Enforcing the January 6 Committee’s Subpoenas

The House Select Committee investigating the January 6 attack on the Capitol is seeking to compel the testimony of Trump administration officials. Former White House chief of staff Mark Meadows and Pentagon official Kash Patel have been subpoenaed and are reportedly “engaging” with the committee. Jeffrey Clark, a Trump Justice Department official who played a key role in internal discussions about potential attempts to overturn the election results, was recently subpoenaed as well. Former Trump advisor Steve Bannon refused to comply with the committee’s subpoena, citing a demand from Trump that he resist on the grounds of executive privilege. In response, the committee is moving to refer Bannon to the Justice Department for prosecution for Contempt of Congress.

Congress has three main tools for enforcing its subpoenas: criminal contempt, inherent contempt, and civil litigation. Each has its strengths and weaknesses. As we saw during the previous administration, subpoenaed witnesses can easily run out the clock with protracted court battles. For example, when the House subpoenaed former White House Counsel Don McGahn in 2019 to testify about Trump’s attempts to interfere with the Mueller investigation, court battles over that subpoena lasted for two years — pushing McGahn’s eventual testimony into 2021 and past the presidential election.

With the January 6 Committee, there’s a real concern that witnesses may be able to delay any testimony until after the 2022 midterm elections. And if the Republicans take back the House in those elections, they will probably drop the investigation so the testimony never happens at all.

If the Select Committee wants to get to the bottom of what happened on January 6 before it runs out of time, it needs to be much more aggressive about responding to stonewalling from Trump and his former aides. The criminal referral of Bannon is a good step – but it’s only a start. Congress needs to be moving forward on multiple fronts to enforce its subpoenas.

Coercion vs. Punishment

If a witness defies a Congressional subpoena, different remedies pursued by Congress will have different consequences. Sometimes contempt is about coercion and sometimes it’s about punishment.

Civil contempt is about coercion. If I refuse a court order to testify, for example, the judge can find me in contempt. She may put me in jail, or impose a daily fine. The purpose is to coerce my compliance with the court’s order. Lawyers often say of this kind of contempt that the witness holds the keys to his own jail cell. I can purge myself of the contempt (and gain my freedom or stop the fines) by agreeing to testify. Civil contempt is not a criminal conviction, and once the witness complies (or the contempt otherwise lapses because, for example, the relevant proceeding ends) there are no further consequences.

A prosecution for criminal contempt, by contrast, is primarily about punishment. If convicted I may be fined and/or sent to prison. I will have a criminal conviction on my record, with all the collateral consequences that entails. But the prosecution itself does not compel me to comply with the original subpoena. It may take place even long after the relevant proceeding has ended and my compliance is no longer possible. And if I were convicted and then decided to comply with the original subpoena, my conviction would still stand – I cannot purge myself of the criminal contempt.

Of course, the threat of a criminal prosecution might coerce a reluctant witness into compliance. And seeing others prosecuted might persuade witnesses that they should comply. But coercing compliance is not a part of the criminal remedy itself.

Steve Bannon
Steve Bannon

Bannon and Criminal Contempt of Congress

That brings us to Steve Bannon. As of this writing, the House is planning to pass a resolution referring Bannon for prosecution for criminal contempt of Congress. The contempt of Congress statute, 2 U.S.C. § 192, provides in part:

Every person who having been summoned as a witness by the authority of either House of Congress to give testimony or to produce papers upon any matter under inquiry before either House . . . willfully makes default, or who, having appeared, refuses to answer any question pertinent to the question under inquiry, shall be deemed guilty of a misdemeanor, punishable by a fine of not more than $1,000 nor less than $100 and imprisonment in a common jail for not less than one month nor more than twelve months.

A companion statute, 2 U.S.C. § 194, provides that if the full House finds a witness in contempt, the matter will be referred to the U.S. Attorney for the District of Columbia, “whose duty it shall be to bring the matter before the grand jury for its action.”

As I discussed in this post, this statute has proven to be relatively ineffective. In most cases, attempts to apply it have involved the House referring a contempt citation of an administration official to the U.S. Attorney’s Office that is part of that same administration. Those U.S. Attorneys have been reluctant to prosecute, particularly if the administration is claiming that resistance to the subpoena is justified by executive privilege. Administrations of both parties have taken the position that, despite the “duty” language, the Department of Justice still has discretion over whether to prosecute.

