AMICUS CURIÆ BRIEF
(John Locke Foundation, Inc.)
Index
Question Presented: Did the Trial Court Err in Invalidating G.S. 158-7.1
as Violative of the North Carolina Constitution?
Interest of the Amicus
The John Locke Foundation, Inc. is a nonprofit, nonpartisan public policy
think tank that examines state and local issues in North Carolina. The
Foundation conducts research, publishes studies and periodicals, provides
testimony and information to governmental bodies, and participates in public
discussion about policy issues facing North Carolina.
The Foundation represents no industry, association, or narrow interest
group. Instead, it seeks to advance the public good through research, analysis,
and commentary. Because of its interest in economic policy in particular,
and its belief that the public good is the only just and constitutional
goal for governmental policy, the Foundation has asked leave to file as
a friend of the court in this important case.
Appreciation is extended to Thomas E. Vass, a student of North Carolina
economic history who contributed greatly to this brief. He is a private
portfolio manager and is the president of Business and Family Financial
Strategies, Inc. located in Raleigh.
Statement of the Case and the Facts
Amicus Curiae adopts the Statement of the Case and the Statement of the
Facts from the Brief of Plaintiff Maready.
Introduction
North Carolina Constitution Article I Section 32 provides that "no person
or set of persons is entitled to exclusive or separate emoluments or privileges
from the community but in consideration of public services."
North Carolina Constitution, Article I, Section 35 provides that "a
frequent recurrence to fundamental principles is absolutely necessary to
preserve the blessings of liberty."
North Carolina Constitution, Article V, Section 2 (1) and (7)
provides:
(1) "The power of taxation shall be exercised in a just and equitable
manner,
for public purposes only, and shall never be surrendered, suspended
or contracted away."
(2) "The General Assembly may enact laws whereby the state, any county,
city or town, and any other public corporation may contract with and appropriate
money to any person, association, or corporation for the accomplishment
of public purposes only."
This brief argues that General Statute 158-7.1 is unconstitutional on its
face and as applied in that it is inherently violative of these constitutional
provisions.
The briefs of other parties and amici approach the question with traditional
legal materials. But constitutional requirements to use public funds only
for public purposes have an economic rationale, which this brief presents
to the Court. This rationale demonstrates not only that a meaningful definition
of "public purpose" would preclude practices such as those contained in
G.S. 158-7.l but also that the affirmation of the "public purpose" doctrine
will not harm the economy of North Carolina. It will enhance it.
Since some of the sources cited are not available in the Supreme Court
Library
the appendix includes copies of relevant portions of some of the materials.
Argument
G.S. 158-7.1 FAILS THE "EXCLUSIVE EMOLUMENTS OR PRIVILEGE" AND "PUBLIC
PURPOSE" TESTS OF THE NORTH CAROLINA CONSTITUTION ARTICLE I SECTION 32
AND ARTICLE V SECTION 2.
SECTION I. OVERVIEW OF NORTH CAROLINA ECONOMIC DEVELOPMENT
POLICY
The issue of how best to expand economic opportunities for North
Carolinians is hardly a new one. In every administration and legislative
session into the last century the issue has come up in one form or another.
Typical of the dialogue is a March 23, 1955 address by Gov. Luther M. Hodges
to the North Carolina Citizen's Association of Raleigh. Messages, and Public
Papers of Luther Hartwell Hodges, Governor of North Carolina, 1954-1956,
Volume I, (North Carolina Council of State, 1960) pp. 105-109.
The governor began his speech with a review of North Carolina's spectacular
industrial recruitment successes with firms in the electronic component
manufacturing sector. After reviewing these successes Hodges noted, with
caution, that North Carolina's citizens had not enjoyed rising per-capita
incomes relative to citizens of other states. "Despite [recruitment successes],
we find ourselves in no better relative position than we were thirty years
ago, ranking 44th out of 48 states in per-capita incomes," he said. Hodges
concluded by enunciating a public economic development plan based upon
"a determined drive to attract outside capital to North Carolina."
This three-part economic policy statement--touting successes, bemoaning
the state's continued relative poverty, and then proposing solutions--has
been repeated throughout the century by North Carolina governors. Thirty
years prior to the Hodges administration, Gov. Angus Wilton McLean repeated
the three-part policy statement in his Biennial Message to the General
Assembly. "North Carolina neither baits nor coddles big business," he said.
