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[House Report 114-457]
[From the U.S. Government Publishing Office]

114th Congress    }                                    {        Report
                        HOUSE OF REPRESENTATIVES
 2d Session       }                                    {       114-457

======================================================================

 
  AUTHORIZING THE SPEAKER TO APPEAR AS AMICUS CURIAE ON BEHALF OF THE 
  HOUSE OF REPRESENTATIVES IN THE MATTER OF UNITED STATES, ET AL. V. 
                       TEXAS, ET AL., NO. 15-674

                                _______
                                

  March 16, 2016.-- Referred to the House Calendar and ordered to be 
                                printed

                                _______
                                

   Mr. Sessions, from the Committee on Rules, submitted the following

                              R E P O R T

                             together with

                             MINORITY VIEWS

                       [To accompany H. Res. 639]

    The Committee on Rules, to whom was referred the resolution 
(H. Res. 639) authorizing the Speaker to appear as amicus 
curiae on behalf of the House of Representatives in the matter 
of United States, et al. v. Texas, et al., No. 15-674, having 
considered the same, report favorably thereon and recommend 
that the resolution be adopted.

                           table of contents

                                                                   Page
Purpose and Summary..............................................     1
Background and Need for Legislation..............................     2
Hearings.........................................................     6
Committee Consideration..........................................     6
Committee Votes..................................................     6
Committee Oversight Findings and Recommendations.................     8
Performance Goals and Objectives.................................     8
Advisory Committee Statement.....................................     8
Section-by-Section Analysis of the Legislation...................     8
Changes in Existing House Rules Made by the Resolution, as 
  Reported.......................................................     8
Minority Views...................................................     9

                          purpose and summary

    This resolution authorizes the Speaker to appear as amicus 
curiae on behalf of the House of Representatives in the matter 
of United States, et al. v. Texas, et al., No. 15-674, and to 
file a brief in support of the position that the petitioners 
have acted in a manner that is not consistent with their duties 
under the Constitution and laws of the United States. The 
resolution also requires the Speaker to notify the House upon 
his decision to file one or more briefs as amicus curiae 
pursuant to this resolution. Finally, the resolution provides 
that the Office of the General Counsel, at the direction of the 
Speaker, will represent the House in connection with the filing 
of any brief as amicus curiae pursuant to this resolution, 
including supervision of any outside counsel providing services 
to the Speaker on a pro bono basis for such purposes.

                  background and need for legislation

    The President has failed on numerous occasions to fulfill 
his duty under Article II, section 3 of the Constitution of the 
United States to ``take Care that the Laws be faithfully 
executed.'' He has ignored certain statutes completely, 
selectively enforced others, and bypassed the legislative 
process to essentially create law by executive fiat. These 
unilateral actions have shifted the balance of power in favor 
of the presidency, thereby diminishing Congress' constitutional 
powers. Such a shift in power should alarm Members of both 
political parties because it threatens the very institution of 
Congress.
    Contrary to its duty to faithfully execute the laws, the 
Administration has acted unilaterally to rewrite the Nation's 
immigration laws. These actions undermine the framework of the 
Constitution, which separates power between the branches to 
best protect liberty. The Constitution provides that, ``All 
legislative Powers * * * shall be vested in a Congress of the 
United States,'' including authority ``to establish a uniform 
rule of naturalization.'' The following are examples of 
executive overreach regarding the enforcement of the Nation's 
immigration laws that are the focus of litigation (United 
States, et al. v. Texas, et al., No. 15-674) currently before 
the United States Supreme Court.

             Deferred Action for Childhood Arrivals (DACA)

    Napolitano Memo.--On June 15, 2012, Secretary of Homeland 
Security Janet Napolitano issued a memo entitled ``Exercising 
Prosecutorial Discretion with Respect to Individuals Who Came 
to the United States as Children'' providing that the 
Department of Homeland Security (DHS) would grant deferred 
action to unlawful aliens who ``came to the United States under 
the age of sixteen; have continuously resided in the United 
States for a least five years preceding June 15, 2012, and were 
present in the United States on that date; are currently in 
school, have graduated from high school, have obtained a 
general education development certificate, or are honorably 
discharged veterans of the Coast Guard or Armed Forces of the 
United States; have not been convicted of a felony offense, a 
significant misdemeanor offense, multiple misdemeanor offenses, 
or otherwise do not pose a threat to national security or 
public safety; and are not above the age of thirty.'' The DACA 
process is not directly at issue in the case  U.S. v. Texas. 
However, the manner in which DACA was implemented was material 
to the lower courts.
    U.S. Citizenship and Immigration Services (USCIS) first 
granted DACA benefits in September 2012. Since the DACA term is 
two years, the first grants began expiring in September 2014. 
In May 2014, USCIS announced renewal procedures for initial 
DACA recipients.