Recent examples of administration officials referred for contempt include IRS official Lois Lerner and attorney general Eric Holder during the Obama administration, and attorney general Bill Barr and commerce secretary Wilbur Ross during the Trump administration. None of these cases resulted in a prosecution by the U.S. Attorney who was part of the same administration. During the Reagan administration, EPA administrator Anne Gorsuch (mother of the current Supreme Court justice – small world) was referred for contempt by the Democratic House to the Reagan-appointed U.S. Attorney, who also declined to prosecute.

A Strong Candidate for Criminal Contempt

Bannon’s case is different. He obviously is not a member of the Biden administration, so the Department of Justice would not face that conflict. Although Trump has claimed that some records sought by the January 6 committee are covered by executive privilege, the Biden administration has declined to assert that privilege. Even if there were potential privilege claims in connection with some former Trump officials, Bannon was not a member of the Trump administration after 2017. There is no colorable claim of executive privilege at all when it comes to Bannon and the events of January 6. And finally, although claiming privilege might allow you to decline to answer certain questions, it doesn’t excuse failing to show up to the hearing at all, as Bannon did.

The Bannon case thus is teed up better than any case in recent memory for an effective use of the criminal Contempt of Congress statute. There appears to be no good reason why the U.S. Attorney’s office would not proceed. And the case would be relatively simple to indict – you could probably do the grand jury presentation in an afternoon.

But recall that, as discussed above, the prosecution would not result in compelling Bannon to appear before the committee and testify or produce documents. It would merely punish him for his defiance of the subpoena. So although punishing Bannon might be completely appropriate, it does not serve the committee’s ultimate goal of determining what happened on January 6.

In addition, the penalties for Contempt of Congress are not very hefty – a maximum one year in jail and $1,000 fine. Bannon might decide it’s worth it to risk a few months in jail in order to be hailed as a martyr in Trump world.

The bottom line is that although Bannon’s prosecution seems entirely appropriate, Congress needs to pursue other remedies as well if it wants to get his testimony.

Congress’s Inherent Contempt Power

Since the early 1800s the Supreme Court has recognized that Congress has an inherent contempt power, similar to that of a court, to punish those who defy its orders. Using this power Congress can fine a witness, or order the witness detained, until the witness complies with a subpoena. As with civil contempt of court, the purpose is compulsion, not punishment – the witness could purge himself of the contempt by agreeing to comply with the subpoena.

In theory, then, when faced with a witness like Bannon who defies a subpoena, Congress could find him in contempt, impose fines, or even send the House Sergeant at Arms to take him into custody. In the current polarized political environment it may not be a good idea to start down the road of Congress unilaterally locking up political opponents for contempt. But it could impose escalating fines until the contemnor agrees to comply.

Congress’s inherent contempt power has long been dormant; the last time it was used was in the 1930s during the Hoover administration. This is probably because the process has been deemed too cumbersome and unwieldy, requiring Congress to get involved in what are essentially trial proceedings. But the option remains, if Congress chooses to revive it.

There currently is no procedural framework in place for Congress to pursue a contempt resolution. But this could be fixed quickly in the House by simply amending the House rules to spell out the process. This would not require legislation and therefore would not be subject to a potential Senate filibuster.

Representative Ted Lieu has a proposal to do just that, the “Congressional Inherent Contempt Resolution.” It provides a process for negotiating with witnesses who refuse to comply with a subpoena, holding hearings where the witness could be represented by counsel, preparing reports, having a committee vote on a contempt resolution, and then presenting that resolution to the full House. Under Lieu’s proposal, if the full House approved the contempt resolution the witness could be fined a maximum of $100,000.

The Problems with Inherent Contempt

Although Lieu’s resolution would be useful for putting a process in place, it also highlights the key problem with inherent contempt: it’s slow and cumbersome. If a witness in court is found in contempt, the judge can immediately order the marshal to take the witness into custody or start imposing fines. There is an instant coercive effect.

With inherent contempt in Congress, however, there are going to be resolutions, hearings, committee debates, reports, and multiple votes. Nothing about that process is going to move swiftly. It lacks the immediate coercive effect that makes contempt of court so effective.

