Sep 2007
Alumni: "No Confidence" in Monaghan
Mon, Sep17, 2007 - Category: School of
Law
[Update below]
Earlier today, the official representation for Ave Maria School of Law's alumni (The AMSL Alumni Association Board of Directors) voted to renew its April 2006 call for the resignation of Dean Bernard Dobranski. The Board also voted to add a call for AMSL Chairman Tom Monaghan's resignation.
Excerpt:
"We also call on the Board of Governors to immediately remove their Chairman, as we affirmatively express our “No Confidence” in him as well. As Chairman of the Board of Governors, we believe Mr. Thomas Monaghan has failed to exercise his fiduciary duty to Ave Maria School of Law and has instead encouraged use of the Law School to spur further development in and the growth of Ave Maria, Florida. The development of this town is intimately and directly entangled with the well-being of other entities in which Mr. Monaghan has a financial interest. Despite these significant conflicts of interest, he has apparently failed to recuse himself from Board votes that have promoted his interests in the town of Ave Maria, while continuing to be a strong promoter and proponent of these other interests in the midst of decisions that should properly focus on the Law School’s best interests. This conflicted focus has had the effect of destabilizing Ave Maria School of Law, destroying faculty morale, and devastating the reputation of the Law School in circles of academia, which have resulted in an unprecedented number of transfers of our students to other law schools."
Tom Monaghan's for-profit business-related conflicts of interest include his personal ownership of prime Town real estate and corporate ownership/management in key sectors of Town real estate, businesses (i.e. raw materials for road and home construction), Ave Maria Utilities, control over Ave Maria Town's largest employer (as Chancellor and Board Chairman of AMU), and a new local bank. [AW series on conflict of interest]
Click "More.." below for the Alumni Board's full text, or here for the PDF version. (Comments are at Fumare.)
UPDATE, 10/2/07 - The Alumni's 'no confidence' vote was picked-up by a host of media organizations, including the Detroit News and New Oxford Review. Fumare has links to all the stories here.More...
Earlier today, the official representation for Ave Maria School of Law's alumni (The AMSL Alumni Association Board of Directors) voted to renew its April 2006 call for the resignation of Dean Bernard Dobranski. The Board also voted to add a call for AMSL Chairman Tom Monaghan's resignation.
Excerpt:
"We also call on the Board of Governors to immediately remove their Chairman, as we affirmatively express our “No Confidence” in him as well. As Chairman of the Board of Governors, we believe Mr. Thomas Monaghan has failed to exercise his fiduciary duty to Ave Maria School of Law and has instead encouraged use of the Law School to spur further development in and the growth of Ave Maria, Florida. The development of this town is intimately and directly entangled with the well-being of other entities in which Mr. Monaghan has a financial interest. Despite these significant conflicts of interest, he has apparently failed to recuse himself from Board votes that have promoted his interests in the town of Ave Maria, while continuing to be a strong promoter and proponent of these other interests in the midst of decisions that should properly focus on the Law School’s best interests. This conflicted focus has had the effect of destabilizing Ave Maria School of Law, destroying faculty morale, and devastating the reputation of the Law School in circles of academia, which have resulted in an unprecedented number of transfers of our students to other law schools."
Tom Monaghan's for-profit business-related conflicts of interest include his personal ownership of prime Town real estate and corporate ownership/management in key sectors of Town real estate, businesses (i.e. raw materials for road and home construction), Ave Maria Utilities, control over Ave Maria Town's largest employer (as Chancellor and Board Chairman of AMU), and a new local bank. [AW series on conflict of interest]
Click "More.." below for the Alumni Board's full text, or here for the PDF version. (Comments are at Fumare.)
UPDATE, 10/2/07 - The Alumni's 'no confidence' vote was picked-up by a host of media organizations, including the Detroit News and New Oxford Review. Fumare has links to all the stories here.More...
Catholic Legal Scholars Spank AMSL
Wed, Sep12, 2007 - Category: School of
Law
If any shred of respectability is left among the Ave
Maria School of Law administrators and Board, this is
going to hurt. The stellar list of Catholic legal
scholars who run the respected blog "Mirror of
Justice" issued a joint statement this evening on
the issue of AMSL's governance and employee
treatment:
Excerpts:
"The AMSL administration has violated several procedural norms of the secular academy. In this case, we see no tension between those norms and the norms of faith and reason that should guide a Catholic law school. Indeed, what has happened at AMSL appears to us to violate core Catholic norms."