"Every honest enterprise is encouraged and is justly treated by our state
government in the enactment and administration of our laws. On account
of this fair and just attitude toward outside capital, our state has in
the past twenty-five years shown a greater rate of progress in industrial
development than any other state in the Union." Still, he concluded, North
Carolina remained relatively low in economic measures, and more economic
development efforts were needed. "Biennial Message to the North Carolina
General Assembly," Public Papers and Letters of Angus Wilton McLean, Governor
of North Carolina, 1925-1929 (Edwards & Broughton, 1931) p. 73.
Throughout the years such efforts by state and local governments in
North Carolina have been the subject of controversy. Some North Carolinians
have advocated a larger governmental role in promoting the state or particular
regions of the state to outside industry. Others have proposed a smaller
governmental role, or a different one. Furthermore, policymakers and economic
developers have disagreed about the importance of various factors in fostering
the creation, expansion, and relocation of businesses. These factors might
include wage rates, availability of labor and capital, tax rates, skill
levels, transportation options, and access to consumer markets.
Similar debates continue today. But the relatively recent government
policy ofproviding cash or other direct, targeted incentives to individual
companies--incentives not available to all firms, but only to particular
ones selected through political rather than market means--represents a
distinct break from North Carolina's past economic development debates.
The new practice raises the constitutional issue because of its relationship
to the exclusive emoluments or privileges' and public purpose' doctrines.
Other government policies might prove to be unwise, counterproductive or
irrational.
But an economic policy can be irrational and nevertheless be constitutionally
permissible.
The use of tax revenues on a selective basis to promote the private
purposes of individual firms, however, is directly opposite to the pursuit
of the common good. This practice relies upon the unreasonable assumption
that governments can best judge which businesses will contribute the most
value to an economy, because the government is taking money away from some
firms, workers and consumers--through taxation--and giving it to others.
This "opportunity cost," is never factored into the equation which government
officials use to justify their policy. Their focus is merely on the jobs
or economic opportunities that appear to be created, not whether there
is a net expansion of jobs or economic opportunities once the opportunity
cost of the policy is subtracted.
Empirical research suggests that cash and other targeted state incentives
have not provided a net economic gain in any jurisdiction. Instead, academic
studies examining the subject have found that such incentives bear no statistically
significant relationship to measures of state economic performance or well-being.
The most comprehensive of these studies is by Margery Marzahn Ambrosius,
"The Effectiveness of State Economic Development Policies: A Time-Series
Analysis" 42 Western Political Quarterly 283 (Spring 1989) which is included
in the Appendix. Ambrosius concludes, at 294:
"In no case, however, does any one of these economic development
policies demonstrate an unequivocally positive, measurable overall impact
on either of the indicators of state economic health.
By using methodology which has not previously been used to analyze the
effectiveness of state economic development policies, considerable support
is thus given to previous findings that these policies have no beneficial
effect on state economies. In fifteen of the sixteen analyses, these policies
have no demonstrable positive effect on the economic health of the adopting
states, as measured by per capita manufacturing value added or by the unemployment
rate."
This means that such incentives merely redistribute jobs and growth
from one area to another, or one firm to another, or even one individual
to another. Targeted incentives are not broadly available and do not promote
the public good as a whole. They advance a private, not a public, purpose.
It is not enough for a government to intend for a tax-funded subsidy
to benefit the economy as a whole rather than simply the firm to which
it is given. If intention alone is allowed to define "public purpose",
then it has no meaningful definition. If the constitutional test for "public
purpose" is anything more than an inkblot, then it must be based on a reasonable
expectation of net social benefit. The next section demonstrates that such
an expectation is inherently impossible with regard to the incentive practices
at issue.
SECTION II. GOVERNMENT INCENTIVES GIVEN TO PRIVATE FIRMS DO
NOT SERVE A PUBLIC PURPOSE
How profits may be used in society to achieve a public purpose was analyzed
by Thomas Aquinas. Aquinas began his analysis by reviewing the philosophical
debate over the activity of trading and the behavior of the individual
trader. Aquinas was interested in demonstrating that an individual trader
could be considered a moral person, even if the activity of trading may
be immoral because it may generate profits in excess of the "just" price.
