What Is Police Brutality?

What Is Police Brutality

Police Brutality Defintion

Police brutality is the use of excessive and/or unnecessary force by police when dealing with civilians. While police brutality has a long history, dating back to the 1800s, it has become a common topic of discussion and controversy in recent years due to a surge of racially driven incidents, protests, and demonstrations. From defining police brutality to studying its historical and present-day context, let’s  examine this social issue starting with a simple question — what is police brutality?

Police in Gear

The Five Forms of Police Brutality

“Police brutality” is actually an umbrella term that encompasses five different forms of the offense: excessive use of force, wrongful search and seizure, racial discrimination, false arrest or wrongful imprisonment, and sexual harassment and abuse. 

Excessive Use of Force

While there are instances in which a police officer may need to use force to subdue an armed suspect or a suspect with a history of violence, the level of the encounter may be above what is needed to control the situation. When a police officer escalates an encounter with a level of force that is above what is necessary, it is police brutality.

 

An excessive use of force comes in many different forms including (but not limited to) beatings with batons, unnecessary use of tasers, firearms use, nerve gases, pepper sprays, and improper or unsanctioned holds and takedowns. 

 

Some of these measures, such as baton and taser use, are employed to control a violent situation but can end up causing serious injury and potentially death when used excessively. Batons can fracture bones, damage internal organs, and injury a spinal cord. Tasers, while typically less damaging, can also cause serious injuries from falls (after taser deployment) and even heart attacks due to the electricity delivered to the suspect by the device.

 

Wrongful Search and Seizure

Police Tape Police Brutality

In accordance with The Fourth Amendment, a police officer must have probable cause to conduct a search of a suspect or their property. The Amendment states:

 

“The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.”

 

With this protection in place, citizens are shielded against arbitrary searches and seizures. Typically, a police officer must first secure a warrant by presenting a probable cause to a judge before enacting any searches. This type of warrant, when secured, allows a police officer to search specific locations or for specific items.

 

There are, however, situations in which a police officer is able to conduct a search without securing a warrant first. If a suspect has already been arrested — lawfully — for a crime, the police are entitled to enter and search the suspect’s home without explicit permission. 

Wrongful Search and Seizure Police Brutality

Racial Discrimination

Racial discrimination has been at the forefront of the police brutality discussion in recent years due to several high-profile incidents involving violence against people of color. Although police officers are tasked with protecting and serving all citizens regardless of race, racial biases have been at the core of many cases of police brutality. These biases are rooted in historical racism, something we’ll explore shortly.

 

To illustrate how prevalent racial discrimination is in law enforcement matters, data has been collected by Mapping Police Violence. According to the organization’s data for 2020, black people in particular are more likely to be killed by police, more likely to be unarmed at the time of the killing, and less likely to be threatening someone at the time of the killing. We’ll explore these statistics more later.

 

False Arrest or Wrongful Imprisonment 

False Arrest Police Brutality

Much like protection against wrongful search and seizure, the Fourth Amendment also protects against arrest and imprisonment without a warrant or probable cause. Arresting an individual without obtaining a warrant first or detaining a person without any evidence can result in a situation of wrongful arrest. These offenses can violate federal civil rights, state, and common laws.

 

The term “probable cause” is important to understand in many of these forms of police brutality. According to Cornell Law School, the explanation of probable cause (and matters pertaining to it) are as follows:

 

“…a requirement found in the Fourth Amendment that must usually be met before police make an arrest, conduct a search, or receive a warrant. Courts usually find probable cause when there is a reasonable basis for believing that a crime may have been committed (for an arrest) or when evidence of the crime is present in the place to be searched (for a search). Under exigent circumstances, probable cause can also justify a warrantless search or seizure. Persons arrested without a warrant are required to be brought before a competent authority shortly after the arrest for a prompt judicial determination of probable cause.”

 

This presents an overview of probable cause, but it’s important to note that the exact definition as determined by a court can oftentimes be fluid — often adopting a broad and flexible definition in lieu of a strict set of legal parameters.