"In suspending the one tenured and two untenured faculty members, AMSL has deprived them of the dignity of their work – their vocation – without adequate process. And, in suspending the tenured faculty member without pay, AMSL has failed to take into account the well-being of that faculty member’s family."
"By the failure to live their Christian commitment, the AMSL Dean and Board cause scandal in the legal, academic, and religious communities. This scandal is exacerbated by the fact that their actions are taken on behalf of a law school named for the Blessed Mother of Christ."
Signatories:
+ Robert John Araujo, S.J., Boston College Jesuit Community
+ Stephen M. Bainbridge, William D. Warren Professor of Law, UCLA School of Law
+ Thomas C. Berg, St. Ives Professor of Law, University of St. Thomas School of Law (Minnesota)
+ Patrick McKinley Brennan, John F. Scarpa Chair in Catholic Legal Studies, Villanova University School of Law
+ Richard W. Garnett, John Cardinal O’Hara, CSC Associate Professor of Law, Notre Dame Law School
+ Elizabeth R. Kirk, Associate Director, Notre Dame Center for Ethics & Culture (formerly a member of the Ave María Law School faculty)
+ Eduardo M. Peñalver, Associate Professor, Cornell University Law School
+ Michael J. Perry, Robert W. Woodruff Professor of Law, Emory University School of Law
+ Mark A. Sargent, Dean and Professor of Law, Villanova University School of Law
+ Michael A. Scaperlanda, Gene and Elaine Edwards Family Chair in Law, University of Oklahoma College of Law
+ Elizabeth R. Schiltz, Associate Professor of Law, University of St. Thomas School of Law (Minnesota)
+ Steven Shiffrin, Charles Frank Reavis, Sr. Professor of Law, Cornell University Law School
+ Gregory Sisk, Orestes A. Brownson Professor of Law, University of St. Thomas School of Law (Minnesota)
+ Susan J. Stabile, Robert and Marion Short Distinguished Chair in Law, University of St. Thomas School of Law (Minnesota)
+ Robert K. Vischer, Associate Professor of Law, University of St. Thomas School of Law (Minnesota)
This is a very important pivotal moment that shows the true unity that uniquely binds both Catholic scholars and the community of academic legal professionals. Let's see if the as-of-yet-silent "Fellowship of Catholic Scholars" shows a fraction of the character and authentic fellowship on display at Mirror of Justice.
How many good people - from students, to employees, to estranged colleagues, to well-respected professionals in the field - how many need to shout "Enough!" before Tom Monaghan puts his pride aside and recognizes that he is destroying the very thing that he claims to be upholding?
Mirror of Justice - full text | Fumare - commentary
UPDATE, 9/13/2007 - Frontpage headlines in today's issue of The Wanderer (subscription required): "At Ave Maria Law School.. Professor 'Terminated' For 'Touching' Secretary". It discusses the railroading of AMSL co-founder and tenured Professor Stephen Safranek [1,2], and quotes heavily from Fumare's comments [1,2].
UPDATE, 9/14/2007 - Media coverage about the Mirror of Justice statement is spreading: Chronicle of Higher Education News Blog, Naples Daily News (syndicated to Bonita News and Marco News), Catholic News Agency, ABA Journal [1,2], Brian Leiter's Law School Reports, Professor Bainbridge, Univ. of Cincinnati's TaxProf, Professor Greg Reynolds' Instapundit, Mark Shea, PrawfsBlawg,
5pm - add Commweal Magazine blog, Blast Furnace Canada blog
Excerpts:
"The AMSL administration has violated several procedural norms of the secular academy. In this case, we see no tension between those norms and the norms of faith and reason that should guide a Catholic law school. Indeed, what has happened at AMSL appears to us to violate core Catholic norms."
"In suspending the one tenured and two untenured faculty members, AMSL has deprived them of the dignity of their work – their vocation – without adequate process. And, in suspending the tenured faculty member without pay, AMSL has failed to take into account the well-being of that faculty member’s family."
"By the failure to live their Christian commitment, the AMSL Dean and Board cause scandal in the legal, academic, and religious communities. This scandal is exacerbated by the fact that their actions are taken on behalf of a law school named for the Blessed Mother of Christ."