The resolution for Aquinas lay in determining whether the profits were
subsequently used to promote the public good. Aquinas developed a three
part categorization of the use of profits which would be used to guide
judgments about the use of profits. If the trader pursues an "honorable"
purpose with the profits, then profits are justified. The three allowable
purposes for profits were self-support, charity, or providing the public
with goods., and thus serving a "public service." Henry William Spiegel,
The Growth of Economic Thought, (Duke University Press 1983) pp.
57-61.
Writing in 1776, Adam Smith, in The Wealth of Nations, made the
link between profits and the public good. Smith described how a society
that relied upon competitive market transactions between sovereign individuals
would achieve greater prosperity for the entire nation than a society that
relied upon government-directed economic policy. See especially Chapter
II "Of Restraints Upon the Importation from Foreign Countries of Such Goods
As can be Produced at Home" in Adam Smith, An Inquiry Into the Nature and
Causes of the Wealth of Nations (Random House 1937).
The branch of economic theory employed by Smith eventually became known
as "general equilibrium welfare economics." It is from this theoretical
perspective that the arguments against the "public purpose" of tax revenue-based
incentives are made. Smith contended that every individual would endeavor
to employ capital in support of domestic industry for practical reasons.
A "stateman who should attempt to direct private people in
what manner they ought to employ their capitals, would not only load himself
with a most unnecessary attention, but assume an authority which could
safely be trusted, not only to no single person, but to no council or senate
whatever, and which would nowhere be so dangerous in the hands of a man
who had folly and presumption enough to fancy himself fit to exercise it."
Id at 423.
One of the leading scholars in welfare economic theory was J. De
V. Graaf, who described what transactions occur in the free market to bring
all the actors to market welfare maximization:
"The familiar result that perfect competition will, under certain
circumstances, lead to an optimal allocation of resources is based on the
satisfaction of the above marginal equivalences. Profit maximizing entrepreneurs
will attempt to equate their marginal private rates of transformation to
given price ratios. Since uniform price ratios will prevail on a competitive
market, the marginal private rates will be the same in every firm. If,
then, the marginal social rates are everywhere equal to the private ones,
or if they are everywhere k times them (where k is any constant), they
too will be the same in every firm."
J. De V. Graaf, Theoretical Welfare Economics, p.22.
What Graff was suggesting was that marginal equivalences, achieved
through price adjustments in the freely competitive markets, would eventually
lead to both maximum efficiency in the use of resources, and maximum welfare
of the participants, given an existing distribution of income.
The key economic piece of information that all consumers and firms regard
in making their decisions is price. It is the price of goods and services,
freely determined in the market exchanges between sovereign consumers and
profit maximizing firms that allows the adjustments of marginal rates of
transformation of resources into finished products, and then the consumption
of products into consumer satisfaction.
In the absence of government intervention in market exchanges, or monopoly
power in production, economic welfare theory predicts that participants
in the free market price system will seek and find maximum welfare for
all. The ultimate outcome of maximum welfare is best viewed with the help
of an economic diagram, reproduced on page 28 of the Appendix, that describes
how the participants in the free market interact with each other.
The diagram and the accompanying narrative are taken from an introductory
economics text by James Quirk and Rubin Saposnik, Introduction To General
Equilibrium Theory and Welfare Economics (McGraw Hill 1968) pp 27-36. The
diagram is useful for two reasons. First, it shows the general concept
of how an expanding production possibilities frontier is related to improved
welfare for producers and consumers. Second, it supports the assertion
that industrial recruitment incentives create perverse economic welfare
outcomes as a result of government intervention in the free market price
system.
The provision of industrial recruitment incentives acts as a price
subsidy to a specific firm selected by the government over any other firm
that may also make an investment under conditions of consumer sovereignty
and free market exchanges. When government intervenes in the market, as
in the case of industrial recruitment incentives, the ratio of net return
to capital is not the same for all savers and investors.
In this less-than-perfectly competitive market, the ideal theoretical
benefits of welfare maximization predicted by economic theory fail to occur.
Some firms benefit from the government intervention, while other firms
do not. Some consumers benefit from the government intervention, while
other, morally equivalent, citizens do not benefit. The government, not
the autonomous workings of the free market, determines who will win and
who will lose as a result of the use of the incentives.
Once the process of government incentive price subsidies begins, a number
of perverse market adjustments and consequences result, none of which has
a market-based resolution that would restore price as the key information
variable. The process of private investment decision-making becomes more
and more politicized and arbitrary, and less and less autonomous.
