Sign the Resolution for a Federal Commission on Drug Policy
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DRCNet Library | Schaffer Library | Major Studies | Licit and Illicit Drugs
by Edward M. Brecher and the Editors of Consumer Reports Magazine, 1972
Narcotics. The one overwhelming objection to opium, morphine, heroin, and the other narcotics is the fact that they are addicting. The other disastrous effects of narcotics addiction on mind, body, and society are primarily the results of laws and policies (see Part 1).
Many American morphine and heroin addicts prior to 1914 led long, healthy, respectable, productive lives despite addiction and so do a few addicts today. The sorry plight of most heroin addicts in the United States today results primarily from the high price of heroin, the contamination and adulteration of the heroin available on the black market, the mainlining of the drug instead of safer modes of use, the laws against heroin and the ways in which they are enforced, the imprisonment of addicts, society's attitudes toward addicts, and other nonpharmacological factors. It was the enforcement of the Harrison Act of 1914 that converted opiate addiction from what it had long been a misfortune and a disgrace into a disaster.
The time has come to recognize what should have been obvious since 1914 that heroin is a drug most users go right on using despite the threat of imprisonment, despite actual imprisonment for years, despite repeated "cures" and long-term residence in rehabilitation centers, and despite the risks of disease and even death. Heroin is a drug for which addicts will prostitute themselves. It is also a drug to which most addicts return despite a sincere desire to "stay clean," a firm resolve to stay clean, an overwhelming effort to stay clean and even a success (sometimes enforced by confinement) in staying clean for weeks, months, or years. This is what is meant by the statement that heroin is an addicting drug.
The first and most important step in solving the heroin problem, accordingly, is to recognize at long last what addiction to heroin means. Society must stop expecting that any significant proportion of addicts will become ex-addicts by an act of will, or by spending five years in prison, or a year or two in a prison-like California, New York State, or federal "drug treatment center," or even in a "therapeutic community" like Synanon, Daytop, Phoenix House, Odyssey House, or any of the others (see Chapter 10).
Almost all heroin addicts, it is true, do stop taking heroin from time to time. But almost all subsequently relapse. Among those who do not relapse, roughly half become skid-row alcoholics. For the details, see Chapter 10. By publicizing the few conspicuous exceptions the handful of successful ex-heroin addicts and by assuming that others need only follow in their footsteps, harm is done in at least three tragic ways.
(1) Another generation of young people is persuaded that heroin addiction is temporary. They are falsely assured that the worst that can happen to them if they get hooked on heroin is that they may have to spend a year or two in a drug treatment center, or, better yet, in a therapeutic community like Synanon or Daytop after which they will emerge, heads high, as certified ex-addicts.
(2) Hundreds of millions of dollars are wasted on vast "treatment programs" that almost totally fail to curb subsequent heroin use by addicts, while more pressing measures are skimped on.
(3) Law-enforcement resources are, wasted on futile efforts to keep heroin away from heroin addicts instead of concentrating on the essential task: keeping heroin away from nonaddicts.
The ideal solution to the heroin problem, of course, would be a cure for opiate addiction some means of erasing altogether both the physiological and the psychological traces of past drug use. But no such cure exists, nor is there one on the horizon and there exist no clues to where such a miracle cure might be found. Accordingly, while scientists who want to search for a cure should certainly be encouraged to do so, it is folly to base national policy on the hope that they may succeed.
There is one major exception to the rule that most heroin addicts go right on using heroin or returning to heroin. A heroin addict can comfortably do without his drug if supplied with a related drug. Methadone is one such drug. Unlike heroin, it can be effectively taken orally rather than by injection; it need be taken only once a day instead of several times; it is legal; it is cheap; and it has other advantages. Like heroin, it has very little effect on either mind or body if taken regularly. An estimated 25,000 ex-heroin addicts were taking legal methadone instead of black-market heroin in 1971, and the number was rapidly growing.
Methadone maintenance is not a panacea. But it frees addicts from the heroin incubus, which is ruining their lives, and it is therefore capable of turning a majority of heroin addicts into law-abiding citizens (like pre-1914 addicts). One of the reasons it succeeds, of course, is that it is itself an addicting drug that is, a drug that must be taken daily. For further details, see Chapters 14-19.
