112g american bar association criminal justice section report to the house of delegates
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- REPORT Summary
- I. Introduction
- II. Prior ABA Policy
- III. Types of Expungeable Offenses
- IV. Positive Outcomes Associated with Record Expungement
- V. Conclusion
- GENERAL INFORMATION FORM
- EXECUTIVE SUMMARY
112G AMERICAN BAR ASSOCIATION CRIMINAL JUSTICE SECTION REPORT TO THE HOUSE OF DELEGATES
RESOLVED, That the American Bar Association urges federal, state, local, territorial and tribal governments to enact laws allowing for the expungement of: (a) convictions, or (b) other statutory ordinances or violations where a court enters a finding of guilt, for actions performed in public spaces that are associated with homelessness. REPORT Summary This resolution calls for jurisdictions to allow individuals to file expungement petitions to remove from public view records of the violation of nuisance crimes, or life-sustaining crimes associated with homelessness, including convictions for such violations. I. Introduction Laws governing the expungement of criminal records vary from state to state.1 Generally, to expunge a criminal record is a legal process in which the record of an arrest, charge, or in some cases conviction is removed from public view.2 “Public view” means only police records and court records, not news or social media, or in some cases private background check software.3 The expungement of criminal records can be very helpful for individuals being denied employment based on their criminal records.4 The expungement of criminal records can be very helpful for individuals being denied employment based on their criminal records.5 In many cases, expungement of criminal records can also help individuals obtain housing that they did not previously qualify for.6 It is important to note that in many cases, expungement does not apply to guilty adjudications.7 Most states allow for at least some form of record clearing for noncovictions such as arrests, charges, dispositions of nolle prosequi, diversion programs, or acquittals., In the states where a guilty disposition may be expunged, the category of crimes that are allowable to petition for expungement are often “nuisance crimes.”8 Examples of nuisance crimes include: urination in a public place, soliciting or panhandling, consuming alcohol in public, and loitering or vagrancy.9 Many times, these crimes are related to homelessness or extreme poverty.10 When an individual has expunged a record, or removed it from public view, it is as if the arrest (or other criminal justice event) never occurred.11 This allows the individual to respond in the negative when asked if he or she has ever been arrested, which can have a net positive effect on their ability to obtain housing, employment, and education and professional licensure.12 The ABA policies on expungement thus far pertain only to victims of human trafficking13 and juveniles14. This resolution seeks to broaden the ABA’s stance on expungement law, by allowing for the expungement of convictions for life-sustaining activities, or crimes associated with homelessness. II. Prior ABA Policy This resolution is consistent with prior ABA policy on life-sustaining acts.15 Crimes such as panhandling, loitering, or vagrancy are often crimes committed out of necessity. If an individual is experiencing homelessness, they may be forced to sleep on the streets if shelter is not available.16 The ABA has previously called for the decriminalization of laws that punish individuals experiencing homelessness for carrying out otherwise non-criminal “life-sustaining” acts in public spaces such as eating, sleeping or camping17 and called upon lawmakers to revise laws and policies to “recognize the problems faced by the homeless when the demand for shelter, housing and services exceeds the supply.”18 The resolution further urges courts, prosecutors, and other legal actors to consider the problems faced by homeless persons who may be forced to engage in life-sustaining practices in public spaces because they have no alternative private space.19 This resolution would take this policy one step further, providing actual relief for individuals who have been convicted of these crimes of necessity. III. Types of Expungeable Offenses In many states, the only types of crimes that are expungeable are nonconvictions.20 However, some states do allow for expungement of convictions, particularly for non-violent misdemeanors.21 While the public safety concerns surrounding sex offenses and violent felonies may have merit, a blanket rule disallowing expungement of criminal convictions does not take into account the individualized circumstances surrounding certain types of convictions. A permanent public history of crimes associated with homelessness or poverty, including panhandling and public urination do not serve a public safety purpose, and cause more harm to the affected individual than benefit to society.22 Though these crimes are often considered minor criminal violations, they still require the convicted individual to check the box admitting to being convicted of a crime on job applications.23 Though there is much progress on “ban the box” laws nationwide, many employers still have biases, implicit or otherwise, against those convicted of a crime, no matter how minor.24 Further, many employers will disqualify an applicant solely based on being convicted of a crime, without doing further research into the type of offense.25 Further, under the