The other problem with the inherent contempt of Congress process, at least when it comes to claims of executive privilege, is that it relies on Congress itself to decide the merits of those claims. But Congress is an interested party in the legal fights with the executive branch over the privilege. No one gets to be the judge and jury in their own case.

All of this means that any attempt by Congress to exercise its inherent contempt power will almost certainly end up in court. The subpoenaed party will ask a judge to intervene to stay the Congressional proceedings and decide claims of privilege, and will mount legal challenges to any fines or proposed detention.

A key advantage of inherent contempt over a referral for criminal contempt is that Congress is not dependent on the executive branch to decide whether to pursue the case. It puts Congress back in control of its own contempt process. That alone may be reason enough to bring it back.

But even if Congress does resurrect inherent contempt, it seems inevitable that any attempts to use that power ultimately will be resolved in the courts, not on the floor of Congress. And if you are going to end up in court anyway, it would save a lot of time just to go there in the first place.

Civil Litigation to Enforce the Subpoena

The third way for Congress to enforce a subpoena is to file a civil lawsuit seeking to compel compliance. For example, when Trump White House counsel Don McGahn refused to testify before Congress based on Trump’s claim of “absolute immunity” from testimony for his officials, Congress filed a lawsuit asking the courts to rule there was no such immunity and ordering McGahn to testify.

If a civil lawsuit to enforce a subpoena is successful, then compulsion of the witness comes back into play. A court may order the witness to comply with the subpoena. If the witness continues to refuse, then contempt of court – rather than contempt of Congress – is an option. The court could order the witness detained to coerce compliance, or could impose daily fines until the witness obeys the court’s order.

The biggest drawback to this approach, as evidenced by the McGahn case, is delay. Court proceedings and appeals can easily stretch over a year or more. It’s relatively easy for a witness to stall until after the Congress that issued the subpoena has expired. In this case, if the House changes hands in 2022, that could result in the entire dispute simply going away.

The best way to enable Congress to enforce its subpoenas would be to create a fast-track process for such lawsuits to proceed through the courts. Congress could enact legislation to require the courts to establish procedures for expedited handling of fights over Congressional subpoenas. Proposed legislation pending in Congress called “The Protecting our Democracy Act” includes establishing such a fast-track process. Of course, passing that bill would require action by both the House and the Senate – including overcoming any Senate filibuster. But who knows, maybe enough Republicans could be convinced to support such legislation, if they are thinking forward to when they will control Congress again.

Legislation is not necessarily required. Courts can fast-track these cases on their own, if they have the will. The judges set the schedule. During the Watergate era we went from a subpoena for Nixon’s Oval Office tapes to a Supreme Court decision upholding that subpoena in the space of only a few months. But recent history indicates that doesn’t usually happen. In the absence of legislation requiring a fast-track process, it’s all up to the judges. The judiciary could play a positive role here, but of course there’s no guarantee that it will.

Lt. Col. Oliver North

Fifth Amendment Issues

Even if a court ruled that Bannon (or another witness) could not rely on executive privilege, he still might end up not testifying. Given the likelihood that crimes were committed in connection with organizing the January 6 riot, Bannon and others might invoke the Fifth Amendment privilege against self-incrimination.

Congress does have the power to immunize witnesses and compel them to testify. It would probably be reluctant to do so, in order to avoid an Oliver North situation. In 1987, over the objections of independent counsel Lawrence Walsh, Congress immunized North to compel him to testify about the Iran-Contra scandal. That resulted in his later criminal convictions being reversed when the D.C. Circuit ruled that prosecutors could not prove his immunized testimony did not influence his trial. Congress was left with egg on its face, having torpedoed the prosecution of one of the main Iran-Contra bad actors.

Congress would need to tread very carefully here. It could consult with the Department of Justice to see whether there was any reasonable likelihood of a criminal prosecution. If DOJ had no objection, then immunizing witnesses might be appropriate. But absent consent from DOJ, Congress will likely — and rightly — avoid any grants of immunity.


The best approach for Congress to follow would be to pursue both fast-track civil litigation to enforce its subpoenas and referrals for criminal contempt where appropriate. The criminal proceedings can serve to punish those who defy a subpoena and to deter others from doing so, while the civil litigation seeks to compel compliance. In the (likely) absence of fast-track legislation, attorneys for the House need to impress upon judges the need for speed. Members of Congress, the public and the press also could join in calls for expedited review. It’s not a great solution, but for now it is the least-bad option.