 

Sexual Harassment and Abuse

Sexual harassment or abuse by a police officer against an individual in custody is a form of police brutality. A common thread through these instances of police brutality is the power dynamic of an officer and a civilian. This struggle is summed up by a quote from Judge Matthew J. Crehan, a sentencing judge in Cincinnati who presided over a sexual abuse case involving a police officer:

 

“He was a police officer and she felt she had to do what she was told…That’s especially true for someone who has been caught in a compromising situation.” Judge Matthew J. Crehan, sentencing judge.

 

While there is no government-run database of sexual harassment and abuse by police officers, several organizations have compiled data on the extent and trends of the abuse throughout the years:

  • A 2003 study by the Police Professionalism Initiative found 40% of reported cases of sexual harassment and abuse by police officers involved teenagers 
  • A 2015 investigation by the Associated Press found around 1,000 officers lost their jobs over a six-year period for incidents of rape, sodomy, and other sex crimes including possession of child pornography and — most applicably to this examination of police brutality — propositioning citizens while on duty
  • A 2010 study by the Cato Institute found more citizens complained about sexual harassment by police officers more than any other issue of police wrongdoing other than excessive force
  • A database created by The Buffalo News found a law enforcement official was caught in an incident of sexual harassment or abuse at least every five days from 2005 to 2015 

 

Forms of Police Brutality Recap

Firearm Police Brutality Stats

While the most apparent type of police brutality comes in the form of physical violence, there are five main forms of the offense:

 

  • Excessive Use of Force: Unnecessary and excessive use of methods of control may constitute as excessive use of force. This includes (but is not limited to) batons, tasers, firearms, nerve gases, pepper sprays, and unsanctioned holds and takedowns.

 

  • Wrongful Search and Seizure: Police officers typically must secure a warrant before searching a premise or seizing any possessions. When a warrant isn’t obtained, an individual’s Fourth Amendment rights may be violated.

 

  • Racial Discrimination: Police officers have the duty of protecting and serving all individuals regardless of race. When racial biases affect an officer’s actions, it can potentially lead to an instance of racial discrimination.

 

  • False Arrest and Wrongful Imprisonment: The Fourth Amendment protects individuals against arbitrary arrests and detainments. This form of police brutality occurs when these expectations are infringed.
  • Sexual Harassment and Abuse: This form of police brutality includes any type of sexual harassment and abuse (physical or verbal) by a police officer. These situations often involve an officer taking advantage of the power dynamic between the police and civilians.

 

 

 

 

Why Does Police Brutality Occur?

Why does police brutality occur?

The history of police brutality, which will be covered later in this article, is well-rooted in race and aggression toward a primarily non-white segment of the population. There are, however, other elements to police brutality that play significant roles — the increased militarization of police organizations, institutional problems with training and culture, and the lack of accountability.

 

Increased Militarization of Police Organizations

After the wars in Iraq and Afghanistan, military-grade equipment totaling billions of dollars was re-deployed in the United States. Vehicles capable of withstanding improvised-explosive-devices, grenade launchers, full-body protection, and a litany of other pieces of equipment found their way into police institutions around the country. A trio of reporters from The Washington Post have studied the link between police brutality and the increased presence of military equipment. In piece from the newspaper (as used by an article by The Atlantic), they reported on some of the findings:

 

“When a county goes from receiving no military equipment to $2,539,767 worth (the largest figure that went to one agency in our data), more than twice as many civilians are likely to die in that country the following year.”

 

With these new injections of military-grade equipment into the institutions, police officers have more force at their disposal than ever before. That alone may not spark instances of police brutality, but the issues combined with other factors can create an environment in which excessive force becomes more normalized. One such issue is problems with police training and culture.

 

Institutional Problems with Training and Culture

Police Brutality Officers

According to a study of NYPD recruits, one of the most common reasons for entering the police force is the “opportunity to help people in the community.” These idealistic beginnings, however, are soon challenged by the rigors and life-or-death pressure of training.

 

The training of a police officer emphasizes the dangers of the position and, combined with the tendency for the job to put officers in the midst of harrowing situations, these views are often reflected in their day-to-day. Hypervigilance becomes the ground state, and most situations — rather than a select few — are heightened to life-or-death matters. A paper written by epidemiologist Erin McCanlies and co-authors entitled “Resilience Mediates the Relationship Between Social Support and Post-Traumatic Stress Symptoms in Police Officers” explains this through the lens of Post Traumatic Stress Disorder (PTSD):

 

“Because police officers are frequently exposed to traumatic events such as death, being shot at, and physical assault, rates of PTSD among police officers have been reported to be as high as 15 percent.”