Signatories:
+ Robert John Araujo, S.J., Boston College Jesuit Community
+ Stephen M. Bainbridge, William D. Warren Professor of Law, UCLA School of Law
+ Thomas C. Berg, St. Ives Professor of Law, University of St. Thomas School of Law (Minnesota)
+ Patrick McKinley Brennan, John F. Scarpa Chair in Catholic Legal Studies, Villanova University School of Law
+ Richard W. Garnett, John Cardinal O’Hara, CSC Associate Professor of Law, Notre Dame Law School
+ Elizabeth R. Kirk, Associate Director, Notre Dame Center for Ethics & Culture (formerly a member of the Ave María Law School faculty)
+ Eduardo M. Peñalver, Associate Professor, Cornell University Law School
+ Michael J. Perry, Robert W. Woodruff Professor of Law, Emory University School of Law
+ Mark A. Sargent, Dean and Professor of Law, Villanova University School of Law
+ Michael A. Scaperlanda, Gene and Elaine Edwards Family Chair in Law, University of Oklahoma College of Law
+ Elizabeth R. Schiltz, Associate Professor of Law, University of St. Thomas School of Law (Minnesota)
+ Steven Shiffrin, Charles Frank Reavis, Sr. Professor of Law, Cornell University Law School
+ Gregory Sisk, Orestes A. Brownson Professor of Law, University of St. Thomas School of Law (Minnesota)
+ Susan J. Stabile, Robert and Marion Short Distinguished Chair in Law, University of St. Thomas School of Law (Minnesota)
+ Robert K. Vischer, Associate Professor of Law, University of St. Thomas School of Law (Minnesota)
This is a very important pivotal moment that shows the true unity that uniquely binds both Catholic scholars and the community of academic legal professionals. Let's see if the as-of-yet-silent "Fellowship of Catholic Scholars" shows a fraction of the character and authentic fellowship on display at Mirror of Justice.
How many good people - from students, to employees, to estranged colleagues, to well-respected professionals in the field - how many need to shout "Enough!" before Tom Monaghan puts his pride aside and recognizes that he is destroying the very thing that he claims to be upholding?
Mirror of Justice - full text | Fumare - commentary
UPDATE, 9/13/2007 - Frontpage headlines in today's issue of The Wanderer (subscription required): "At Ave Maria Law School.. Professor 'Terminated' For 'Touching' Secretary". It discusses the railroading of AMSL co-founder and tenured Professor Stephen Safranek [1,2], and quotes heavily from Fumare's comments [1,2].
UPDATE, 9/14/2007 - Media coverage about the Mirror of Justice statement is spreading: Chronicle of Higher Education News Blog, Naples Daily News (syndicated to Bonita News and Marco News), Catholic News Agency, ABA Journal [1,2], Brian Leiter's Law School Reports, Professor Bainbridge, Univ. of Cincinnati's TaxProf, Professor Greg Reynolds' Instapundit, Mark Shea, PrawfsBlawg,
5pm - add Commweal Magazine blog, Blast Furnace Canada blog
Woman Kneels Before Monaghan
Wed, Sep12, 2007 - Category: Foundation
| Miscellaneous
The following is, by far, the most commonly heard
"insider" story concerning Tom Monaghan. Ask a past
or present employee from any of the Ave Maria
entities about this story, and he or she will
probably be familiar with it. Multiple current and
former employees have offered AveWatch corroborating
accounts. Yet, to date, it remains unpublished.
Tom Monaghan is a staunch believer and enforcer of dress codes, particularly for women. In large and small meetings, Monaghan has been asked by female employees if they could wear slacks in lieu of the required skirts/dresses on winter days when bitter sub-zero wind-chills whip through Michigan. This was a significant safety concern for women who needed to do regular travel on the snow-covered roads of Michigan as part of their employment responsibilities. Monaghan's response was a consistent "no" to slacks; however, he would "allow" women to wear slacks into and out-of the building if they immediately changed into their dress in the bathroom upon entering the building.
But, requiring a dress or skirt was not enough for Mr. Monaghan. It had to be of a 'proper' length at/below the knees.