There is an overwhelming national interest in determining exactly what led to the January 6 riot so that similar threats to our democracy can be avoided in the future. Maybe enough judges can be persuaded that they need to move quickly.

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The Protecting Our Democracy Act

Last week House Democrats introduced new legislation, the “Protecting Our Democracy Act,” described as “a landmark reforms package that will prevent future presidential abuses, restore our system of checks and balances, strengthen accountability and transparency, and protect our elections.” The need for such reforms has become apparent in light of the abuses by the Trump administration over the past four years. Trump’s actions — including stonewalling Congressional investigations, firing Inspectors General, and interfering in criminal investigations — have highlighted how much the proper functioning of the executive branch has relied on unwritten norms without legal force to back them up. The legislation seeks to provide some new legal muscle to enforce those norms.

Just as in the post-Watergate era, legislators in the post-Trump era must take steps to ensure that the abuses by this administration are not repeated. The bill has no chance of passage until after the election, and only then if the Democrats succeed in taking the Senate. But overall it’s a solid package of much-needed reforms, and the country would benefit from its passage.

Roger Stone
Roger Stone

Preventing Abuse of the Pardon Power

Title I of the Act contains reforms designed to prevent the abuse of the pardon power by a president, with “pardon power” broadly defined to include not only granting pardons but also the commutation of sentences. Pardon reform is tricky, because the Constitution gives the president broad authority to grant clemency. Congress probably can’t simply prohibit particular kinds of pardons. Instead, the legislation seeks to increase transparency surrounding pardons and to clarify that in some circumstances granting a pardon may run afoul of other criminal laws.

President Trump’s use and threatened use of the pardon power has led to several different controversies. During the Mueller investigation, there were reports that attorneys for the president may have dangled the prospect of a pardon before potential witnesses such as Paul Manafort and Michael Flynn. The implication was that they should refuse to cooperate against the president and if they got into any trouble, Trump would pardon them. More recently, when Trump confidant Roger Stone was convicted for obstruction of justice and lying to Congress about his role as an intermediary between the Trump campaign and Wikileaks concerning stolen Democratic emails, Trump commuted Stone’s sentence rather than allow him to report to prison.

The first section of this Act requires that for pardons involving certain “covered offenses” the Attorney General must provide to Congress within thirty days the Department of Justice investigative materials related to the offense and consideration of the pardon. The president must also produce to Congress within the same time period any materials produced or obtained by the White House pertaining to the pardon. “Covered offenses” under this section include offenses arising from investigations where the president or one of his/her relatives is a target, subject or witness, offenses involving refusal to testify or provide documents to Congress, and crimes of obstruction of justice, false statements, or perjury related to Congressional proceedings or investigations.

This first section is primarily about transparency. Again, Congress can’t prohibit the president from pardoning a family member, or from commuting the sentence of someone like Roger Stone. But the Act seeks to ensure that Congress and the public will at least receive information related to the grant of any such pardons. Of course, this depends on compliance by the DOJ and White House; with the current administration, for example, we might expect them to resist compliance with at least some of these requirements, perhaps by claiming executive privilege over the pardon deliberations.

Pardons and Bribery

The Act also clarifies that federal bribery law may apply to granting pardons. It specifies that the definition of “public official” under 18 U.S.C. 201, the primary federal bribery law, includes the president and vice president. It further specifies that the grant of a pardon or other clemency could serve as an “official act” under that statute, and that the grant of clemency also could constitute a “thing of value” under the statute in a case involving bribery of a witness.

Once again, these changes would not outlaw a president pardoning a witness against himself. But they seek to clarify that, in such a case, the act of granting the pardon may violate federal bribery law, even if the pardon itself stands. These changes are primarily clarifications, not new requirements. As I wrote here, I believe under the existing law it’s already true that granting a pardon is an “official act” and could be a “thing of value,” and that corrupt pardons could be prosecuted as bribery. And it’s already generally accepted that the bribery statute applies to the president. These changes would simply make these things explicit, and there’s no harm in that even if it’s not strictly necessary.

No Self-Pardons: The final section of this portion of the Act provides that a president can’t pardon himself and that such a pardon will have no legal effect. This section is of dubious constitutionality. Whether a president could self-pardon has never been settled, but it is almost certainly a constitutional question for the Supreme Court if we ever get to that point. It’s likely not something that Congress can control by statute.