In the first instance, the price subsidy distorts the rate of return
throughout the capital markets that all firms use to judge the profitability
of investment alternatives. The government incentive acts to drop the real
rate of return of the recipient firm, compared to the prevailing market
rate of return for non-recipients, thus making socially inefficient investments
possible and more likely to recur.
Second, in the absence of a market-derived, commonly observed rate of
return, the socially optimal rate of investment does not equal the time
preferences of consumers for present versus future rates of consumption.
It becomes more rational for nonrecipient firms, who are not initially
blessed by government largesse, to begin searching for incentive handouts
and focusing their attention on obtaining easy government revenues, not
on obtaining the more difficult market derived profits. The rate of investment
declines for profitable enterprises that would be undertaken, thus adversely
affecting consumption in future periods.
The government handouts serve not only to produce socially inefficient
investments that would not otherwise be undertaken in the competitive market,
but also serves to distort the rate of investment required to produce optimal
levels of welfare in the future. This process eventually leaves the government
as the sole arbitrary force in determining both the socially optimal rate
of investment for the future and the type and location of investments that
will occur.
Third, the government subsidy is designed, according to its proponents
to create "more jobs." It is actually the derived stream of income from
the "more jobs" that the proponents should be stressing, because it is
income that allows consumption in the free market. This act of consumption
is linked to welfare maximization of consumers.
The "more jobs" provided by incentives produces a stream of income that
may or may not have been present in the economy prior to the incentive.
If "more jobs" is created when "more jobs" is not required because of full
employment, then the government incentive serves to squeeze other more
socially beneficial investments and capital out of the market.
In other words, the government not only determines who wins and loses,
but its action with the incentive has a secondary effect of squeezing other
investment alternatives out of the market. It is not, then, rational for
non-recipient firms to either commit capital to investments that would
compete with the government subsidized investments, or to invest for future
time periods, given capacity constraints in the labor market.
Fourth, while dropping the real rate of return for the recipient firms,
the government lowers the risk of failure for the firm compared to the
higher risk levels faced by non-recipient firms. The subsidized firm has
a lower level of commitment to the success or failure of the investment
because less of the firm's own capital is invested. The incentive acts
as an insurance policy for the recipient firm. If and when things go bad,
or if and when some other state offers a better incentive deal, the firm
has less at risk in abandoning the project.
This type of government intervention becomes self-perpetuating. If it
took a government subsidy to recruit the firm to the location, and that
subsidy helps promote a lack of commitment to the investment, then it seems
likely that it will take more incentives to keep the firm from leaving.
Unless the government continually meets the competitive bids of other states,
the firm, basing its decisions on the political process, and not the market
rate of return or market rate of risk, will continually extract greater
incentives from the government agent in order to stay.
There is some evidence that firms are using this ploy to extract higher
incentives to remain in North Carolina. In "Goodyear's flip side a downside",
Stella Eiselle of the Charlotte Observer reported on August 10, 1995, that
Goodyear Tire and Rubber received $180,000 from the Governor's Industrial
Recruitment Competitive Fund to locate a plant in Statesville, without
informing government agents that the move to Statesville would mean shutting
down its plant in Charlotte. When informed of this information oversight,
a representative of the state declared, "I do wish that we had known (of
the closures). It's just not relevant...We're still thrilled that we provided
a $180,000 grant."
Fifth, over a period of time, the price subsidy to the recipient firm
distorts the adjustment relationship between returns to capital and returns
to labor that are expected to occur in a competitive market. In perfect
competitive equilibrium the marginal equivalency of profits to consumer
satisfaction is reached after a series of price-based exchanges. By providing
the incentive, the government allows higher nominal returns to be achieved
by the firm, vis-a-vis non-recipient firms than is consistent with the
payment of lower wages that prevail in the labor market, although the return
appears lower when the government's subsidy is counted as part of the recipient
firm's investment.
Given a highly automated or technologically advanced production process,
the subsidized firm can match low-skilled, low-wage labor to the equipment,
and take the incentive as unearned profits. The repeated use of the incentives
over time by the government serves to erect a permanent barrier to the
expected rise in wages that would occur in a competitive market by distorting
the equilibrium of the adjustment process in returns to capital and labor.
There is some evidence that this government intervention explains the
historical persistence of low wages and low incomes of North Carolina workers.