 

This type of psychological stress and heightened nerves becomes more dangerous and can elevate to instances of police brutality when another element of police training is factored in — firearms training.

 

In a 2013 report from the Bureau of Justice, a recruit’s training was broken down into various categories. Observing changes in training hours from 2006 to 2013, the report found an increase in firearms training and a decrease in criminal and constitutional law. The report states:

 

“Between 2006 and 2013, the average amount of instruction required per recruit increased the most for firearms skills, from 63 hours in 2006 to 71 hours in 2013 (figure 9). Decreases were observed for criminal and constitutional law (from 64 hours to 53 hours) and patrol procedures (from 58 hours to 52 hours).”

 

In the same report, it shows that an average of 43 hours is spent on community-policing training. This prioritization of firearms over other policing tactics combined with a heightened sense of danger and PTSD issues can all contribute to situations of police brutality. 

 

Lack of Accountability

Police Brutality Convictions

There is no national system for reporting misconduct by police officers, and that means there is no centralized collection of data on these incidences. There are, however, reports and studies conducted by academics and journalists that provide a window into the issue of the lack of accountability in cases of police brutality. 

 

Philip M. Stinson, a law professor at Bowling Green State University, maintains the The Henry A. Wallace Police Crime Database. This database is a valuable resource in examining the data behind police brutality and accountability. From 2005 to 2014, the database shows 10,287 criminal arrest cases of 8,495 non-federal sworn law enforcement officers. However, in more recent data shared with FiveThirtyEight (through March 2020), Stinson reported only 110 instances in which law enforcement officials were charged with murder or manslaughter for an on-duty shooting even though more than 1,000 individuals are killed by police officers every year (according to data from The Washington Post). Filtering down further, only 42 of those officers were convicted (with many being lowered to lesser offenses), 50 were not convicted, and 18 of those cases are still pending.

 

This set of statistics shows the difficulty not only in convicting a case of police brutality but even simply keeping track of them in the first place. This “hidden” nature of police brutality may embolden the excessive actions of some officers.

 

When a police officer is brought to trial, studies have shown judges and juries are more likely to believe a police officer when they say they felt as though their life was threatened (in cases of police brutality or murder). Also, police departments often work closely with persecutors, introducing a conflict in pursuing convictions against what is essentially a coworker. 

How To File A Complaint Against A Police Officer

Why Does Police Brutality Occur Recap 

Police brutality occurs for a number of different reasons, not the least of which is racial bias. There are, however, other facts that have been shown to contribute to police brutality and misconduct.

 

  • Increased Militarization of Police Organizations: Many police organizations inherited billions of dollars’ worth of military-grade equipment after the wars in Iraq and Afghanistan wound down. While this new equipment doesn’t cause police brutality alone, it can lead to more aggressive approaches to policing when combined with other facts of misconduct.

 

  • Institutional Problems with Training and Culture: The psychological stress of the day-to-day life of a police officer, often framed as life-and-death in much of an officer’s training, can contribute to instances of police brutality. Additionally, training for aggressive practices such as the use of firearms has increased over time while less-aggressive training such as community policing has decreased.

 

  • Lack of Accountability: There are systemic challenges in charging and convicting police officers of police brutality and other forms of misconduct. If an office is convicted, the sentence is reduced down to a lesser charge many times. There is also statistical data that shows a jury and judge is more likely to believe a police officer than a victim of police brutality.

 

 

 

 

History of Police Brutality

Police Car

Although what can be considered “modern policing” didn’t really take shape until the 1830s and 1840s, it didn’t take long after for police brutality to become an issue within the organizations. Initially, police brutality was primarily inflicted on European immigrants in northern areas of the country that saw a need for a more organized form of authority. As black individuals left the Jim Crow south for new lives, however, they too became targets of police brutality.

 

As the years continued, black individuals in particular faced the brunt of police brutality. In the 1929 Illinois Crime Survey report published by the Illinois Association for Criminal Justice, data showed Black residents of Chicago and Cook County — although making up just 5% of the overall population of the area — represented 30% of police killings.