flawed police practices resulting from “Broken Windows Theory,” 26 many jurisdictions adopted policies that increased arrests for nonviolent nuisance crimes as a means of general crime control.27 Broken Windows Theory, termed by criminologists George Kelling and James Wilson in a 1982 issue of The Atlantic, suggests that obvious signs of neglect in a neighborhood signal to both residents and outsiders that the neighborhood is uncared for, and if police address small signs of disorder, then the larger crimes are less likely to occur.28 This approach to crime control was famously embraced by then-New York City mayor Rudy Giuliani after winning election in 1993.29 New Yorkers saw violent crime plummet, supposedly due to this new approach. However, crime was also dropping in other cities that had not adopted this policing style, which called into question the efficacy of this method.30 Whether “broken windows” policing was the cause of the drop in crime or not, what began as a crackdown on subway gate jumpers quickly morphed into discriminatory practices such as “stop and frisk.”31 Policy makers began to realize that cracking down on low level crime often meant racial profiling, and thousands of young black men were being repeatedly stopped on the street without ever having committed a crime.32 In a 2008 analysis of stops, only one-fifteenth of 1 percent of stops for “furtive movements” turned up a gun.33 Kelling and Wilson addressed the potential for this type of abuse in 1982, and Kelling has since spoken out against stop and frisk,34 but regardless of the intention behind the theory, it led to decades of abusive policing, targeting young black men, and leading to consistent contact with the criminal justice system. Thus, many individuals faced police scrutiny for routine activities such as socializing outside of their apartment building.35 Young men of color continue to be the most affected by these flawed policing methods.36 In a study conducted by Berkeley Law’s Policy Advocacy Clinic, researchers found that in California, enforcement of anti-homelessness laws is likely based more on status rather than specific behavior.37 The data shows that while enforcement of “vagrancy” crimes is increasing, arrests for similar crimes such as drunkenness and disorderly conduct are decreasing, illustrating that homeless individuals are being punished for being undesirable to the community, rather than for exhibiting bad behavior.38 Punishing homeless persons for being homeless decreases the affected persons’ ability to gain housing and employment, keeping them in a cycle of poverty.39 Expungement could provide recourse for individuals targeted by these dubiously constitutional40 anti-homeless statutes. Allowing the expungement of convictions for nuisance crimes serves both a compassionate and economical purpose. The social stigma surrounding homelessness and criminal convictions can lead to denial of housing, employment, and potentially other collateral consequences.41 One of the highest predictors of recidivism is lack of employment.42 Having to carry around convictions for arguably crimes of survival unfairly blocks individuals from meaningful employment opportunities.43 Expunging nuisance convictions would lift a huge barrier for individuals trying to get back on their feet after experiencing homelessness or extreme poverty.44 IV. Positive Outcomes Associated with Record Expungement More permissive expungement laws allow people to obtain jobs and housing that can lift them out of poverty.45 Securing meaningful employment has been shown to be one of the most predictive factors of criminal recidivism.46 Having a criminal record, even if an individual was acquitted or if the charges were dismissed, can have a negative effect on employment prospects.47 In many states, records of nonconvictions such as arrests can remain open to public view indefinitely.48 NYU Law Professor James Jacobs refers to this indefinite retention as “the eternal criminal record.”49 This, compounded with already existing racial biases in employment can lead to worse outcomes for individuals of color.50 In a recent study, 22% of white applicants with a criminal history were given a call back interview for a job versus 10% of black applicants with a criminal history.51 For individuals with criminal convictions who have previously served time in prison, the employment prospects are grim.52 It is estimated that the “wage penalty” or the disparity between those who have been imprisoned and those who have not is between 10 to 20 percent.53 More permissive expungement laws can lead to more success and less interaction with the criminal justice system for people of color, impoverished individuals, and people who have experienced or are currently experiencing homelessness.54 Studies conducted on the topic of record clearing suggest that record clearing both increases employment rates and also increases earnings.55 In one particular study, participants who had their record cleared experienced a 5 to 10 percent increase in employment rate after having their records cleared.56 Additionally, these participants also experienced an increase in earnings after having their records cleared.57 In the three years after record clearing, participant earnings increased by roughly $6,000, which equates to roughly one third of the sample’s average earnings of $18,000 annually.58 While more data is needed on the topic of record expungement, these results point towards a net positive impact on employment prospects for