The conversion of heroin addicts into methadone maintenance patients is proceeding too slowly. Some communities have no methadone maintenance program; most programs have long waiting lists. Putting an addict on a waiting list for methadone has been likened to putting a drowning man on a waiting list for artificial respiration.
Ideally, addicts should be given a choice of treatment modalities, a choice between methadone maintenance and other programs offering a similar likelihood of rehabilitation. But first those effective alternatives must be found. Consumers Union enthusiastically endorses laboratory and clinical research into effective alternatives to methadone maintenance, including both drug-free approaches and rehabilitation programs using drugs other than methadone. But large sums should not again be spent on alternatives which since the early "opiate cures" of the nineteenth century have already repeatedly demonstrated their worthlessness. A program should be considered experimental until it has proved its effectiveness; there should be no further mass failures, such as the California and New York State programs, into which vast sums have been sunk with barely a trace of benefits.
To date, no program other than methadone maintenance has demonstrated its ability to rehabilitate more than a minute proportion of addicts. Failure rates in nonmethadone programs range from 90 to 100 percent, even when entrance is limited to select groups of highly motivated addicts. The failures return to the American black-market system of heroin distribution, paying exorbitant prices for dangerously adulterated and contaminated heroin. Surely methadone maintenance is better than that.
It is shocking, of course, to think of tens of thousands of newly addicted young people and of addicted Vietnam veterans taking a narcotic such as methadone daily, for months, years, perhaps for the rest of their lives (see Chapter 20). No one can look forward to such a prospect with satisfaction. But no better solution is in sight. And the alternative for those who are not rehabilitated by existing methods is a return to black market heroin.
The heroin black market must be abolished in the only way it can be abolished: by eliminating the demand for black-market heroin.
On the central issue of narcotics addiction, accordingly, Consumers Union recommends (1) that United States drug policies and practices be promptly revised to insure that no narcotics addict need get his drug from the black market; (2) that methadone maintenance be promptly made available under medical auspices to every narcotics addict who applies for it; (3) that other forms of narcotics maintenance, including opium, morphine, and heroin maintenance, be made available along with methadone maintenance under medical auspices on a carefully planned, experimental basis.
The third of these recommendations that opium, morphine, and heroin as well as methadone be made available to addicts under well-planned experimental conditions is based in part on the unassailable fact that an addict is personally far better off on legal, low-cost, medicinally pure opium, morphine, or heroin than he is on exorbitantly priced, dangerously adulterated, and contaminated black-market heroin.
Similarly, society is better off when addicts receive their drugs legally and at low cost or free of charge.
Finally, reliable scientific data on the relative advantages and disadvantages of various maintenance drugs under actual conditions of use in the United States can be secured only by comparative-use studies. The experimental programs should be designed to determine, if possible on a blind or double-blind basis, (a) whether any other drug has any advantages over methadone for general use in narcotics maintenance programs, and (b) whether any particular subcategories of patients may do better on opium, morphine, heroin, or some other maintenance drug rather than on methadone. The tests should be designed to determine whether it is the heroin molecule itself or the mystique surrounding it that makes the difference.
The comparative trials should also be designed to determine whether, as in Britain, there is a proper role for injectable methadone in maintenance programs, or for other routes of administration (such as smoking) for the various opiates. Oral morphine and oral heroin should be among the drugs submitted to double-blind trials in competition with oral methadone.
Consumers Union's recommendation for experimental opium, morphine, and heroin maintenance programs is not based on any confidence that they will prove superior to maintenance on methadone or on newer, longer-acting versions of methadone (such as acetyl-alpha-methanol). All of the data so far indicate that methadone is very nearly the ideal maintenance drug fully effective by mouth, effective for a full twenty four hours, effective in stable doses, with minimal side effects, and with its safety, effectiveness, and acceptability to addicts already proved under actual field conditions in some 25,000 patients. But the ready availability of an excellent maintenance drug is not a sound reason for abandoning the search for an even better maintenance drug. And even if, in the end, the trials of opium, morphine, and heroin maintenance merely buttress the conclusion that methadone is the maintenance drug of choice, the research will have served a useful purpose, for oral methadone has so far only proved its worth in competition with black-market heroin. The next challenge oral methadone should be required to meet is a carefully controlled comparison with legal opium, morphine, and heroin, with injectable methadone, and perhaps with other drugs. *
* Including dipipanone, pethidine [meperidine, Demeroll, dextromoramide, levorphanol all of which are narcotics and all of which are being tried as maintenance drugs in Britain.