 

That year, President Hoover established the National Commission of Law Observance to track policing tactics and prohibition-related crime. In reports published by the commission (14 volumes of data), the depth and proliferation of police brutality was exposed. In an examination of a volume entitled, “Report on Lawlessness in Law Enforcement”, a research collection project made the findings of the report clear:

 

“In uncompromising language, the Report on Lawlessness in Law Enforcement concluded that [t]he third degree that is, the use of physical brutality, or other forms of cruelty, to obtain involuntary confessions or admissions is widespread. Specific tactics included protracted questioning, threats and methods of intimidation, physical brutality, illegal detention, and refusal to allow access of counsel to suspects. The report declared unequivocally that the third degree is a secret and illegal practice.”

 

Photos and videos vividly captured police brutality during the Civil Rights era of the 1960s. The tactics such as police dogs and fire hoses were deployed against peaceful protestors garnered much of the public’s attention but reports of daily brutality on a community level saw the trust in the police by people of color erode further.

 

Media and Police Brutality

Police Brutality Media

Although police brutality has been covered by the media for more than a century, the coverage has expanded and changed with the times. With technology a regular part of our daily lives, there have never been more “eyes” watching when incidents of police brutality and misconduct occur. 

 

Smart phones have democratized the idea of a “cameraman,” allowing for first-hand and sometimes livestreamed accounts of police brutality. Social media has also made it possible for accounts of police brutality to be spread to millions of people faster than ever before.

 

Police officers, too, are outfitted with more technology than in the past. Dashcams on cruisers, bodycams on officers themselves, and widespread surveillance cameras in public areas all have contributed to the public-at-large having direct access to situations of police brutality and misconduct. 

 

This near-instant access to police brutality is a far cry from how media has sometimes covered the issue in the past. The Kerner Commission, put in place by President Lyndon Johnson in 1968 to examine the root cause of the 1967 race riots in Detroit, did its job — it identified white racism as the driving cause — but the media coverage was still sometimes skewed. Without a direct account of the brutality that took place (and, of course, due to race-fueled cultural norms) the media often portrayed the police violence and misconduct as a Black problem — not one that was driven by racial discrimination and cultural issues of police organizations. A headline in The New York Times at time, “Johnson Unit Assails Whites in Negro Riots: Will Urge Drive on Prejudice, Neglect and Ignorance,” illustrates this disconnect.

 

Now, however, camera lens being virtually everywhere allow for instances of police brutality to be displayed in stark reality. There may not necessarily be a massive increase of police misconduct now, but the public is able to see much more of what does occur. In recent years, many high-profile cases of police brutality have been captured in firsthand accounts and have gone on to be spark points for protests, riots, and the call for justice. 

 

Cases of Police Brutality

Justice for Breonna Taylor

In the United States

Rodney King

On March 3, 1991, Rodney King was beaten by a group of officers after leading police on a high-speed vehicle chase in Los Angeles. The beating was videotaped by a bystander and became a national sensation, showing — possibly for the first time — police brutality to the public. Despite video and physical evidence of excessive force, a jury acquitted three of the officers and could not decide on a verdict for the fourth. The verdicts prompted the LA Riots of 1992.

 

George Floyd

On May 25, 2020, police were called to a Cup Foods in Minneapolis, Minnesota, on a report of a man (George Floyd) using counterfeit bills to buy cigarettes. Three police officers responded to the scene and attempted to get Floyd into the back of a police car. After falling on the ground, an officer placed his knee on the back of Floyd’s neck for seven minutes and 46 seconds, some of which was marked by Floyd repeatedly saying he couldn’t breathe or pleading for his mother. Once Floyd was put into an ambulance (in an unresponsive state), he was pronounced dead an hour later at a hospital. The offices involved are facing various charges but have not been tried as of this writing.

 

Breonna Taylor

On September 23, 2020, Breonna Taylor was murdered in her apartment in Louisville, Kentucky, after three plainclothes police officers forced their way in while executing a search warrant. Taylor’s boyfriend, believing it was the woman’s ex-boyfriend breaking in, fired a shot from his licensed firearm, striking one of the officers in the leg. The officers returned fire with 32 rounds, including 10 that were, “wantonly and blindly fired” according to one of the officer’s termination letters. Taylor died in the hallway of her apartment. One of the officers was charged with three counts of “wanton endangerment,” but no other charges have been filed.