individuals who have successfully cleared their criminal records. Expungement can also play a particularly important role for racial minorities by reducing the effects of racially motivated arrests and convictions.59 Expungement laws not allowing for the clearing of convictions for life-sustaining crimes have a disparate impact on minorities who are often victims of racial profiling and targeting by police.60 Additionally, “broken windows” style policing can lead to an increase in arrests for minor crimes, which may lead to longer criminal records.”61 Overly restrictive laws regarding criminal records do not take into account the impact of poverty on criminal justice outcomes.62 Individuals who are poor are more likely to be arrested and convicted of crimes.63 They also likely will not have access to an attorney who can assist them with expungements at the time of their case, which could lead to different decisions on whether to accept plea deals base on the collateral consequences of conviction.64 Further, in many states, individuals charged with misdemeanors are not entitled to representation, which will clearly lead to less optimal outcomes than if the individual was represented by counsel.65 Laws that restrict an individual’s recourse in removing convictions for life-sustaining crimes from their criminal record clearly have a disparate impact on the poor and people of color, which will lead to less meaningful employment and less economic stability in communities of color. In addition to poor employment prospects, individuals with a criminal record experience discrimination in housing.66 This type of discrimination is not limited to simply denying individuals housing who have a criminal record.67 Poor credit histories and a lack of rental history also contribute negatively to housing prospects.68 Expungement of criminal records can lead to better housing outcomes, and thus, more stability and likelihood for economic success.69 Family unification is also a major concern. In many cases, public housing regulations prohibit those with criminal records to live in public housing.70 This causes the breakup of family units, and unfairly penalizes primary caregivers by removing their partners from the household and prevents them from meaningfully sharing household responsibilities.71 Recidivism is expensive. Some researchers estimate the cost of crime in the United States at approximately 300 billion dollars per year.72 This includes costs of policing, courts, and corrections.73 Additionally, the United States employs 2.5 times more correctional officers compared to the rest of the word.74 Allowing for expungement can increase employment and housing prospects and decrease recidivism, and potentially “increase the economic viability of entire communities.”75 Overall, any possible public safety risks associated with allowing individuals to remove convictions for life-sustaining acts from their record is small compared to the safety concerns surrounding recidivism and further incidences of crime.76 Additionally, allowing individuals to remove nuisance crime convictions from their record can help individuals move on from poor economic conditions and contribute meaningfully to the economy. On an economic level, reducing recidivism decreases spending on corrections, and increases people entering the workforce which stimulates economic growth.77 The societal and economic benefits to a more permissive expungement law are numerous, and on a human level, securing meaningful employment leads to lower incidences of drug and alcohol abuse78, lower levels of depression79, and more healthy family relationships80. The benefits of permissive expungement laws are numerous, and will lead to better outcomes for individuals, families and communities. V. Conclusion This resolution calls for jurisdictions to allow individuals to petition for expungment of records of convictions for life-sustaining activities. Allowing individuals to remove convictions for these non-violent crimes of necessity will give them the hand up they need to lift themselves out of poverty. Because recidivism is expensive, both to the individuals paying court costs, and to society as a whole, policies that make it possible for individuals with prior criminal convictions to obtain employment serve both a compassionate and a fiscally responsible purpose. Respectfully submitted, Matt Redle Chair, Criminal Justice Section August, 2017 GENERAL INFORMATION FORM Submitting Entity: Criminal Justice Section Submitted by: Matt Redle, Chair
This resolution calls on jurisdictions to allow for the expungement of convictions for so-called “nuisance crimes” or life staining crimes including, but not limited to, public urination, loitering, and vagrancy.
No.
Comports with all relevant ABA policy on expungement and record sealing including: Resolution 104H (February 11, 2013) http://www.americanbar.org/content/dam/aba/administrative/domestic_violence1/Resources/Trafficking%20Policies/2013_MY_104H.authcheckdam.pdf Resolution 103A (August 2015) http://www.americanbar.org/content/dam/aba/images/abanews/2015annualresolutions/103a.pdf Resolution 106 (Midyear 2007) http://www.americanbar.org/content/dam/aba/publications/criminaljustice/2017/cj_policies_list.authcheckdam.pdf
N/A.
N/A.
Policy will be used for lobbying efforts in conjunction with Governmental Affairs Office, filing of amicus briefs, for CJS’s State Policy Implementation Project, and other relevant projects. Policy will also be used for CLE and member event purposes.
N/A.