Shirley Daum was a married mother who worked at Domino Farms. According to co-workers and friends, she was a solid employee who "always acted professionally" and was "a cheerful and delightful person to be around". As the account goes, in Mr. Monaghan's outer office area, he noticed one day that Daum was wearing a skirt whose length might not have met the knee dress code. In the presence of other employees, Monaghan then proceeded to tell Daum to kneel in front of him so that he could determine whether the skirt touched the floor and was subsequently in compliance with the dress code.
Can you imagine the humiliation of a married woman being told by her boss to kneel in his presence, in front of co-workers? To be clear, AveWatch is not implying that the instruction to kneel was done with sexual intent. But, it doesn't need to be overtly sexual to be humiliating. It should also be remembered that a perpetrator's private "intent" is not necessarily transferable to a participant or observer who may have very different perceptions about the intent.
AveWatch asked Daum's former co-workers if she did anything to provoke such treatment, or if she dressed provocatively? "That depends upon whose definition of 'provocative' you're referring to," said a current employee who wished to remain anonymous. "It seems that anything straying from drab 'Catholic Amish' garb doesn't fit with Mr. Monaghan's taste for women and is thus 'provoking'. He appears to be intimidated by attractive women who dress smart, sharp, or snappy. I would not call her dress provocative by any normal person's definition of the word." Former employees corrobrate this account, telling AveWatch that Daum "always dressed very professionally".
There is a great contradiction between Monaghan's apparent need to exert control over his real-life local female employees and with his willingness to interview for a sexed-up fantasy-making magazine like GQ.. a magazine that he'd likely not tolerate a female employee posing for (or a male employee reading while at Ave Maria). A popular story, told with a chortle, at Ave Maria School of Law is Monaghan's yearly suggestion to students that they spend $10,000 to get their wardrobe started. His focus on clothes adds to the notion that Monaghan is perpetually more concerned with style and perception over substance.
AveWatch readers should ask which of the following begins to rise to the level of harassment and "intimidation" - a pat on the arm with a smile and 'Good morning', or telling a subordinate to kneel in the presence of co-workers?
Tom Monaghan is a staunch believer and enforcer of dress codes, particularly for women. In large and small meetings, Monaghan has been asked by female employees if they could wear slacks in lieu of the required skirts/dresses on winter days when bitter sub-zero wind-chills whip through Michigan. This was a significant safety concern for women who needed to do regular travel on the snow-covered roads of Michigan as part of their employment responsibilities. Monaghan's response was a consistent "no" to slacks; however, he would "allow" women to wear slacks into and out-of the building if they immediately changed into their dress in the bathroom upon entering the building.
But, requiring a dress or skirt was not enough for Mr. Monaghan. It had to be of a 'proper' length at/below the knees.
Shirley Daum was a married mother who worked at Domino Farms. According to co-workers and friends, she was a solid employee who "always acted professionally" and was "a cheerful and delightful person to be around". As the account goes, in Mr. Monaghan's outer office area, he noticed one day that Daum was wearing a skirt whose length might not have met the knee dress code. In the presence of other employees, Monaghan then proceeded to tell Daum to kneel in front of him so that he could determine whether the skirt touched the floor and was subsequently in compliance with the dress code.
Can you imagine the humiliation of a married woman being told by her boss to kneel in his presence, in front of co-workers? To be clear, AveWatch is not implying that the instruction to kneel was done with sexual intent. But, it doesn't need to be overtly sexual to be humiliating. It should also be remembered that a perpetrator's private "intent" is not necessarily transferable to a participant or observer who may have very different perceptions about the intent.
AveWatch asked Daum's former co-workers if she did anything to provoke such treatment, or if she dressed provocatively? "That depends upon whose definition of 'provocative' you're referring to," said a current employee who wished to remain anonymous. "It seems that anything straying from drab 'Catholic Amish' garb doesn't fit with Mr. Monaghan's taste for women and is thus 'provoking'. He appears to be intimidated by attractive women who dress smart, sharp, or snappy. I would not call her dress provocative by any normal person's definition of the word." Former employees corrobrate this account, telling AveWatch that Daum "always dressed very professionally".
There is a great contradiction between Monaghan's apparent need to exert control over his real-life local female employees and with his willingness to interview for a sexed-up fantasy-making magazine like GQ.. a magazine that he'd likely not tolerate a female employee posing for (or a male employee reading while at Ave Maria). A popular story, told with a chortle, at Ave Maria School of Law is Monaghan's yearly suggestion to students that they spend $10,000 to get their wardrobe started. His focus on clothes adds to the notion that Monaghan is perpetually more concerned with style and perception over substance.