 

In Other Countries

India

Father and son P. Jayaraj and J. Bennicks were taken into custody by Punjabi police on June 19, 2020 where they were sexually assaulted and tortured, eventually leading to their deaths.

 

Argentina

In 2009, Luciano Arruga, a 16-year-old boy, went missing after being brought to a police station for allegedly having stolen three cellphones. His remains weren’t found until 2014. The case is seen as a clear representation of enforced disappearance by police in post-dictatorship countries.

 

Canada

In 2016, a Toronto police officer beat Dafonte Miller, a 19-year-old Black male, with a pipe. The beating led to the removal of Miller’s eye. The officer was found guilty of assault and was sentenced to nine months in prison with 12 months of probation. 

 

Police Brutality and the Black Lives Matter Movement

Police Brutality Black Lives Matter

With more people able to witness acts of police brutality almost firsthand through various means of technology, the treatment of people of color has been at the forefront of American discourse in recent years (but, of course, has been a national issue for decades).

 

The Black Lives Matter movement was formed after the acquittal of George Zimmerman, the man who shot and killed Trayvon Martin. The movement’s goals are stated on its website:

 

“#BlackLivesMatter was founded in 2013 in response to the acquittal of Trayvon Martin’s murderer. Black Lives Matter Global Network Foundation, Inc. is a global organization in the US, UK, and Canada, whose mission is to eradicate white supremacy and build local power to intervene in violence inflicted on Black communities by the state and vigilantes. By combating and countering acts of violence, creating space for Black imagination and innovation, and centering Black joy, we are winning immediate improvements in our lives.”

 

Since forming, the widespread movement has been at the center of protests around the country, all focusing on the racial mistreatment of people of color in the United States. While many of these protests are in response to cases of police brutality, Amnesty International has found many instances of police brutality occurring in the protests themselves. The organization found 125 separate incidents of police violence, sometimes excessive, against protestors, medics, journalists, and legal observers during the protests of May and June 2020. Several of these instances of force were documented in the organization’s report including.

  • “Out of the blue, they started breezing pepper spray into the crowd…then they started with the tear gas. Someone who was right in front —  had a tear gas canister hit his head and started running back. We were trying to help him, flushing his eyes and then he just fainted and started having a seizure.” — Lizzie Horne, on police force during a Philadelphia protest
  • “They had enough time to shake the pepper spray and to spray it, despite me and others shouting, ‘Press, press,’ continually. I’ve literally spent most of my career in places where being a journalist was something I had to hide and something I had to be careful about sharing. And this is one place where I should be able to proclaim this is what I do.” — Ed Ou, NBC News photo journalist 

 

According to report on police brutality during the protests of 2020, Bellingcat and Forensic Architecture recorded at least 950 incidents of police brutality including:

  • 500 cases of violations when using less-lethal rounds, pepper spray, and tear gas
  • 60 cases of officers using unlawful assembly to arrest protestors
  • 19 incidents of officers being more permissive toward the far right and white supremacists
  • Five attacks on medical professionals
  • 11 instances of kettling

 

Laws Against Police Brutality

Forms of Police Brutality

In the United States, there are federal laws in place that address the issues of police brutality and misconduct. These protections, both criminal and civil, loosely focus on instances in which a police officer deprives an individual of their personal rights. 

 

Criminal Law Against Police Brutality 

The section of the U.S. Code that addresses the federal criminal enforcement of these laws is as follows:

 

“Whoever, under color of any law, statute, ordinance, regulation, or custom, willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, on account of such person being an alien, or by reason of his color, or race, than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned not more than one year, or both; and if bodily injury results from the acts committed in violation of this section or if such acts include the use, attempted use, or threatened use of a dangerous weapon, explosives, or fire, shall be fined under this title or imprisoned not more than ten years, or both; and if death results from the acts committed in violation of this section or if such acts include kidnapping or an attempt to kidnap, aggravated sexual abuse, or an attempt to commit aggravated sexual abuse, or an attempt to kill, shall be fined under this title, or imprisoned for any term of years or for life, or both, or may be sentenced to death.” — 18 U.S. Code § 242 – Deprivation of Rights Under Color of Law

 

The term “under color of law” is key to this passage and is important to understand. “Under color of law” means the individual enacting these crimes is using power granted by Federal, State, or local government bodies. As outlined by The United States Department of Justice (DOJ), these crimes include, “…excessive force, sexual assault, intentional false arrests, theft, or the intentional fabrication of evidence resulting in a loss of liberty to another.” The enforcement of the punishments associated with this code specifically do not require evidence of racial, religious, or any other discriminatory factors.

