Jones, Leap Year, supra, at 3; Leonard, supra, at A28; Ctr. for Am. Women & Politics, Eagleton Inst. of Politics, Rutgers, The State Univ. of N.J., Election 2000: Summary of Results for Women, at http://www.rci.rutgers.edu/~cawp/facts/Summary2000.html [hereinafter cited as Election 2000]. Although there were five female governors after the 2000 election, that number did not last long: Governor Christine Todd Whitman (R) of New Jersey left her gubernatorial post before her term ended to serve as head of the Environmental Protection Agency in the Bush administration. See David M. Halbfinger, DiFrancesco Sworn in as Acting Governor, N.Y. Times, Feb. 1, 2001, at B5; Glen Johnson, A Divided Panel Backs Ashcroft, Key Opponents of Bush Choice Hoping for 40 Votes Tomorrow, Boston Globe, Jan. 31, 2001, at A1; Election 2000, supra. With Whitman’s departure, Senate President Donald T. DiFrancesco (R) became the next governor of New Jersey, reducing the female gubernatorial total to four. See Halbfinger, supra, at B5. However, the number will return to five should Massachusetts Governor Paul Cellucci (R) be confirmed as the U.S. ambassador to Canada, a post he was nominated for in February. See Frank Phillips & Anne E. Kornblut, The Cellucci Nomination; Cellucci Set to ‘Serve the Country’ Says He’ll Leave Massachusetts in Good Hands, Boston Globe, Feb. 14, 2001, at A1. Cellucci, whose confirmation as ambassador, and thus resignation as governor, should come by the end of April, will be succeeded by Lieutenant Governor Jane M. Swift (R), the first female governor to serve in Massachusetts. See id. The numbers following the 2000 election represent an increase of two female governors, three female congresswomen and four senators over the number of women in office before the 2000 election. See Jones, Leap Year, supra, at 3; Leonard, supra, at A28. Clift and Brazaitis correctly note that in 2000 there were three female governors and nine women in the Senate. Clift & Brazaitis, supra note 1, at 17–18. However, the authors also claim there were “65 women among the 435 members of the House,” a claim that is false. Id. at 18; see Jones, Leap Year, supra, at 3. In 2000, there were 56 voting members out of the 435 members of the House, not 65 as the authors suggest. Clift & Brazaitis, supra note 1, at 18; see Jones, Leap Year, supra, at 3.
12 See Ansolabehere & Snyder, supra note 10, at 608; Briffault, supra note 10, at 652; Wertheimer & Weiss Manes, supra note 10, at 1128; Jones, Leap Year, supra note 11, at 3; Leonard, supra note 11, at A28; Election 2000, supra note 11.
13 2 U.S.C.  431–456 (1997); Wardle, supra note 10, at 536–37.
14 2 U.S.C.  441a(a). An individual cannot contribute more than $1,000 to any candidate or authorized committee of the candidate with respect to any federal election. Id. Individuals can contribute up to $20,000 per year to political committees maintained by the national party. Id. Individuals can also contribute up to $5,000 a year to any other political committees, with a total contribution limit for individuals of $25,000 per year. Id. Multicandidate political committees shall not make contributions to any candidate or to their committee in any federal election that exceeds $5,000, and not more than $15,000 in a calendar year to any political committee maintained by a national party. Id. The term “multicandidate political committee” means “a political committee which has been registered under section 303 [U.S.C.S.  433] for a period of not less than 6 months, which has received contributions from more than 50 persons, and, except for any State political party organization, has made contributions to 5 or more candidates for Federal office.” Id.  441a(a)(4). The term “election” with regard to the above statute is defined as:
[A] general, special, primary, or runoff election; a convention or caucus of a political party which has authority to nominate a candidate; a primary election held for the selection of delegates to a national nominating convention of a political party; and a primary election held for the expression of a preference for the nomination of individuals for election to the office of President.
Id. 431(1)(A)(D). This means, for instance, that the contribution limit of $1,000 per person to any given candidate per election allows a donor to give $1,000 in the primary and another $1,000 in the general election and in any special or runoff election that includes that candidate. See id.; 2 U.S.C. 441a(a). Political action committees are multicandidate political committees that do not have ties to the national parties or to a particular candidate. Karen O’Connor & Larry J. Sabato, The Essentials of American Government, Continuity and Change 336 (3d ed. 1998).