AveWatch readers should ask which of the following begins to rise to the level of harassment and "intimidation" - a pat on the arm with a smile and 'Good morning', or telling a subordinate to kneel in the presence of co-workers?
Dobranski Misrepresents ABA?
Tue, Sep11, 2007 - Category: School of
Law
Ave Maria School of Law Dean Bernard Dobranski has
been fishing for headlines the past two weeks. And,
boy, did it backfire.
On August 30, this puff piece was released by Monaghan neocon apologist Brent Bozell [1,2] on his "news" website - "Ave Maria School Weathers Critics, Moves Forward, Says Dean". The (self) interview included softballs like:
Q - "Tom Monaghan earned about $1 billion when he sold Domino's Pizza, and a large chunk of that went into the Ave Maria Foundation. Is it fair to say that the Ave Maria School of Law and all it provides - jobs for faculty and administration, scholarships for students, and a top-notch law education - would not exist were it not for Tom Monaghan?"
A - (Dobranski excerpt) "Oh, absolutely - first of all, it was his idea. It was his vision."
The notion that AMSL was Tom Monaghan's "idea" and "vision" contradicts Dobranski's own version of the founding of AMSL from Fall 2004 (University of Toledo Law Review, 36 U. Tol. L. Rev. 55): "In our first year, among those on the faculty were four of the original five founding faculty who suggested the creation of a new Catholic law school to Mr. Monaghan in 1998" and "Mr. Monaghan's interest in starting a law school at this time had been stimulated by a group of five faculty members from the University of Detroit Law School.."
In the puff piece, Dobranski also attempted to make the point that ABA accreditation standards support the current exclusion of faculty from institutional decision-making processes. He conveniently failed to cite the ABA Standard that says "Except in circumstances demonstrating good cause, a dean should not be appointed or reappointed to a new term over the stated objection of a substantial majority of the faculty." [Recall that the AMSL faculty voted no-confidence in Dobranski's leadership.] The central issue is NOT whether the faculty should have been given a larger say in the Board's decision to move to Florida. The central issue is that one person, Tom Monaghan, used financial coercion to make the Board impotent, requiring that duty to his personal interests be placed above those of institutional interests; as such, the Board was never in an autonomous position to determine the institution's destiny. [see also Fumare]
The Bozell article was only part of the Dean's campaign for headlines. In mid-August, he started creating an air that all is well at AMSL with the exception of a few bitter power-grabbing faculty who simply don't want to move [1,2]. Later, on August 24, Dobranski sent this email to the AMSL community. In Dobranski's typical lawyerly fashion, he used carefully chosen words to paint the image of an ABA that is close to dropping its investigation of the school's sub-standard administration.. an ABA that only remains interested in a small technicality involving "undisclosed" faculty complainers. That email was later supported in public by Dobranski's Bozell article:
Q - "So, the ABA has essentially given you a fairly clean bill of health?"
A - [Dobranski] "Yes, there's one item - and when you throw enough mud, something likely will stick. And what stuck was this one thing about faculty leaving. I'm very confident we'll be able to respond to this one concern. We will have no trouble convincing them that we are able to recruit new faculty - that's not a difficulty. But what's very interesting is that there's nothing about governance, shared responsibility, or academic freedom, which were the thrust of the complaints."
No problemo? On Friday September 7, the Dean released a terse email to the AMSL community "in the interest of clarifying my August 24, 2007 statement regarding the ABA inquiry". Dobranski cut/pasted the verbatim request from the ABA to AMSL for "all relevant information necessary to demonstrate compliance" with an ABA Standard involving faculty.
Why would Ave Maria - an organization that has never felt obligated to inform its constituents of administrative matters - release such a verbatim "clarification" using quotes from the ABA? Did the ABA tell Dobranski to clear-up an air of misrepresentation?
Dobranski really stepped in it; his aforementioned "clarification" was a red flag to journalists (including AW). A lead news article in today's Chronicle of Higher Education reads "Ave Maria School of Law May Face Threat to Accreditation". Yesterday's Wall Street Journal Law Blog reads "More Trouble for Ave Maria School of Law". The story was also picked-up by Michigan Daily and Mirror of Justice.