Further, Consumers Union calls for three immediate steps to be taken in connection with the tragic deaths of many hundreds of heroin users each year from so-called "overdose" (see Chapter 12).
First, the dangerously wrong "heroin overdose" myth must be promptly exploded once and for all. Addicts and the public alike must be warned that sudden death can follow the intravenous injection of mixtures containing very little heroin or possibly none at all.
Second, heroin addicts throughout the country should be warned by all means available, including the fullest possible use of the mass media, that deaths falsely attributed to heroin overdose may be due to injecting heroin while drunk on alcohol or barbiturates. Although the evidence linking the many hundreds of so-called "heroin overdose" deaths to alcohol and the barbiturates is not conclusive, the evidence is conclusive that an addict who injects heroin while drunk on alcohol or barbiturates is running a far greater risk than one who shoots up while sober. This should be the public health message.
Third, a full-scale research program must be promptly launched, under capable scientific leadership, to determine what is in fact causing these hundreds of deaths annually, and what measures can be taken to lower the addict death rate. These deaths must be viewed not merely as arguments against injecting heroin, but as the tragic events they are. Society must seek ways to avert them, just as ways are sought to prevent the untimely deaths of nonaddicts.
Some readers who turn to these conclusions without first having read Part I may have indignant objections to our recommendations on narcotics objections that cannot be answered here. Readers are referred to Part I for the answers.
Cocaine and the amphetamines. These twin drugs must be considered together. In general, the less said about them, the better. Antiamphetamine laws and campaigns have been among the major factors popularizing the amphetamines (see Chapter 38); and recent law-enforcement efforts to suppress the amphetamines have opened wide the door to cocaine (see Chapter 41).
Among drug users and potential drug users, two facts about the amphetamines are worth stressing. First, they are much less likely to prove damaging if taken in modest doses; hence the dosage should be kept down. Second, they should be taken orally if at all; the injection of amphetamines or cocaine in large doses constitutes one of the most damaging forms of drug use known to man. The failure to draw these distinctions between small and large doses, between oral and intravenous use, discredits drug propaganda programs and encourages the "speed-freak" phenomenon. For details, see Chapter 37.
The latest data from the youth drug scene suggest that the speed-freak phenomenon that is, the injection of amphetamines in large doses has passed its peak. Many speed freaks are turning to heroin instead, and the recruitment of new speed freaks is falling off. If a fresh antiamphetamine campaign is not launched, there is every reason to hope that the next wave of youthful drug users will engage in less damaging forms of drug use. But a revival of the antiamphetamine campaign could well sabotage this hopeful outlook.
The barbiturates and alcohol. These are pharmacologically a single problem. Both make you drunk in the same way; both can be addicting in the same way; both can produce hangovers, and delirium tremens can occur after withdrawal from excessive and persistent use. The barbiturates have the effect, in most respects, of solid alcohol and alcohol is from the pharmacological point of view a kind of liquid barbiturate (see Part IV). The persistent, excessive use of alcohol and barbiturates ranks with the speed-freak phenomenon in damage wrought, and affects vastly more people.
The great majority of users of alcoholic beverages are able to do so occasionally, in moderation, and with minimal adverse effects. But roughly 10 percent of the users become alcoholics (alcohol addicts) or "problem drinkers," with disastrous results to themselves and to society. As with the use of other addicting drugs, no one using alcohol can foretell if or when he will be among the addicted.
Alcohol Prohibition failed woefully from 1920 to 1933. Barbiturate repression is no more successful today. For these as for most other drugs, the ideal solution is to raise a generation of young people whose needs for such drugs are minimal. At moments when life is rich and challenging who wants a mood-altering drug?
As an interim measure, Consumers Union recommends that the advertising and promotion of alcoholic beverages be prohibited. An appropriate hazard notice should be required on all alcoholic beverage labels; like the warning on cigarette packages, it might not deter use of alcohol, but such a notice would at least indicate society's recognition of the potentially harmful nature of alcoholic beverages.
Other interim measures that might palliate this country's alcohol problem a far larger problem, no matter how measured, than all other drug problems added together are beyond the scope of this Report.
In particular, the problem of driving automobiles and using machinery while drunk on alcohol is a major menace. A solution to the drunken driving problem is urgently needed, along with a solution to the problem of driving while under the influence of other drugs. Prohibition of drugs, like prohibition of alcohol, is not the answer.