15 See Buckley v. Valeo, 424 U.S. 1, 143 (1976). The Act requires each political committee to register with the Federal Election Commission and keep detailed records of contributions and expenditures. 2 U.S.C.  433, 432(c), (d). Each committee and candidate also must file quarterly reports with detailed financial information and personal information of the donors. Id.  434(a), (b). In general, the term “political committee” in the statute refers to:
[A]ny committee, club , association, or other group of persons which receives contributions aggregating in excess of $1,000 during a calendar year or which makes expenditures aggregating in excess of $1,000 during a calendar year; or any separate segregated fund under the provisions of section 316(b) [2 U.S.C.S.  441b(b)]; or any local committee of a political party which receives contributions aggregating in excess of $5,000 during a calendar year, or makes payments exempted from the definition of contribution or expenditure as defined in section 301(8) and (9) aggregating in excess of $5,000 during a calendar year, or makes contributions aggregating in excess of $1,000 during a calendar year or makes expenditures aggregating in excess of $1,000 during a calendar year.
Id.  431(4)(A)–(C).
16 See Buckley, 424 U.S. at 143.
17 Wardle, supra note 10, at 538. The Court, in Buckley, inadvertently “spawned a money chase that requires constant fundraising and continued reliance on wealthy donors.” Kenneth J. Levit, Campaign Finance Reform and the Return of Buckley v. Valeo, 103 Yale L.J. 469, 473 (1993).
18 See Levit, supra note 17, at 473.
19 See 2 U.S.C. 441a(a); O’Connor & Sabato, supra note 14, at 336. The number of PACs grew to 4,079 in 1996, more than six times the number in 1974, just two years before Buckley. O’Connor & Sabato, supra note 14, at 336; Wertheimer & Weiss Manes, supra note 10, at 1131–32. The authors argue that Buckley, combined with the failure of the 1974 reforms to include public financing, left candidates with no choice but to rely on special-interest money. See Wertheimer & Weiss Manes, supra note 10, at 1132; Wardle, supra note 10, at 539.
20 See 2 U.S.C.  441a(a)(2)(A), (8); Wardle, supra note 10, at 535. The statute states:
For purposes of the limitations imposed by this section, all contributions made by a person, either directly or indirectly, on behalf of a particular candidate, including contributions which are in any way earmarked or otherwise directed through an intermediary or conduit to such candidate, shall be treated as contributions from such person to such candidate. The intermediate or conduit shall report the original source and the intended recipient of such contribution to the Commission and to the intended recipient.
2 U.S.C.  441a(a)(8).
21 See id.; FEC Contribution and Expenditure Limitations and Prohibitions, 11 C.F.R.  110.6 (2000); Wardle, supra note 10, at 535.
22 11 C.F.R.  110.6(b)(1).
23 Id.  110.6(c)(1)(i)(iv)(A).
24 Id.  110.6(c)(2)(i)–(ii).
25 Id.  110.6(d)(1)–(2).
26 See 966 F.2d 1471, 1478 (D.C. Cir. 1992); Wardle, supra note 10, at 541–42.
27 Nat’l Republican Senatorial Comm., 966 F.2d at 1473.
28 Id.
29 See id. at 1478.
30 Wardle, supra note 10, at 558.
31 See Ian Ayres & Jeremy Bulow, The Donation Booth: Mandating Donor Anonymity to Disrupt the Market for Political Influence, 50 Stan. L. Rev. 837, 869 (1998). The authors’ proposal for mandated donor anonymity would “effectively outlaw bundling” by keeping PACs from getting the credit for soliciting the donations. See id. at 869–70; Wertheimer & Weiss Manes, supra note 10, at 1128; Wardle, supra note 10, at 573; Proposals at a Glance, supra note 8. The article gives an overview of various campaign finance-related bills in the 105th Congress, listing Representative Sam Farr’s (D-Cal.) measure which would ban bundling, among other things. Proposals at a Glance, supra note 8.
32 Ansolabehere & Snyder, supra note 10, at 598; Wertheimer & Weiss Manes, supra note 10, at 1128.
33 Ansolabehere & Snyder, supra note 10, at 598. Because the 1979 amendments excluded state and local party-building expenditures from contribution limits, contributors can give unlimited amounts of money to the national parties’ state and local party-building accounts, dubbed “non-federal” accounts. Id.