 Deferred Action for Unlawful Alien Parents of U.S. Citizen and Legal 
         Permanent Resident Children (DAPA) and DACA Expansion

    Johnson Memo.--On November 20, 2014, Secretary of Homeland 
Security Jeh Johnson issued a memo entitled ``Exercising 
Prosecutorial Discretion with Respect to Individuals Who Came 
to the United States as Children and with Respect to Certain 
Individuals Who Are the Parents of U.S. Citizens or Permanent 
Residents.'' In this memo, Secretary Johnson ordered USCIS to: 
1) expand the DACA process by removing the age restriction that 
excluded those who were older than 31, extended DACA renewal 
and work authorization periods from two to three years, and 
adjusted the eligibility cut-off date by which a DACA applicant 
must have been in the United States from June 15, 2007 to 
January 1, 2010; and, 2) establish Deferred Action for Unlawful 
Alien Parents (DAPA),``a process, similar to DACA, for 
exercising prosecutorial discretion through the use of deferred 
action, on a case-by-case basis, to those individuals who have 
* * * a son or daughter who is a U.S. citizen or lawful 
permanent resident; have continuously resided in the U.S. since 
before January 1, 2010; are physically present in the United 
States on November 20, 2014 * * * and at the time of making a 
request for consideration of deferred action with USCIS; have 
no lawful status on the date of this memorandum; are not an 
enforcement priority (as defined) * * * ; and present no other 
factors that, in the exercise of discretion, makes the grant of 
deferred action inappropriate.'' This memo is directly at issue 
in U.S. v. Texas.
    The Migration Policy Institute estimated that 3.71 million 
unlawful aliens will be potentially eligible to apply for DAPA. 
The Obama Administration estimated the number to be 4.1 
million.

            Texas v. United States and the Challenge to DAPA

    Over 25 states or state officials have filed suit 
challenging the Administration's expansion of DACA and the 
creation of a DACA-like program for aliens who are parents of 
U.S. citizens or lawful permanent residents (DAPA). The states 
allege that these administrative actions run afoul of the Take 
Care Clause of the Constitution. Article II, section 3 declares 
that the President ``shall take Care that the Laws be 
faithfully executed,'' thus requiring the President to enforce 
all constitutionally valid Acts of Congress, regardless of the 
Administration's view of their wisdom or policy. The states 
also allege that these legalizations run afoul of the 
separation of powers set forth in the Constitution. Article I, 
section 8 gives Congress, not the President, the authority ``to 
establish a uniform rule of naturalization.'' While the Supreme 
Court has indicated on several occasions that the President has 
some measure of ``inherent'' power over immigration, see, e.g., 
 United States ex rel. Knauff v. Shaughnessy, 338 U.S. 537, 542 
(1950), the Court has settled on the view that the formation of 
immigration policy ``is entrusted exclusively to Congress,'' 
Galvan v. Press, 347 U.S. 522, 531 (1954), and that ``[t]he 
plenary authority of Congress over aliens * * * is not open to 
question,'' INS v. Chadha, 462 U.S. 919, 940-41 (1983). 
Congress passed the Immigration and Nationality Act (INA), 
which specifies the limited cases in which the Executive Branch 
can suspend the removal of unlawful aliens. Finally, the states 
allege that the legalizations violate substantive and 
procedural requirements of the Administrative Procedure Act 
(APA).