Nicotine. This, too, is an addicting drug. "The confirmed smoker acts under a compulsion which is quite comparable to that of the heroin user." 1 For the evidence, see Part III. Just as some heroin addicts can and do stop, so some cigarette smokers can and do stop. But the disastrous effect of basing public policy on these exceptional cases is evident from that fact that cigarette consumption, after seven years of anticigarette drives urging voluntary abstinence, is close to its all-time high.
The other evil effect of failure to recognize that nicotine is an addicting drug is that it encourages young people to start smoking. A majority of teen-age smokers have been persuaded, at least in part by anticigarette campaigns, that they will be able to smoke for a few years and then "kick the habit" when they are ready to quit (see Chapter 26). It is hard to imagine a nastier trap than this one that society has set for its own children.
The anticigarette campaigns have succeeded in persuading both adults and teenagers that cigarette smoking causes lung cancer and is damaging to health in numerous other ways. But this conviction is not deterring tens of millions of adults and teenagers from smoking cigarettes. Despite the highly impressive anticigarette ads on television and other well-planned campaigns, the proportion of smokers among seventeen- and eighteen year-olds is almost as high as among adults.
It is uncertain whether a ban on cigarette advertising by itself would significantly reduce the numbers of new recruits to cigarette smoking. But, while it may not by itself be sufficient, such a ban is a necessary precondition if other anticigarette measures are to be effective (see Chapter 26). This is the practical ground that leads Consumers Union to recommend that all cigarette advertising and promotion including point-of-sale displays and cigarette vending machines be banned altogether.
There is also an ethical ground for our recommendation: it is immoral to permit the advertising of an addicting product that causes lung cancer and other diseases.
In the absence of effective ways to curb cigarette smoking, a safer substitute for nicotine is needed. So far, scientists have hardly even begun to look for one. When they do start to look, the odds are excellent that they will find a safer nicotine substitute, as well as safer ways of using nicotine itself.
Prescription drugs. Adults are securing mind-affecting drugs on prescription in vast quantities stimulants, sedatives, hypnotics, tranquilizers, and others. Whether they are getting too many, or not enough, or the wrong ones, deserves objective research.
Many members of the generation under thirty are using, among others, the same drugs their elders get on prescription but without bothering to get a prescription first. If young adults continue this practice as they mature, many prescription drugs may gradually become "nondrugs" like caffeine, nicotine, and alcohol. This, indeed, may already be happening. For details, see Chapter 62.
LSD. Until 1962, this drug was a promising adjunct to psychotherapy,, tried out on thousands of patients with few adverse effects (see Chapter 48). Then came the anti-LSD campaign and the anti-LSD laws, which helped convert LSD from a psychotherapeutic novelty to an illicit drug popular even among high-school students.
The anti-LSD publicity, the scare campaigns, and the laws also helped convert what had been until 1962 a relatively unknown and innocuous drug into a quite damaging one. As in the case of heroin, legal and social rather than pharmacological factors account for most of the LSD tragedies of the 1960s (see Chapter 51).
Now that the furor has died down, LSD appears to be becoming less damaging again. The latest data indicate that it is not (as was supposed) a way of life, but a stage through which some drug users pass. Most users either discontinue LSD altogether after a few months or years or else reduce their consumption to a few "trips" a year.
The scattered data available so far indicate that LSD use has not benefited users as much as they suppose nor has it damaged them as much as has been alleged. The LSD "chromosome scare" is treated in Chapters 50 and 52.
It is still too early to map out a sensible program for making the LSD experience legally available to those who want it for self-betterment and self-exploration ("mind expansion"). That time, however, may come. Meanwhile, experimental use of LSD in therapy for alcoholism, for the palliation of terminal cancer, and perhaps for other indications, should be revived and objectively evaluated.
As matters stand, with only "street LSD" of unknown strength and purity available, and in the absence of skilled supervision, no prudent person will take LSD just as no prudent person will get dead drunk on alcohol. And it is the height of imprudence to take LSD more than a few times a year just as it is the height of imprudence to get drunk frequently. For schizophrenics, for borderline schizoid personalities, and perhaps for some others, LSD may prove particularly damaging.