The “No President Is Above the Law” Act

The next portion of the Protecting Our Democracy Act is about statutes of limitations. It provides that the limitations period for federal crimes will be tolled – stop running – during the time a president and vice-president are in office. This would apply to crimes committed before they took office, as well as to crimes committed while in office. The limitations time would start to run again once they left office.

The need for this act stems from the current Department of Justice opinion that a sitting president may not be indicted while in office. This is just an internal opinion, and has never been tested by a court. But it is current DOJ policy and special counsel Robert Mueller, for example, felt himself bound by it. Once a president leaves office, it’s clear he or she is then subject to prosecution.

Most federal crimes have a statute of limitations of five years. If a president committed crimes in order to win the election and then was in office for two terms, he or she could effectively “run out the clock” on those crimes. The same would be true for crimes committed while in office, if they were more than five years old when the president left office. If the president is not impeached and removed from office before the limitations period expires, and if the president can’t be indicted while in office, then he/she effectively would be immune from prosecution. This previously unlikely hypothetical has taken on real significance with the prospect of president Trump possibly winning a second term.

This Act will ensure that while the president and vice-president are in office, the statute of limitations clock stops running. This is a much-needed reform and is well within Congress’s power. As the name suggests, it will ensure that the president is not above the law and cannot avoid criminal responsibility merely by virtue of being in office.

Picture of the U.S. Constitution

Foreign and Domestic Emoluments Enforcement

The formerly obscure emoluments clauses of the Constitution have been front and center since before Trump was even sworn in. The foreign emoluments clause prevents federal officers from receiving presents or other things of value from foreign nations unless Congress provides its consent. The  domestic emoluments clause prohibits the president from receiving payments or gifts from the federal government or a state government. These anti-corruption provisions are designed to prevent conflicts of interest and divided loyalties in federal officials.

President Trump’s international business empire has raised grave concerns about potential violations of these clauses. For example, foreign governments may have granted favored tax or zoning treatments to properties owned by the Trump Organization in order to curry favor with the president.  Foreign delegations visiting Washington D.C. stay at the Trump Hotel, effectively putting money in the president’s pockets. Several lawsuits have been filed alleging emoluments clause violations, but they have sputtered through the courts for nearly four years and have raised difficult issues concerning proof of injury and who actually has standing to sue.

The Protecting Our Democracy Act seeks to put some enforcement teeth behind the constitutional provisions. The legislation basically repeats the constitutional prohibitions but goes on to provide that Congress may bring a civil action to enforce those prohibitions and that those lawsuits will be heard on an expedited basis. In other words, this Act gets around the constitutional standing issues related to enforcing the emoluments clauses by essentially repeating those prohibitions in a statute and providing that Congress has standing to enforce it. It also makes clear that the statutory prohibitions apply to the president and vice-president, in response to some academic debate over whether the constitutional language applies to those officers.

This too should be well within Congress’s power and seems like a useful reform. The Act also beefs up requirements under the Ethics in Government Act for public officials to disclose the receipt of any emoluments, and provides that the Office of Government Ethics and Office of Special Counsel may investigation any violations.

Enforcement of Congressional Subpoenas

A significant problem highlighted during the Trump administration has been the inability of Congress to enforce compliance with its subpoenas. Trump has routinely stonewalled Congress, refused to produce documents, and instructed members of his administration not to testify. During the impeachment investigation, for example, many key witnesses simply refused to show up, and the White House refused to supply subpoenaed documents. Congress can file a lawsuit to force compliance, but the court process can take many months. For example, the lawsuit seeking to compel former White House counsel Don McGahn to testify before the House about incidents detailed in the Mueller report is still working its way through the courts after a year and a half. It appears the administration will successfully run out the clock without McGahn ever testifying.

The bill seeks to remedy this problem. It first makes it clear that Congress has a right of action to sue to enforce its subpoenas, to clear up any lingering questions about standing that have plagued some of the subpoena lawsuits. It requires that such lawsuits be expedited as much as possible, and requires the judiciary to establish rules to ensure that happens. It provides financial penalties for failure to comply with a subpoena, and that those fines may not be paid by government agencies with taxpayer dollars.   