Administration Claims that DAPA is Merely An Exercise of Prosecutorial 
                               Discretion

    In ``Protecting the Homeland: Tool Kit for Prosecutors,'' 
ICE describes `deferred action' as ``not a specific form of 
relief but rather a term used to describe the decision-making 
authority of ICE to allocate resources in the best possible 
manner to focus on high priority cases, potentially deferring 
action on [removal] cases with a lower priority * * *''. This 
includes, as they note in ``Continued Presence: Temporary 
Immigration Status for Victims of Human Trafficking,'' such 
action as ``not placing an individual in removal proceedings.''
    DHS claims that grants of deferred action are merely an 
exercise of prosecutorial discretion. See Texas v. U.S., No. 
15-40238, slip op. at 34-35 (5th Cir. Nov. 9, 2015). 
Prosecutorial discretion is the inherent authority of an agency 
charged with enforcing a law to decide whether to devote 
resources to enforce the law in particular instances. It 
applies to both criminal and civil enforcement. The Supreme 
Court found in Heckler v. Chaney, 470 U.S. 821 (1985), that 
``an agency's decision not to prosecute or enforce, whether 
through civil or criminal process, is a decision generally 
committed to an agency's absolute discretion.'' Id. at 831. 
However, the Court in Heckler stated that the Executive Branch 
cannot ```consciously and expressly adopt[] a general policy' 
that is so extreme as to amount to an abdication of its 
statutory responsibilities.'' Id. at 833 n.4 (quoting Adams v. 
Richardson, 480 F.2d 1159, 1162 (D.C. Cir. 1973)(en banc).
    To determine whether DAPA could fairly be characterized as 
an exercise of prosecutorial discretion, the District Court 
examined the operation of the DACA process. Despite its claim 
that DACA was applied on a case-by-case basis, the 
Administration could not provide a federal district court in 
Texas with any examples of DACA applicants who met the 
program's criteria but were denied DACA status. See  Texas v. 
U.S., Civ. No. B-14-254, slip op. at 109 n.101 (S.D. Tex. Feb. 
16, 2015)(memorandum order and opinion). The Fifth Circuit 
ratified the district court's finding, stating that DHS 
``purported to identify several instances of discretionary 
denials. . . The states properly maintain that those denials 
were not discretionary but instead were required because of 
failures to meet DACA's objective criteria.'' Texas v. U.S., 
No. 15-40238, slip op. at 49, 49 n.140 (5th Cir. Nov. 9, 
2015)(affirming grant of preliminary injunction). In other 
words, had this program truly been applied on a case-by-case 
basis and had it not been binding on those who review 
applications, one would suspect that there would be at least a 
few instances in which a DACA applicant would have been denied 
status. Proof of such cases simply did not exist.
    In addition, the Fifth Circuit concluded that:
     `` * * * there was evidence that the DACA application 
process itself did not allow for discretion * * * The district 
court's conclusion that DACA and DAPA would be applied 
similarly * * * was not clearly erroneous and indeed was not 
error under any standard of review * * * [W]e conclude that the 
states have established substantial likelihood that DAPA would 
not genuinely leave the agency and its employees free to 
exercise discretion.'' Id. at 48, 48 n.139, 50.
    USCIS considers unlawful aliens who have received DAPA 
relief to be ``lawfully present,'' see Texas v. U.S., No. 15-
40238, slip op. at 38, and usually grants them work 
authorization, see 8 C.F.R. Sec.  274a.12(c)(14)--making DAPA 
in essence a grant of administrative, extra-statutory 
legalization. The Fifth Circuit concluded that ``the INA 
[Immigration and Nationality Act] flatly does not permit the 
reclassification of millions of illegal aliens as lawfully 
present and thereby make them newly eligible for a host of 
federal and state benefits * * *'' Texas v. U.S., No. 15-40238, 
slip op. at 63. And, while DHS claims that 8 U.S.C. Sec.  
1324a(h)(3)--which provides that an alien is eligible to work 
if they are ``either (A) an alien lawfully admitted for 
permanent residence, or (B) authorized to be so employed by 
this chapter or by the [Secretary of Homeland Security]''--
grants it the statutory authority to grant work authorization 
to unlawful aliens at its choosing, the Fifth Circuit rejected 
this interpretation, stating that ``[t]he interpretation of 
th[e] provision[] that the Secretary advances would allow him 
to grant * * * work authorization to any illegal alien in the 
United States--an untenable position in light of the INA's 
intricate system of immigration classifications and employment 
eligibility.'' Id. at 62.