In its October 1977 analysis of jobs recruited to North Carolina, the North
Carolina Department of Administration found that since 1970, the mix of
new jobs in each class of indices had on average paid less than existing
North Carolina jobs but because more jobs overall were in the high wage/fast
growth and high wage/low growth categories, the average wages for all manufacturing
continues to increase." "A Balanced Growth Policy for North Carolina" (Appalachian
Regional Commission Investment Policy for F Y 1978) p. VI-22.
This tends to support the assertion that incentives distort the relationship
between returns to labor and returns to capital. The government which provides
the incentive is assisting in the process of permanently locking North
Carolina's manufacturing workers in the lower wage labor market. The subsidy
acts to skew the market's ability to seek maximum welfare outcome between
capital and labor that macroeconomic theory predicts will occur at equilibrium.
One of the outcomes of this incentive-driven investment process is that
workers in the lower wage firms, in the aggregate, will never achieve the
level of discretionary savings that are sufficient to initiate the process
of self-renewing capital investments. Not only does government intervention
distort the competitive relationship between capital and labor, incentives
act to make this discriminatory relationship a permanent feature of North
Carolina's economic development process. In the words of Adam Smith, the
government agent who attempts this feat has engaged in "folly" and "presumption".
Supra at 423.
The distortion in returns to capital and labor creates a capital gap
between the amount of capital needed to maintain an economic growth rate
and the capital available for investment from the existing economy. Greater
and greater levels of government intervention in the form of incentives
are required to overcome the cumulative effects of this capital gap in
investment funds to sustain growth. If the subsidized firms export their
profits, and if workers are too poor to save, then the most likely source
of capital to overcome the gap is tax revenues.
In the earlier years of North Carolina's industrial recruitment history
the capital gap was not significant and could be readily met by infusions
of incentives from private sources. As the capital gap worsened industrial
recruiters began searching for new sources of revenue.
When the government uses property taxes, as in the case of Winston-Salem
or Forsyth County, or income taxes, as in the case of the Governor's Incentive
Fund, it violates the constitutional prohibition on the use of public funds
for private purposes. Tax dollars are given to private firms in an economic
process that acts to perpetuate both the lack of domestic surplus capital
and to permanently depress the economic welfare of its citizens.
The source of revenue for incentives has shifted in recent years from
private sources to public sources. This Court is asked to determine whether
any taxpayer should be forced to support an economic policy whose major
economic outcome is a government-induced barrier to the higher wages and
incomes only optimized in a free competitive market.
SECTION III. POLITICAL FAVORITISM IS AN INHERENT BYPRODUCT
OF THE SYSTEM OF GOVERNMENT RECRUITMENT INCENTIVES
In his 1995 book, Trust, social scientist Francis Fukuyama writes:
"In Europe and Latin America, by contrast, governments have found it
almost impossible politically to dismantle sunset industries. Rather than
helping to accelerate their decline, European governments nationalized
failing industries like coal, steel, and automobiles, in the vain hope
that state subsidies would make them internationally competitive. While
paying lip-service to the need to shift resources into more modern sectors,
the very democratic character of European governments led them to give
in to political pressures to direct government subsidies to older industries,
often at tremendous cost to taxpayers. There is no doubt that something
similar would happen in the Unites States if the government got into the
business of handing out "competitiveness" subsidies. Congress, responding
to interest group pressure, could be relied on to declare that industries
like shoes and textiles, rather than aerospace and semiconductors, were
"strategic" and thus worthy of government subsidization. Even in the hightech
area, older technologies are likely to carry more political clout than
ones under development. Thus, the most compelling argument against an industrial
policy for the United States is not an economic one at all but is related
to the character of American democracy." Id. at 16.
This brief does not argue that the Winston-Salem/Forsyth County
situation involves actual political favoritism. What it argues is that
the process of government recruitment incentives inherently creates a condition
in which favoritism (i.e., invidious discrimination) is inevitable.
When government selects the recipients of incentives it overrides consumer
sovereignty of free choice in the market place. The government substitutes
its own judgement in place of the collective, autonomous, free decisions
of the market on what type of goods and services should be produced. Any
such judgment by the government is inherently arbitrary and capricious
because it is neither bounded by legislation nor constitutional constraints,
nor is it available to all those similarly situated.