The Act also contains other rules to ensure compliance with subpoenas. One interesting section provides that a failure to comply with a Congressional subpoena may be referred to the D.C. Attorney General for prosecution for contempt, in which case the crime would be a misdemeanor. The current Contempt of Congress statute requires Congress to refer such a case to the D.C. U.S. Attorney. But that prosecutor works for the administration, and if the lawsuit is seeking to compel compliance by the administration that sets up a potential conflict of interest. Now in such a case Congress may seek enforcement by the local Attorney General instead.

The Act also makes clear that this legislation does not override or constrain any other authority that Congress already has to enforce its subpoenas. This would include the inherent contempt power: Congress’s ability to send out its Sergeant at Arms to arrest and detain those who fail to comply. Congress has been reluctant to invoke this power and has not used it for decades, but it is always lurking in the background.

William Barr
Attorney General William Barr

Security from Political Interference in Investigations

Since Watergate, there has been a strong norm that limits the communication and coordination between the White House and the Justice Department concerning ongoing investigations. This shields the administration of justice from even the appearance of political influence.  Trump and Attorney General Barr have demonstrated that this norm can easily be shredded by an administration indifferent to the damage it causes to the DOJ.  This DOJ has intervened in cases involving Trump allies such as Roger Stone and Michael Flynn, and has launched investigations, such as the probe into the origins of the Russia investigation, that appear to be designed to benefit the president politically. The politicization of the Justice Department may end up being the area where damage caused by this administration takes the greatest time to heal.

The Act seeks to at least shed some light on any such activities by requiring the Attorney General to keep a log of certain contacts between DOJ and the White House concerning ongoing investigations, and to provide that log to the DOJ Inspector General on a semi-annual basis.  The IG, in turn, can provide notice of any suspicious communications to Congress.

This provision too is limited in that it depends on voluntary compliance by the administration. A corrupt administration bent on politicizing the DOJ could simply refuse to enter relevant communications in the log. And we could probably expect claims of Executive Privilege as to at least some such communications. But this provision would at least give some legislative recognition to the vital importance of what, up until now, has simply been an executive branch policy.

Protecting Inspector General Independence

The independent Inspectors General who oversee the various federal agencies perform a critical role in rooting out corruption and ensuring compliance with federal law. President Trump has removed a number of Inspectors General, apparently in retaliation for investigations that may have led to exposing wrongdoing within his administration — in other words, for doing their jobs. The Act provides that an IG may be removed only for specific, limited causes, requires the administration to provide documentation to Congress explaining the reason for any removal, and clarifies the independence and powers of the IGs within the intelligence community.  

Red square in Moscow
Red Square in Moscow

Defending Elections Against Foreign Interference

This section is inspired, of course, by Russia’s interference in the 2016 election and efforts to assist the Trump campaign, which was well-documented by the Mueller report and by an even lengthier report by the bi-partisan Senate Intelligence Committee. After the election, we learned that although most campaign officials would understand it was improper to accept foreign assistance and that any offers of such assistance should be reported to the FBI, there was no law in place that required such reporting. Federal election law was also potentially ambiguous concerning whether accepting something like opposition research from a foreign government would violate the law.

The Act seeks to remedy those deficiencies by requiring campaigns and other political entities to report any efforts at foreign interference or contact by foreign agents to the Federal Election Commission and the FBI, and requiring the FBI to report such information to Congress. It provides criminal penalties for those who violate these requirements. The Act also clarifies that the Federal Elections Campaign Act prohibits accepting help such as opposition research, polling, and other non-public information from foreign actors, and provides criminal penalties for violating that prohibition.

Other Sections

Other portions of the bill include: 1) strengthened protections for whistleblowers; 2) increased restrictions on the Executive Branch’s ability to re-direct or refuse to spend money appropriated by Congress;  3) strengthened enforcement and penalties for the Hatch Act, which generally prohibits federal employees from engaging in improper partisan political activities (and which has been repeatedly ignored and violated by members of the Trump administration); 4) limits on the president’s ability to appoint acting heads of agencies, rather than permanent heads subject to Senate confirmation; and 5) strengthening Congressional oversight of presidential emergency declarations.


In the post-Trump era, there will be a compelling need for reform legislation to prevent some of the abuses we’ve seen over the past few years. This proposed legislation from the House is a great start. Let’s hope it is able to be re-introduced and passed by a new Congress after the first of the year.

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