                         Procedural Disposition

    On February 16, 2015, the district court (i) held that the 
states have standing to sue, (ii) held that DAPA and DACA 
expansions are judicially reviewable, and (iii) entered a 
preliminary injunction prohibiting further implementation of 
these programs on the ground that the states are likely to 
prevail in their argument that the programs run afoul of the 
procedural requirements of the APA. See Texas v. U.S. Civ. No. 
B-14-254, slip op. at 67, 112, 123 (granting preliminary 
injunction). Subsequently, on November 9, 2015, the U.S. Court 
of Appeals for the Fifth Circuit affirmed the district court's 
order granting a preliminary injunction. See Texas v. U.S., No. 
15-40238, slip op. at 70. The Fifth Circuit concluded that (i) 
the states had standing to sue, id. at 28, (ii) DAPA was a 
reviewable agency action, id. at 40, (iii) DAPA's grant of 
lawful presence and eligibility for benefits was a substantive 
rule under the APA that must go through notice and comment, id. 
at 42, (iv) ``the states have established a substantial 
likelihood of success on the merits of their procedural 
claim,'' id. at 54, that DAPA was ``manifestly contrary to the 
statute'' and ``therefore was properly enjoined,'' id. at 66, 
and (v) the states ``have satisfied the other requirements for 
a preliminary injunction,'' id. The Administration then sought 
review from the Supreme Court, which granted its petition for 
certiorari on January 19, 2016. In so doing, the Court 
indicated that it would also consider the plaintiffs' claims 
under the Take Care Clause.

                               Conclusion

    The questions presented in this case are extraordinarily 
significant to the House of Representatives. In particular, 
this case raises issues relating to the limits on Executive 
discretion not to enforce laws enacted by Congress, as well as 
the point at which the exercise of such discretion turns into 
lawmaking, thereby infringing on Congress's Article I 
legislative powers. It is precisely because of these 
constitutional questions pending before the Supreme Court that 
the House will take the rare step to consider this resolution 
authorizing the Speaker to appear as amicus curiae on behalf of 
the House of Representatives in this important litigation.

                                hearings

    The Rules Committee held a hearing on this resolution on 
March 16, 2016.

                        committee consideration

    The Committee on Rules met on March 16, 2016 in open 
session and ordered H. Res. 639, without amendment, favorably 
reported to the House by a record vote of 7 yeas and 3 nays, a 
quorum being present.

                            committee votes

    Clause 3(b) of rule XIII of the Rules of the House of 
Representatives requires the Committee to list the record votes 
on the motion to report legislation and amendments thereto. A 
motion by Mr. Woodall to report the resolution, without 
amendment, to the House with a favorable recommendation was 
agreed to by a record vote of 7 yeas and 3 nays, a quorum being 
present. The names of Members voting for and against follow:

                  rules committee record vote no. 156

                              h. res. 639

    Date: March 16, 2016.
    Motion by Mr. Woodall to report the resolution to the House 
with a favorable recommendation.
    Agreed to: 7 yeas and 3 nays.

--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                             Not                                                                   Not
                 Representative                    Yea    Nay    Present   Voting             Representative             Yea    Nay    Present   Voting
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ms. Foxx, Vice Chairman.........................                                X   Ms. Slaughter, Ranking Member.....            X
Mr. Cole........................................                                X   Mr. McGovern......................            X
Mr. Woodall.....................................     X                              Mr. Hastings......................                                X
Mr. Burgess.....................................     X                              Mr. Polis.........................            X
Mr. Stivers.....................................     X
Mr. Collins.....................................     X
Mr. Byrne.......................................     X
Mr. Newhouse....................................     X
Mr. Sessions, Chairman..........................     X
                                                                                                                       ---------------------------------
                                                                                    Vote Total:                            7      3         0         3
--------------------------------------------------------------------------------------------------------------------------------------------------------

    The committee also considered the following amendments on 
which record votes were requested. The names of Members voting 
for and against follow:

                  rules committee record vote no. 155

                              h. res. 639

    Date: March 16, 2016.
    Motion by Ms. Slaughter to adopt Slaughter amendment #1, 
which would express the position of the House in support of the 
Obama Administration in U.S. v. Texas.
    Not Agreed to: 3 yeas and 7 nays.