The government has no way of determining the social advantages of its
decision. But its decision creates winners and losers, many of whom cannot
be identified in advance. The power to decide who gets the incentive is
perfectly symmetrical to a power to deny an incentive, or to provide a
disincentive to a private firm considering location in North Carolina.
The North Carolina Center for Public Policy Research examined this element
of industrial recruitment in a 1985 study titled "Phantom Jobs--New Studies
Find Department of Commerce Data to be Misleading." This study found that
about 39% of the new jobs publicly promised by private firms from 1978
to 1984 never materialized. The report concluded "We do believe that the
deception of economic growth in terms of jobs available is significant
to the citizens of North Carolina." Bill Finger, "Phantom Jobs", N.C. Insight,
Volume 8, No. 3-4 (April 1986) pp. 50-52.
In another study on the phenomena of phantom jobs, researchers from
North Carolina State University reviewed the period from 1971 to 1980.
They found that only 47% of the announced new jobs in that time period
had actually materialized by 1986. Id. AT 50.
Even if jobs could be guaranteed, industrial incentives to secure them
are poor economic policy. In addition to the distortion of market equilibrium
these incentives cause economic waste. James M. Buchanan explained in Constitutional
Economics at page 39.
"What is rent-seeking?
The basic notion is a very simple one and once again it represents the
extension of standard price theory to politics. From price theory we learn
that profits tend to be equalised by the flow of investments among prospects.
The existence or emergence of an opportunity for differentially high profits
will attract investment until returns are equalised with those generally
available in the economy. What should we predict, therefore, when politics
creates profit opportunities or rents? Investment will be attracted toward
the prospects that seem favourable and, if output' cannot expand as in
the standard market adjustment, we should predict that investment will
take the form of attempts to secure access to the scarcity rents. When
the state licenses an occupation, when it assigns import or export quotas,
when it allocates TV spectra, when it adopts land-use planning, when it
employs functionaries at above-market wages and salaries, we can expect
resource waste in investments to secure the favoured plums.
Demands for money rents are elastic. The state cannot readily give money
away' even if it might desire to do so. The rent-seeking analysis can be
applied to many activities of the modern state, including the making of
money transfers to specified classes of recipients. If mothers with dependent
children are granted payments for being mothers, we can predict that we
shall soon have more such mothers. If the unemployed are offered higher
payments, we predict that the number of unemployed will increase. Or, if
access to membership in recipient classes is arbitrarily restricted, we
predict that there will be wasteful investment in rent-seeking. As the
expansion of modern government offers more opportunities for rents, we
must expect that the utility-maximising behaviour of individuals will lead
them to waste more and more resources in trying to secure the rents' or
profits' promised by government."
The concept of economic waste caused by "rent-seeking" is further explored
by Gordon Tullock in "The Backward Society: Static Inefficiency, Rent-Seeking,
and the Rule of Law" found in The Theory of Public Choice-II. ed.
James M. Buchanan and Robert D. Tollison (University of Michigan Press
1984) and found in the Appendix.
A principle beneficial effect of the free market system is to minimize
the need for politicized control over economic decisions thus preserving
the character of American democracy. Fukuyama, supra at 16. Our constitution
prohibits the routine intrusion of government upon the everyday affairs
of the citizen. These two systems (free market and constitutional), working
in tandem, create for the individual citizen great opportunities for achieving
wealth and political freedom.
The intervention of the government using tax dollars in schemes that
create financial benefits for a private firm is directly contrary to the
provisions of North Carolina's constitution prohibiting exclusive emoluments
and privileges and prohibiting expenditures for other than public purposes.
John Locke Foundation, Inc. asks this Court to declare that G.S. 158-7.1
on its face (and as applied in the Winston-Salem/Forsyth County context)
contravenes these constitutional prohibitions.
Conclusion
Cash (and other targeted) incentives provided by government by private
firms do not promote the common good. They do not serve a public purpose.
By definition they are exclusive emoluments or privileges.
The Trial Court was correct in holding that G.S. 158-7.1 which authorizes
these incentives violates basic constitutional safeguards.
Respectfully submitted this the 4th day of January 1996.
STAM, FORDHAM & DANCHI, P.A.
By:
[signature]
Paul Stam, Jr.
Attorney for John Locke Foundation, Inc. P.O. Box 1600
Apex, North Carolina 27502
(919) 362-8873
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