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Legal Aid & Indigent Defense Commission on Disability Rights Special Committee on Hispanic Legal Rights & Responsibilities Commission on Homelessness and Poverty Center for Human Rights Commission on Immigration Racial & Ethnic Diversity Racial & Ethnic Justice Youth at Risk Young Lawyer’s Division Civil Rights and Social Justice Government and Public Sector Lawyers International Law National Conference of Federal Trial Judges National Conference of State Trial Judges Law Practice Division Science & Technology Health Law Litigation GP/Solo Children and the Law
Stephen Saltzburg 2000 H Street, NW Washington, D. C. 20052 T: 202-994-7089 E: ssaltz@law.gwu.edu Neal Sonnett 2 South Biscayne Blvd., Suite 2600 Miami, Florida 33131-1819T: 305-358-2000 Cell: 305-333-5444 E: nrslaw@sonnett.com EXECUTIVE SUMMARY 1. Summary of the Resolution This resolution also calls on jurisdictions to allow for the expungement of convictions for so-called “nuisance crimes” or life staining crimes such as public urination, loitering, and vagrancy. 2. Summary of the Issue that the Resolution Addresses Expungement generally refers to removing criminal records from public view by petitioning the court. Expungement generally only refers to charges, not convictions. This resolution addresses expungement of convictions only for non-violent life sustaining crimes (sometimes referred to as nuisance crimes) including public urination, loitering and vagrancy. 3. Please Explain How the Proposed Policy Position Will Address the Issue The proposed policy will allow individuals convicted of life sustaining crimes such as public urination, loitering, and vagrancy to expunge convictions or violations for those offenses. 4. Summary of Minority Views or Opposition Internal and/or External to the ABA Which Have Been Identified. None. 1 Anna Kessler, Excavating Expungement Law: A Comprehensive Approach, 87 Temp. L. Rev. 403 (2015) 2 Kele Onyejekwe, Erasing the Past: How to Expunge a Client’s Criminal Record, TYL, http://www.americanbar.org/publications/tyl/topics/client-development/erasing-past-how-expunge-clients-criminal-record.html 3 What is Expungement? Insights on Law and Society, American Bar Association, http://www.americanbar.org/publications/insights_on_law_andsociety/16/winter2016/expungement.html 4 Kele Onyejekwe, Expunging Criminal Records Promotes Justice, ABA Section of Litigation, (February 24, 2016), http://apps.americanbar.org/litigation/committees/criminal/articles/winter2016-0216-expunging-criminal-records-promotes-justice.html 5P Kele Onyejekwe, Expunging Criminal Records Promotes Justice, ABA Section of Litigation, (February 24, 2016), http://apps.americanbar.org/litigation/committees/criminal/articles/winter2016-0216-expunging-criminal-records-promotes-justice.html 6 http://www.abacollateralconsequences.org/ 7 Anna Kessler, Excavating Expungement Law: A Comprehensive Approach, 87 Temp. L. Rev. 403 (2015) 8 See Md. Code Ann., Crim. Proc. §10-105(a)(9)(i)-(ix) (West 2016) (listing the nuisance offense convictions eligible for expungement). 9 Id. 10 No Safe Place The Criminalization of Homelessness in U.S. Cities, National Law Center on Homelessness & Poverty, https://www.nlchp.org/documents/No_Safe_Place 11 See Conn. Gen. Stat. §§ 54- 142a; 31-51i(d) for an example of a statute allowing individuals to deny arrest under oath if they have had the record expunged. 12 Id. See also Colo. Rev. Stat. § 24-72-703(4)(d) 13 See resolution 104H (February 11, 2013) http://www.americanbar.org/content/dam/aba/administrative/domestic_violence1/Resources/Trafficking%20Policies/2013_MY_104H.authcheckdam.pdf 14 See Resolution 103A (August 2015) http://www.americanbar.org/content/dam/aba/images/abanews/2015annualresolutions/103a.pdf 15 See Resolution 106 (Midyear 2007) http://www.americanbar.org/content/dam/aba/publications/criminaljustice/2017/cj_policies_list.authcheckdam.pdf 16 No Safe Place The Criminalization of Homelessness in U.S. Cities, National Law Center on Homelessness & Poverty, https://www.nlchp.org/documents/No_Safe_Place 17 Resolution 106, Midyear 2007 18 Id. 19 Id. 20 See Ala.Code 1975 § 15-27-1 21 See https://www.nacdl.org/ResourceCenter.aspx?id=25091#ND for a comprehensive list of state expungement policies. 