--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                             Not                                                                   Not
                 Representative                    Yea    Nay    Present   Voting             Representative             Yea    Nay    Present   Voting
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ms. Foxx, Vice Chairman.........................                                X   Ms. Slaughter, Ranking Member.....     X
Mr. Cole........................................                                X   Mr. McGovern......................     X
Mr. Woodall.....................................            X                       Mr. Hastings......................                                X
Mr. Burgess.....................................            X                       Mr. Polis.........................     X
Mr. Stivers.....................................            X
Mr. Collins.....................................            X
Mr. Byrne.......................................            X
Mr. Newhouse....................................            X
Mr. Sessions, Chairman..........................            X
                                                                                                                       ---------------------------------
                                                                                    Vote Total:                            3      7         0         3
--------------------------------------------------------------------------------------------------------------------------------------------------------

            committee oversight findings and recommendations

    Pursuant to clause 3(c)(1) of rule XIII of the Rules of the 
House of Representatives, the Committee made findings and 
recommendations that are reflected in this report.

                    performance goals and objectives

    Pursuant to clause 3(c)(4) of rule XIII of the Rules of the 
House of Representatives, the Committee establishes the 
following performance related goals and objectives for this 
legislation:
    The resolution will ensure the Speaker is authorized to 
appear as amicus curiae on behalf of the House of 
Representatives in the matter of United States, et al. v. 
Texas, et al., No. 15-674, and to file a brief in support of 
the position that the petitioners have acted in a manner that 
is not consistent with their duties under the Constitution and 
laws of the United States.

                      advisory committee statement

    No advisory committees within the meaning of section 5(b) 
of the Federal Advisory Committee Act were created by this 
legislation.

             section-by-section analysis of the legislation

    First Section. This section provides independent authority 
for the Speaker, on behalf of the House of Representatives, to 
appear as amicus curiae in the matter of United States, et al. 
v. Texas, et al., No. 15-674, and to file a brief in support of 
the position that the petitioners have acted in a manner that 
is not consistent with their duties under the Constitution and 
laws of the United States.
    Sec. 2. This section requires the Speaker to notify the 
House upon his decision to file one or more briefs as amicus 
curiae pursuant to this resolution.
    Sec. 3. This section provides that the Office of the 
General Counsel, at the direction of the Speaker, will 
represent the House in connection with the filing of any brief 
as amicus curiae pursuant to this resolution, including 
supervision of any outside counsel providing services to the 
Speaker on a pro bono basis for such purposes.

  changes in existing house rules made by the resolution, as reported

    In compliance with clause 3(g) of rule XIII of the Rules of 
the House of Representatives, the Committee finds that this 
resolution does not propose to repeal or amend a standing rule 
of the House.