Civil Law Against Police Brutality

Police Lineup

The civil law against police brutality is similar to the criminal code. The section of the U.S. Code that addresses the federal civil enforcement of these laws is as follows:

 

“(a) Unlawful conduct

It shall be unlawful for any governmental authority, or any agent thereof, or any person acting on behalf of a governmental authority, to engage in a pattern or practice of conduct by law enforcement officers or by officials or employees of any governmental agency with responsibility for the administration of juvenile justice or the incarceration of juveniles that deprives persons of rights, privileges, or immunities secured or protected by the Constitution or laws of the United States.

 

“(b) Civil action by Attorney General

Whenever the Attorney General has reasonable cause to believe that a violation of paragraph (1) [1] has occurred, the Attorney General, for or in the name of the United States, may in a civil action obtain appropriate equitable and declaratory relief to eliminate the pattern or practice.” — 34 U.S. Code § 12601.Cause of Action

 

Under this law, the police brutality or misconduct in question must be part of a pattern of abuse, not an isolated incident. 

While these laws are designed to protect individuals against police brutality while holding officers accountable for their actions, we’ve already seen how difficult it can be to proper charge and convict a law enforcement officer. As stated previously:

 

“There are systemic challenges in charging and convicting police officers of police brutality and other forms of misconduct. If an office is convicted, the sentence is reduced down to a lesser charge many times. There is also statistical data that shows a jury and judge is more likely to believe a police officer than a victim of police brutality.”

 

How to Report Police Brutality

Crime scene

Although holding a police officer accountable for police brutality may be difficult, an individual still has the right to do so. It is important, however, to do so in the proper way.

If a person has been the victim of or has witness an act of police brutality or misconduct, they should first do the following:

  • Write down all of the names of the people involved in the incident including any witnesses
  • Take photographs of any injuries received during the incident 
  • Seek medical attention for the injuries from a medical professional
  • Seek the assistance of a qualified police brutality attorney

It’s important that these steps be done as quickly as possible; some jurisdictions set a time limit in which police brutality or misconduct must be reported.  

 

For a more in-depth look at how to report an incident of police brutality, refer to, “How to File a Complaint Against a Police Officer.”

 

Police Brutality Statistics

Police Brutality Stats

We’ve examined some police brutality statistics earlier in this article, but here is a recap of those points as well as several other data points. This 2020 data is sourced from Mapping Police Violence (MPV).

 

Of the 1,127 people killed by police, 96% were killed by shootings while tasers, physical force, and police vehicles accounted for the majority of the rest. Most of these incidents (658) came during non-violent offenses or cases in which no crime was reported. 121 people were killed after being stopped by a police officer for a traffic violation.

 

80 people killed by police were unarmed. According to Mapping Police Violence, an “unarmed” person is classified as the following (sourced from the MPV website):

  • not holding any objects or weapons when killed
  • holding household/personal items that were not used to attack others (cellphone, video game controller, cane, etc.)
  • holding a toy weapon (BB gun, pellet gun, air rifle, toy sword)
  • an innocent bystander or hostage killed by a police shooting or other police use of force
  • a person or motorist killed after being intentionally hit by a police car or as a result of hitting police stop sticks during a pursuit

Of the 80 unarmed people killed by police, 27 were Black, 15 were Hispanic, one was Native American, two were Asian/Pacific Islander, 31 were White, and four were unknown.

 

Of the 444 officers Mapping Police Violence was able to identify, at least 15 officers had shot and killed someone before.

 

Showing the difficulty in charging and convicting police officers (as stated before), only 15 of these killings resulted in an officer being charged with a crime. In seven of these cases, video evidence was available from a body or dash cam.

 

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