Laws, policies, and attitudes should accordingly be shaped to minimize the damage done by LSD and LSD-like drugs to those imprudent enough to take them. Repressive and punitive laws that add the damage done by imprisonment and criminalization to whatever damage may be done by LSD are irrational and counterproductive.
Marijuana. It is now much too late to debate the issue: marijuana versus no marijuana. Marijuana is here to stay. No conceivable law enforcement program can curb its availability. Accordingly, we offer these seven recommendations.
(1) Consumers Union recommends the immediate repeal of all federal laws governing the growing, processing, transportation, sale, possession, and use of marijuana.
(2) Consumers Union recommends that each of the fifty states similarly repeal its existing marijuana laws and pass new laws legalizing the cultivation, processing, and orderly marketing of marijuana subject to appropriate regulations.
The term "legalization of marijuana" means many things to many people. As used here, it means that marijuana should be classed as a licit rather than an illicit drug.
We do not recommend legalization because we believe that marijuana is "safe" or "harmless." No drug is safe or harmless to all people at all dosage levels or under all conditions of use. Our recommendation arises out of the conviction that an orderly system of legal distribution and licit use will have notable advantages for both users and nonusers over the present marijuana black market. In particular it will separate the channels of marijuana distribution from heroin channels and from the channels of distribution of other illicit drugs and will thereby limit the exposure of marijuana smokers to other illicit drugs. Even more important, it will end the criminalization and alienation of young people and the damage done to them by arrest, conviction, and imprisonment for marijuana offenses.
Three major questions are not answered by the above recommendation:
Most discussions of legalizing marijuana anticipate that distribution will be turned over to the tobacco companies, or the alcoholic beverage companies, or to similar large commercial enterprises. We urge instead that individual states experiment with a wide range of distribution patterns.
Marijuana grows readily in fields, along highways, in backyards, in window boxes, and even in suitably illuminated closets and cellars. An informal distribution system has grown up that, is, in considerable part, a sharing among friends, and that is patterned after native arts-and-crafts enterprise rather than large-scale commercial enterprise. If legalizing marijuana should mean turning over production and distribution exclusively to the tobacco companies or to other corporate giants, it is questionable whether all marijuana smokers would readily patronize such a system. Some would no doubt continue to harvest and distribute their own, illegally, just as mountaineers and others continue to make and sell their own whiskey. Bootlegging does not encourage respect for law.
Unfortunately, no body of experience exists in any Western country which might serve as a guide or model for an acceptable system of marijuana distribution. In the absence of experience, neither the states nor the federal government can foretell how a system will work. We therefore believe that the fifty states at least in the beginning should be left free to devise their own systems and that a wide range of alternative systems should be tried out. Among the possibilities are distribution through a statewide marijuana monopoly (private or public), through small-scale enterprises resembling arts-and-crafts centers, through alcohol channels, and through tobacco channels.
The fifty states should similarly consider alternative answers to other pressing questions. At what age should young people be allowed to buy marijuana legally? Should only one grade and strength be permitted, or should varying strengths be legally marketable? Should marijuana smoking be permitted in public or only in private? If in public, should it be permitted in cocktail lounges, taverns, bars, and roadhouses or only in places where alcoholic beverages are not sold? How can the problem of operating an automobile or other machinery while under the influence of marijuana best be handled? Only a wide range of experience can provide the answers needed for wise long-term decisions on these and related issues.
This does not mean, however, that the federal government should play no role. Experience in other fields has shown federal regulation to have great advantages; and this is almost certain to prove true with marijuana regulation as experience with various regulatory approaches accumulates.
(3) Consumers Union therefore recommends that a national marijuana commission be established to help provide the states with needed research information, to monitor the various plans evolved by the states, and to build, eventually, the best features of those plans into federal marijuana legislation.
Adequately staffed and funded, the commission should coordinate federal and state research programs, including ongoing controlled studies into long-term effects of marijuana use.
If some aspect of one state's plan proves disastrous, the commission should recommend a federal law prohibiting the practice nationally. If some other aspect of a state's law proves to be an outstanding success, the successful feature can in due course be accepted as national policy and embodied in federal laws or regulations. Four possibilities in particular should concern the national marijuana commission from the beginning:
Such a hybrid of state experimentation plus federal intervention is hardly a tidy arrangement, but our system of government has never been noted for its tidiness. In fact, as a welcome result of this untidiness, it is possible for a state to experiment with a new policy without the entire country being subjected to that experimentation. * Our marijuana proposals are designed to take the greatest possible advantage of this freedom to experiment while also making it possible to terminate experiments that go sour and to adopt nationally those that succeed.