                             MINORITY VIEWS

    H. Res. 639, authorizing the Speaker to file an amicus 
brief on behalf of the House of Representatives in U.S. v. 
Texas, is at best an unfortunate misuse of the House's time and 
resources.
    Congress has the constitutional power if not the obligation 
to enact legislation making sense of our broken immigration 
system. The system, as it stands, cruelly fails to distinguish 
between hardened criminals and hard-working taxpayers who 
entered the country simply to build a better life for their 
families. It simultaneously fails to meet the needs of American 
businesses and our economy. Instead of putting the interests of 
the country first and bringing up the bipartisan, comprehensive 
immigration reform bill passed by the Senate 68-32 last term 
when they had the opportunity, House Republicans blocked it.
    When the President sought to temporarily address some of 
the most significant problems in our immigration enforcement 
regime by exercising prosecutorial discretion and authority 
granted to him explicitly by Congress, Republicans voiced their 
objection.
    But instead of opposing the Administration's policies using 
the powers committed to the Legislative Branch by the 
Constitution--including passing laws and overriding vetoes, 
engaging in oversight and carrying out investigations, or 
leveraging the power of the purse--Republicans have reached for 
a tool not in their constitutional toolbox: running to the 
courthouse. Rather than allow Congress to do its job, 
Republicans insist on telling the other branches of government 
how to do theirs.
    House Republicans will file an amicus brief pursuant to 
this resolution and it will masquerade as expressing the 
position of the institution of the House of Representatives in 
an inter-branch, separation of powers conflict. But the fact 
is, this is nothing more than a partisan fight about elections 
and immigration policy. Democrats, who represent half of the 
country, were not consulted. We were denied an opportunity to 
present an alternative. The Speaker's amicus brief does not 
speak for the Democratic Members of the House.
    President Obama's executive actions on immigration--
Deferred Action for Childhood Arrivals (DACA) and Deferred 
Action for Parents of Americans and Lawful Permanent Residents 
(DAPA)--are common-sense, lawful exercises of executive 
discretion, consistent with the actions of presidents from both 
parties over the last half dozen decades.
    For example, from 1987 to 1990, Presidents Reagan and Bush 
implemented a ``Family Fairness'' policy that deferred 
deportation of an estimated 1 million spouses and children of 
people who qualified for legal status. As President Obama is 
doing today, President Reagan used his discretion to grant work 
authorization to beneficiaries of deferred action, a 
longstanding practice that was later codified by Congress in 
the 1986 Immigration Reform and Control Act. Presidents from at 
least Eisenhower to Clinton have done similarly, and there are 
numerous laws on the books going at least as far back as 1952 
explicitly instructing the Executive Branch either to exercise 
prosecutorial discretion or prioritize enforcement in 
immigration matters.
    Even the Supreme Court, including Chief Justice Roberts and 
Justice Anthony Kennedy, has acknowledged the legitimacy of 
Executive Branch discretion in immigration. In U.S. v. Arizona, 
the Court recognized that this broad discretion is a 
``principal feature of the removal system'' and that it extends 
to the question of ``whether it makes sense to pursue removal 
at all.''
    Indeed, such prioritization is necessary in light of the 
fact that Congress appropriates only enough money for the 
Department of Homeland Security to remove approximately four 
percent of the undocumented immigrants already in the country.
    But there is something more troubling here than the misuse 
of the House's time and resources, the weakness of the 
Republicans' legal argument, or the harm to the country and the 
economy that would result from the implementation of their 
preferred policies on immigration. Bringing this resolution to 
the floor of the House at this particular moment says something 
worrisome about the state of the Republican Party and its 
leadership.
    It is quickly becoming clear that this is a dangerous 
moment in our country and in our political system. The 
Republican presidential primary field is resorting to 
demagoguery and nativism, fanning the flames of dangerous anti-
immigrant anger, and anger in general. What the President 
rightly called ``vulgar and divisive rhetoric'' in the 
Republican contest is a logical and foreseeable consequence of 
the anger and fear carefully and deliberately cultivated by 
decades of Republican campaign strategy, as Republicans went 
beyond principled advocacy for smaller government to the 
outright encouragement of people to think of government as the 
problem and an enemy to be hated. In an effort to delegitimize 
President Obama, they indulged conspiracy theories about our 
first African American president being a foreign-born ``secret 
Muslim'' who aspires to be a dictator and take away our 
freedoms. And capping what the New York Times Editorial Board 
characterized on March 15 as ``decades of pandering to 
intolerance,'' Republicans have used hateful slurs to describe 
Latino immigrants, saying they have ``calves the size of 
cantaloupes,'' calling them ``wetbacks,'' ``dogs,'' 
``livestock,'' and saying they come from a ``violent 
civilization.'' All of those things Republicans did and said to 
win elections and score political points have helped prime the 
electorate for this year's candidates.
    Now that Republican leaders see what they have created, do 
they take this opportunity to back off of the rhetoric? No, 
they forge ahead with more anti-immigrant, anti-Latino 
legislation, with more accusations that the President is a 
lawless tyrant who violates the Constitution and makes his own 
law.
    If ever there were a moment for responsible leaders to take 
a step back and use their positions of influence and power to 
encourage level-headedness, this would be the time.
    Our country of immigrants desperately needs its legislators 
to reform its badly broken immigration system. Doing so would 
create jobs, align the labor force with the needs of employers, 
reduce our deficit, strengthen our economy, keep families 
together, and make our communities safer by bringing millions 
of people out of the shadows. That Republican leaders continue 
instead to send to the floor of the House legislation designed 
to appeal to people's fear and hatred, even as our political 
system comes closer and closer to the edge of a crisis brought 
about by the deliberate sowing of that same fear and hatred, 
says something very worrisome indeed.

                                   Louise M. Slaughter.
                                   James P. McGovern.
                                   Alcee L. Hastings.
                                   Jared Polis.

                                  [all]
```