34 Id.
35 See id. at 601. The authors explain that soft money opponents believe that because the donations are so large, they may influence policy by putting pressure on congressmen, senators and the president of a particular party to adhere to the wishes of a large donor. See id.
36 See Alison Mitchell, Bush and McCain Meet on Campaign Finance, N.Y. Times, Jan. 25, 2001, at A20. The 2000 election found the parties raising the highest amounts of soft money ever, with the Democrats’ party committees taking in $243.1 million and the Republicans collecting $244.4 million, for a total of $487.5 million. Id. In 1996, the two national political parties raised $263 million, nearly three times as much as was raised in 1992. Steve Campbell, Campaign System Riddled with Loopholes; They Render Existing Finance Restrictions Virtually Meaningless, The Portland Press Herald (Me.), Sept. 16, 1997, at 1A.
37 See Briffault, supra note 10, at 632–33.
38 Id. at 631–32. The author notes that an FEC Advisory Opinion in 1995 that allowed the Republican National Committee to criticize President Clinton by name while discussing issues led to the widespread use of such “issue” advertising in the 1996 election. Id. at 632. The Advisory Opinion also stipulated that issue advocacy ads cannot be paid for exclusively through soft money; only a specified portion of the cost can be funded through soft money, a ruling that is being challenged in the courts by both parties, but has not yet been resolved. Id. at 633.
39 Id.
40 See S. 27, 107th Cong. (2001); S. 1816, 106th Cong. (1999); S. 26, 106th Cong. (1999); H.R. 417, 106th Cong. (1999); Briffault, supra note 10, at 633; Wertheimer & Weiss Manes, supra note 10, at 1128.
41 See Briffault, supra note 10, at 652 (stating that limits on party spending for a candidate might as well not exist because they can easily be circumvented).
42 See id. at 653.
43 See id. at 659; Wertheimer & Weiss Manes, supra note 10, at 1128; Proposals at a Glance, supra note 8. Soft money has long been on the legislative agenda: In the 105th Congress, Representatives Christopher Shays (R-Conn.) and Martin T. Meehan (D-Mass.) proposed a bill to prohibit national parties from raising and spending soft money among other things (the House counterpart to the McCain-Feingold bill in the Senate); Representative Charlie Bass’ (R-N.H.) bill would ban national parties from raising soft money; Representative Sam Farr’s (D-Cal.) bill would ban soft money; Representatives Asa Hutchinson (R-Ark.) and Tom Allen’s (D-Me.) bill would prohibit national parties from raising and spending soft money; former Representative Vince Snowbarger’s (R-Kan.) bill would prohibit any soft-money donations from unions and corporations to political party committees; and Rep. John F. Tierney’s (D-Mass.) bill would ban soft money. See Proposals at a Glance, supra note 8.
44 See S. 27.
45 Id. at Title I,  101. If passed, the proposed legislation would amend FECA to include:
(1) IN GENERAL—A national committee of a political party (including a national congressional campaign committee of a political party) may not solicit, receive, or direct to another person a contribution, donation, or transfer of funds or any other thing of value, or spend any funds, that are not subject to the limitations, prohibitions, and reporting requirements of this Act.
Id.
46 See Larry Bivins, Thompson Pushes Bill Banning ‘Soft Money’; Bipartisan Support Could Expedite Vote on Reform, The Tennessean (Nashville), Jan. 23, 2001, at 6A. With the additional support of senators like Republican Thad Cochran of Mississippi, a previous opponent of the bill, the legislation has a better chance of passage in 2001. See id. In addition, Republican Senator Fred Thompson (Tenn.) recently stated, “‘We have a better chance than ever before to get something done.’” Id. (quoting Senator Thompson); Mitchell, supra note 36, at A20. Mitchell notes that the House version of the bill has passed in that body two years in a row, but has “repeatedly died in a Senate filibuster.” Mitchell, supra note 36, at A20. It takes sixty votes to break a filibuster; McCain says he now has enough votes to break a possible filibuster this year. Id.
47 See Ansolabehere & Snyder, supra note 10, at 608; Briffault, supra note 10, at 661.
48 See Ansolabehere & Snyder, supra note 10, at 608; Briffault, supra note 10, at 661.
49 See Ansolabehere & Snyder, supra note 10, at 608, 611. Although the authors admit that a large reduction in party money would reduce challenger vote shares by 2.5%, they conclude this would not “change competition in the national elections appreciably” because the typical challenger only receives 35% of the vote. See id. at 611. However, one could argue a 2.5% vote loss could impact some challengers in tight elections. See id. As Clift and Brazaitis point out, challenger candidate Harriett Woods lost by a mere 27,000 votes to incumbent John Danforth in the 1982 Missouri Senate race in which she received inadequate party support; 2.5% certainly would have helped her win the race since she lost by about 1%. See Clift & Brazaitis, supra note 1, at 87.