* United States Supreme Court justice Louis D. Brandeis wrote (1931): "It is one of the happy incidents of the federal system that a single courageous State may, if its citizens choose, serve as a laboratory; and try novel social and economic experiments without risk to the rest of the country." 2
During the period of transition, the marijuana debate will no doubt wax even hotter than it has in the past. Even more attention will be focused on marijuana even more people will be attracted to the drug. Perhaps it will prove unfortunate, but it is equally possible that one effect of the greater concern with marijuana will be a lessening of use of other drugs, licit as well as illicit. This may prove a major gain.
(4) Consumers Union recommends that state and federal taxes on marijuana be kept moderate, and that tax proceeds be devoted primarily to drug research, drug education, and other measures specifically designed to minimize the damage done by alcohol, nicotine, marijuana. heroin, and other drugs.
Both Congress and state legislatures over the years have tended to tax alcoholic beverages and cigarettes for all that the traffic will bear in part on the theory that high prices may deter use. As we have shown, however, high drug prices do not deter use. High taxes similarly would be unlikely to deter marijuana use. Rather, their effect very probably would be to encourage the bootlegging and smuggling of marijuana to avoid the tax, as whiskey is bootlegged and cigarettes are smuggled today.
It is hardly likely, of course, that Congress will repeal federal marijuana laws tomorrow, or that state legislatures will legalize marijuana without lengthy debate. Some delay may be tolerable provided that interim measures are taken to end the cruelty and irrationality of current laws. We accordingly propose these interim measures, which we urge Congress and the states to adopt without delay:
(5) Consumers Union recommends an immediate end to imprisonment as a punishment for marijuana possession and for furnishing marijuana to friends. *
* From the 1970 Interim Report of Canada's Le Dain Commission: "There is obviously a big difference between selling the drug for monetary consideration and giving it to a friend. Selling it at cost to an acquaintance is different from selling it to a variety of people to make a profit. Selling it on a small scale to make a marginal profit perhaps to support one's own usage is not the same as organizing and controlling a large entrepreneurial organization. As can be seen, trafficking activities range along a spectrum from a kind of act not far removed in seriousness from simple possession to the extensive activities of the stereotyped exploiter and profiteer whose image led to the kinds of penalties associated with trafficking ." 3
This recommendation rests on the nihil nocere principle set forth above. The imprisonment of youthful marijuana users has not curbed marijuana smoking. It does more harm than good (see Part VIII). When a physician finds that his prescription is doing more harm than good, he withdraws the prescription.
The usual argument for continuing to imprison marijuana offenders that the results of further scientific research should be awaited is sophistical and brings both the law and scientific research into disrepute. What it tells young marijuana smokers, in effect, is something like this: "We will continue to imprison you for marijuana offenses because scientists are searching feverishly for some justification for imprisoning marijuana smokers, and they will no doubt find one some day." Even if marijuana ultimately proves as damaging as alcohol, which seems very unlikely, imprisonment is hardly the treatment of choice for users.
(6) Consumers Union recommends, pending legalization of marijuana, that marijuana possession and sharing be immediately made civil violations rather than criminal acts. Including marijuana offenses under the criminal law has two major adverse effects on marijuana smokers, even if there is no imprisonment. First, a criminal record bars an individual from government employment and from a wide variety of other jobs and activities. Second, engaging in criminal behavior has a subtle but significant effect on the self-image of individuals. Because they are criminals under the law, they begin to think of themselves as criminals. Lacking respect for the marijuana laws, they may lose respect for other laws as well. Taking marijuana possession and sharing offenses out of the criminal law altogether will contribute to respect for law.
(7) Consumers Union recommends that those now serving prison terms for possession of or sharing marijuana be set free, and that such marijuana offenses be expunged from all legal records. It is hard to think of a more dramatic way to demonstrate this country's earnest desire to bridge the generation gap and to right grievous miscarriages of justice. Respect for law will surely increase.
1. Vincent P. Dole, personal communication.
2. U. S. Supreme Court justice Louis D. Brandeis, dissenting opinion, New State Ice Company v. Ernest A. Liebmann, 1931 (285 U.S. 311).
3. Le Dain Commission Interim Report, p. 182.
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