At minimum, Dobranski's September 7 "clarifying" shows that his statements - and the conclusions that he extrapolates from the statements of others like the ABA - cannot be trusted. Likewise, we should reconsider Dobranski's ability to accurately draw conclusions from statements that he read in the Safranek and Fr. William Thomas incidents.
h/t Fumare
On August 30, this puff piece was released by Monaghan neocon apologist Brent Bozell [1,2] on his "news" website - "Ave Maria School Weathers Critics, Moves Forward, Says Dean". The (self) interview included softballs like:
Q - "Tom Monaghan earned about $1 billion when he sold Domino's Pizza, and a large chunk of that went into the Ave Maria Foundation. Is it fair to say that the Ave Maria School of Law and all it provides - jobs for faculty and administration, scholarships for students, and a top-notch law education - would not exist were it not for Tom Monaghan?"
A - (Dobranski excerpt) "Oh, absolutely - first of all, it was his idea. It was his vision."
The notion that AMSL was Tom Monaghan's "idea" and "vision" contradicts Dobranski's own version of the founding of AMSL from Fall 2004 (University of Toledo Law Review, 36 U. Tol. L. Rev. 55): "In our first year, among those on the faculty were four of the original five founding faculty who suggested the creation of a new Catholic law school to Mr. Monaghan in 1998" and "Mr. Monaghan's interest in starting a law school at this time had been stimulated by a group of five faculty members from the University of Detroit Law School.."
In the puff piece, Dobranski also attempted to make the point that ABA accreditation standards support the current exclusion of faculty from institutional decision-making processes. He conveniently failed to cite the ABA Standard that says "Except in circumstances demonstrating good cause, a dean should not be appointed or reappointed to a new term over the stated objection of a substantial majority of the faculty." [Recall that the AMSL faculty voted no-confidence in Dobranski's leadership.] The central issue is NOT whether the faculty should have been given a larger say in the Board's decision to move to Florida. The central issue is that one person, Tom Monaghan, used financial coercion to make the Board impotent, requiring that duty to his personal interests be placed above those of institutional interests; as such, the Board was never in an autonomous position to determine the institution's destiny. [see also Fumare]
The Bozell article was only part of the Dean's campaign for headlines. In mid-August, he started creating an air that all is well at AMSL with the exception of a few bitter power-grabbing faculty who simply don't want to move [1,2]. Later, on August 24, Dobranski sent this email to the AMSL community. In Dobranski's typical lawyerly fashion, he used carefully chosen words to paint the image of an ABA that is close to dropping its investigation of the school's sub-standard administration.. an ABA that only remains interested in a small technicality involving "undisclosed" faculty complainers. That email was later supported in public by Dobranski's Bozell article:
Q - "So, the ABA has essentially given you a fairly clean bill of health?"
A - [Dobranski] "Yes, there's one item - and when you throw enough mud, something likely will stick. And what stuck was this one thing about faculty leaving. I'm very confident we'll be able to respond to this one concern. We will have no trouble convincing them that we are able to recruit new faculty - that's not a difficulty. But what's very interesting is that there's nothing about governance, shared responsibility, or academic freedom, which were the thrust of the complaints."
No problemo? On Friday September 7, the Dean released a terse email to the AMSL community "in the interest of clarifying my August 24, 2007 statement regarding the ABA inquiry". Dobranski cut/pasted the verbatim request from the ABA to AMSL for "all relevant information necessary to demonstrate compliance" with an ABA Standard involving faculty.
Why would Ave Maria - an organization that has never felt obligated to inform its constituents of administrative matters - release such a verbatim "clarification" using quotes from the ABA? Did the ABA tell Dobranski to clear-up an air of misrepresentation?
Dobranski really stepped in it; his aforementioned "clarification" was a red flag to journalists (including AW). A lead news article in today's Chronicle of Higher Education reads "Ave Maria School of Law May Face Threat to Accreditation". Yesterday's Wall Street Journal Law Blog reads "More Trouble for Ave Maria School of Law". The story was also picked-up by Michigan Daily and Mirror of Justice.
At minimum, Dobranski's September 7 "clarifying" shows that his statements - and the conclusions that he extrapolates from the statements of others like the ABA - cannot be trusted. Likewise, we should reconsider Dobranski's ability to accurately draw conclusions from statements that he read in the Safranek and Fr. William Thomas incidents.
h/t Fumare