50 See Briffault, supra note 10, at 660.
51 See id. at 661.
52 See id.
53 See Ansolabehere & Snyder, supra note 10, at 608; Briffault, supra note 10, at 660–61.
54 Jones, Leap Year, supra note 11, at 3; Leonard, supra note 11, at A28; Election 2000, supra note 11. The number of female governors quickly dropped to four following the 2000 election because of the departure of New Jersey Governor Christine Todd Whitman (R) to head the Environmental Protection Agency. See Halbfinger, supra note 11, at B5; Johnson, supra note 11, at A1. However, the number will return to five should Massachusetts Governor Paul Cellucci (R) be confirmed as U.S. ambassador to Canada; he would be succeeded by Lieutenant Governor Jane M. Swift (R). See Phillips & Kornblut, supra note 11, at A1.
55 See Leonard, supra note 11, at A28. The 13 women out of a total of 100 senators and the 59 voting congresswomen out of a total of 435 members is very far from being on par with the U.S. population: fifty percent of the country is comprised of women. See id. The U.S., when compared to governments around the world, ranks fiftieth in women elected to office. Id.
56 See id.
57 See Doug Brown, Women in Politics; Candidates Face Money Problems, L.A. Times, June 27, 1986, at 1 (quoting March Fong Eu).
58 See Clift & Brazaitis, supra note 1, at 141–42; Ansolabehere & Snyder, supra note 10, at 608; Briffault, supra note 10, at 660–61; Jones, Leap Year, supra note 11, at 3; Leonard, supra note 11, at A28.
59 See Pat Swift, Gender Gap Plays a Role in Campaign Funding, The Buffalo News, Mar. 18, 2000, at 7C. The article details the challenges of female candidates in raising money to run for elective office. See id. The author notes that “women’s views of campaign finance reform are colored by their preference for fund raising networks and issue groups. They tend to oppose eliminating soft money contributions.” Id.
60 See Clifford J. Levy, ‘Soft Money’ Ban Called a Problem for Mrs. Clinton, N.Y. Times, Sept. 22, 2000, at A1.
61 See id.; Dean E. Murphy, Candidates Back ‘Soft Money’ Ban in New York Race, N.Y. Times, Sept. 24, 2000, at 1. The deal included a ban on television and radio advertising paid for by political parties with soft money. See id. In addition, both sides agreed to ask independent groups not to advertise on each candidate’s behalf. See id.
62 See Murphy, supra note 61, at 1 (quoting Hillary Clinton).
63 See Levy, supra note 60, at A1; Adam Nagourney, Bush and Gore Vie for an Edge with Narrow Electoral Split; Hillary Clinton Goes to Senate; Big Victory for First Lady in Contest with Lazio, N.Y. Times, Nov. 8 2000, at A1. Despite the setback caused by the soft money ban, the First Lady won the election for Senate in New York on November 7, 2000. See Nagourney, supra, at A1.
64 See generally Clift & Brazaitis, supra note 1. The authors detail the troubles of raising money, especially the trouble Harriett Woods had in her bid to unseat John Danforth in the 1982 Missouri Senate race. See id. at 87. The authors acknowledge that because she lost by only 27,000 votes, more money could have made the difference. Id. The authors also note that women were angry that the Democratic Party did not fully support her candidacy. See id. Since that time the parties have become more active in supporting all candidates, and a ban on soft money would return challengers, women included, to the position Woods was in with little party support. See id.
65 Jennifer A. Moore, Note, Campaign Finance Reform in Kentucky: The Race for Governor, 85 Ky. L.J. 723, 741 (1996–97).
66 See Ayres & Bulow, supra note 31, at 869; Wertheimer & Weiss Manes, supra note 10, at 1128; Wardle supra note 10, at 573; Proposals at a Glance, supra note 8.