22 Hon. Cynthia Diane Stephens, Keeping an Arrest from Resulting in A Life Sentence in an Age of Full Disclosure of Criminal Records, Mich. B.J., November 2008, at 29 23 See https://www.eeoc.gov/laws/practices/inquiries_arrest_conviction.cfm 24 Economic Perspectives on Incarceration and the Criminal Justice System, The White House, (April 2016), https://www.whitehouse.gov/sites/default/files/page/files/20160423_cea_incarceration_criminal_justice.pdf 25 Id. 26 George L. Kelling AND James Q. Wilson, Broken Windows, The Atlantic, (Vovember 2012), http://www.theatlantic.com/magazine/archive/2012/11/broken-windows/309142/ 27 Sarah Childress, The Problem with “Broken Windows” Policing, PBS Frontline, (JUNE 28, 2016), http://www.pbs.org/wgbh/frontline/article/the-problem-with-broken-windows-policing/ 28 https://www.theatlantic.com/magazine/archive/1982/03/broken-windows/304465/ 29 http://www.npr.org/2016/11/01/500104506/broken-windows-policing-and-the-origins-of-stop-and-frisk-and-how-it-went-wrong 30 Id. 31 Id. 32 Id. 33 Id. 34 Id. 35 See City of Chicago v. Morales, 527 U.S. 41, 119 S. Ct. 1849, 144 L. Ed. 2d 67 (1999) 36 Id. 37 Fisher, Marina and Miller, Nathaniel and Walter, Lindsay and Selbin, Jeffrey, California's New Vagrancy Laws: The Growing Enactment and Enforcement of Anti-Homeless Laws in the Golden State (February 12, 2015). Available at SSRN: https://ssrn.com/abstract=2558944 or http://dx.doi.org/10.2139/ssrn.2558944 38 Id. 39 Id. 40 See Papachristou v. City of Jacksonville, 405 U.S. 156 (1972) 41 Economic Perspectives on Incarceration and the Criminal Justice System, The White House, (April 2016), https://www.whitehouse.gov/sites/default/files/page/files/20160423_cea_incarceration_criminal_justice.pdf 42 Lahny R. Silva, Clean Slate: Expanding Expungements and Pardons for Non-Violent Federal Offenders, 79 U. Cin. L. Rev. 155 (2010). 43 Researchers Examine Effects of a Criminal Record on Prospects for Employment, Council of State Governments Justice Center, (August 20, 2014), https://csgjusticecenter.org/reentry/posts/researchers-examine-effects-of-a-criminal-record-on-prospects-for-employment/ 44 Economic Perspectives on Incarceration and the Criminal Justice System, The White House, (April 2016), https://www.whitehouse.gov/sites/default/files/page/files/20160423_cea_incarceration_criminal_justice.pdf 45 Jon Geffen & Stefanie Letze, Chained to the Past: An Overview of Criminal Expungement Law in Minnesota-State v. Schultz, 31 Wm. Mitchell L. Rev. 1331 (2005) 46 Lahny R. Silva, Clean Slate: Expanding Expungements and Pardons for Non-Violent Federal Offenders, 79 U. Cin. L. Rev. 155 (2010). 47 Pager et al., Sequencing Disadvantage: Barriers to Employment Facing Young Black and White Men with Criminal Records, American Academy of Political and Social Science, (May 2009), http://scholar.harvard.edu/files/pager/files/annals_sequencingdisadvantage.pdf 48 UNMARKED 49 Id. 50 https://ucr.fbi.gov/crime-in-the-u.s/2014/crime-in-the-u.s.-2014/tables/table-43 51 Economic Perspectives on Incarceration and the Criminal Justice System, The White House, (April 2016), https://www.whitehouse.gov/sites/default/files/page/files/20160423_cea_incarceration_criminal_justice.pdf 52 Amy L. Solomon, In Search of a Job: Criminal Records as Barriers to Employment, National Institute of Justice, https://www.nij.gov/journals/270/pages/criminal-records.aspx 53 Sara Wakefield and Christopher Uggen, Incarceration and Stratification, University of Minnesota Annual Review of Sociology, http://users.soc.umn.edu/~uggen/Wakefield_Uggen_10_ARSb.pdf 54 Economic Perspectives on Incarceration and the Criminal Justice System, The White House, (April 2016), https://www.whitehouse.gov/sites/default/files/page/files/20160423_cea_incarceration_criminal_justice.pdf 55 Selbin, McCrary & Epstein, Unmarked? Criminal Record Clearing and Employment Outcomes. Journal of Criminal Law and Criminology, Vol. 108, No. 1, 2017. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2486867 56 Id. 57 Id. 58 Id. 59 Id. 60 Jon Geffen & Stefanie Letze, Chained to the Past: An Overview of Criminal Expungement Law in Minnesota-State v. Schultz, 31 Wm. Mitchell L. Rev. 1331 (2005) 61 Sarah Childress, The Problem with “Broken Windows” Policing, PBS Frontline, (JUNE 28, 2016), http://www.pbs.org/wgbh/frontline/article/the-problem-with-broken-windows-policing/ 62 Jon Geffen & Stefanie Letze, Chained to the Past: An Overview of Criminal Expungement Law in Minnesota-State v. Schultz, 31 Wm. Mitchell L. Rev. 1331 (2005) 63 Elizabeth Brown, Ph.D. and Randall G. Shelden, M.A., Ph.D., Does Age or Poverty Level Best Predict Criminal Arrest and Homicide Rates? A Preliminary Investigation, Justice Policy Journal - Volume 8, Number 1, (May 12, 2011), http://www.cjcj.org/news/5579#article-5 64 Paul Prettitore, Does Legal Aid Reduce Povery? The Brookings Institution, (June 23, 2015), https://www.brookings.edu/blog/future-development/2015/06/23/does-legal-aid-reduce-poverty/ 65 Jon Mosher, Drawing the line at actual imprisonment, The Sixth Amendment Center, (January 31, 2013), http://sixthamendment.org/drawing-the-line-at-actual-imprisonment/ 66 Rebecca Oyama, DO NOT (RE)ENTER: THE RISE OF CRIMINAL BACKGROUND TENANT SCREENING AS A VIOLATION OF THE FAIR HOUSING ACT, Michigan Journal of Race and Law, (Fall 2009). 67 Economic Perspectives on Incarceration and the Criminal Justice System, The White House, (April 2016), https://www.whitehouse.gov/sites/default/files/page/files/20160423_cea_incarceration_criminal_justice.pdf 68 Id. 69 Kathryn E. McCollister, Michael T. French,and Hai Fang, The Cost of Crime to Society: New Crime-Specific Estimates for Policy and Program Evaluation, (January 13, 2010), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2835847/ 70 Id. 71 Id. 72 Economic Perspectives on Incarceration and the Criminal Justice System, The White House, (April 2016), https://www.whitehouse.gov/sites/default/files/page/files/20160423_cea_incarceration_criminal_justice.pdf 73 Id. 74 Id. 75 Id. 76 Kathryn E. McCollister, Michael T. French,and Hai Fang, The Cost of Crime to Society: New Crime-Specific Estimates for Policy and Program Evaluation, (January 13, 2010), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2835847/ 77 Economic Perspectives on Incarceration and the Criminal Justice System, The White House, (April 2016), https://www.whitehouse.gov/sites/default/files/page/files/20160423_cea_incarceration_criminal_justice.pdf 78 Alejandro Badel , Brian Greaney, Exploring the Link between Drug Use and Job Status in the U.S., The Regional Economist, (July 2013), See also Ioana Popovici and Michael T. French, Does Unemployment Lead to Greater Alcohol Consumption? Industrial Relations: A Journal of Economy & Society (18 March 2013), https://www.stlouisfed.org/Publications/Regional-Economist/July-2013/Exploring-the-Link-between-Drug-Use-and-Job-Status-in-the-US; 79 Susan Adams, How Unemployment And Depression Fit Together, Forbes, (June 9, 2014 12:15 PM) http://www.forbes.com/sites/susanadams/2014/06/09/how-unemployment-and-depression-fit-together/#52d0f97a3fa1 80 Andrea Kay, At Work: Job, self-esteem tied tightly together, USA Today (Aug. 31, 2013), http://www.usatoday.com/story/money/columnist/kay/2013/08/31/at-work-self-esteem-depression/2736083/ Directory: content -> dam -> aba -> directories -> policy policy -> Resolution policy -> American bar association adopted by the house of delegates policy -> 109a american bar association adopted by the house of delegates february 10, 2014 policy -> Adopted by the house of delegates policy -> 115 american bar association adopted by the house of delegates february 6, 2017 policy -> American bar association adopted by the house of delegates policy -> American bar association standing committee on paralegals report to the house of delegates policy -> 119b american bar association adopted by the house of delegates august 14-15, 2017 policy -> 107d american bar association adopted by the house of delegates february 9, 2015 policy -> American bar association adopted by the house of delegates Download 92.43 Kb. 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