67 See Wardle, supra note 10, at 545–46.
68 See id. at 548.
69 See id. at 550–51.
70 See id.
71 See Clift & Brazaitis, supra note 1, at 79.
72 See Jon Friedman, The Founding Mother, N.Y. Times, May 2, 1993,  6 (Magazine), at 50; Schwinn, supra note 6, at A10.
73 See Friedman, supra note 72, at 50.
74 Bundling Makes Emily’s List, Legal Times (Washington, D.C.), Apr. 26, 1993, at 5.
75 See, e.g., Wardle, supra note 10, at 551.
76 See Wertheimer & Weiss Manes, supra note 10, at 1142; Schwinn, supra note 6, at A10.
77 Schwinn, supra note 6, at A10.
78 Wertheimer & Weiss Manes, supra note 10, at 1126, 1142.
79 Ayres & Bulow, supra note 31, at 869.
80 Friedman, supra note 72, at 50; Schwinn, supra note 6, at A10.
81 See Schwinn, supra note 6, at A10. DeLauro said the practice allows individual voices to be heard in Washington. Id. Alexander said, “I don’t call it [bundling] a loophole. Blacks and women are underrepresented in Congress. They hit on a way of networking and now they’re told, ‘You can’t do that.’” Id.
82 Ellen R. Malcolm, Reining Big Givers, N.Y. Times, Mar. 30, 1993, at A23.
83 Id.
84 See Clift & Brazaitis, supra note 1, at 88, 93.
85 Id. at 99. This is the largest increase of Democratic women in the House in a non-presidential election year. Id.
86 Id.
87 See Wardle, supra note 10, at 565; Swift, supra note 59, at 7C.
88 Bundling Makes Emily’s List, supra note 74, at 5. The author notes that it is somewhat understandable that Emily’s List would fight any legislation that would discontinue their ability to bundle donations given that this method of helping candidates is their life blood. Id.
89 See Schwinn, supra note 6, at A10. The author describes the bundling loophole as “a loophole that means big bucks for women candidates and others.” Id.; Collins, supra note 10, at 54; see also Brown, supra note 57, at 1. The author quotes former California Secretary of State March Fong Eu as saying, “‘Male donors don’t see women as politicians. They see women as wives who should be at home and not in politics. They often do this unconsciously, but the bottom line is that they do not deal with female candidates in the same way that they do male candidates.’” Brown, supra note 57, at 1.
90 Jones, Leap Year, supra note 11, at 3.
91 See Wardle, supra note 10, at 565.
92 See Clift & Brazaitis, supra note 1, at 18–19, 91. Since 1969, the number of women in state legislatures has increased fivefold. Id. at 19. Also, when Barbara Mikulski was elected to the Senate from Maryland in 1986 (the first year of Emily’s List), she became only the nineteenth woman to serve in the Senate in the country’s 200-year history. Id. at 91. At the beginning of 2001, there were thirteen women in the Senate. Collins, supra note 10, at 54; Leonard, supra note 11, at A28; see also Mary Lynn F. Jones, Moving Up: ‘Trailblazing’ Panel Looks at Progress, Problems of Women, Chi. Trib., Mar. 22, 2000, at 2 [hereinafter Jones, Moving Up]. “In politics, women have gone from holding congressional offices only by succeeding husbands who had died to winning a record number of seats in their own right . . . .” Id.
93 See Collins, supra note 10, at 54; Jones, Leap Year, supra note 11, at 3; Leonard, supra note 11, at A28. The 2000 election brought a record number of female governors, senators and congresswomen. Jones, Leap Year, supra note 11; Jones, Moving Up, supra note 92, at 2; Jill Lawrence, Women’s Numbers Improved the Most in State Elections, USA Today, Nov. 11, 1998, at 6A; Leonard, supra note 11, at A28; Election 2000, supra note 11. Women won the top five state offices in the 1998 election in Arizona, and in Washington, forty-one percent of the legislature following the 1998 election was comprised of women, a record for any state legislature. Lawrence, supra, at 6A; see also Jones, Leap Year, supra note 11, at 3. The almost nine million dollars in contributions Emily’s List made during the 2000 election is likely to have had a significant impact on a large number of female candidates. See Jones, Leap Year, supra note 11, at 3.
94 Collins, supra note 10, at 54.
95 See generally Clift & Brazaitis, supra note 1.
96 See generally id.
97 See generally id.
98 See sources cited supra note 10.
99 See sources cited supra note 10.
100 Collins, supra note 10, at 54.
101 See sources cited supra note 10. See generally Clift & Brazaitis, supra note 1.