Monday, June 29, 2009

Secular laws vs. God's laws

I was on the road last weekend and attended church at a Mormon ward in another city. Their Sunday School schedule was a week behind my home ward, so I got to hear the Word of Wisdom lesson twice. After hearing members of the class quibble over what constitutes "hot drinks" and the purpose behind the various prohibitions and admonitions, I started thinking about how the Word of Wisdom compares to secular laws.

I've often said before that the Word of Wisdom would be a lot clearer if it came with a definition section, but that approach probably wouldn't work well for a religious law. A Word of Wisdom written like modern statutes would probably be less ambiguous, but it would also be limited by the text of the document. For example, illegal drugs are commonly included in the prohibitions of the Word of Wisdom, but there isn't any particular text in Doctrine & Covenants 89 that supports this interpretation. Instead, that prohibition is based on the spirit of the law and (more importantly) revelation and clarification by modern prophets having the authority of God.

We have secular laws for many of the same reasons that we have laws from God. Those laws are intended at least in part to encourage certain behaviors and discourage others, so as to create a better-functioning society. Secular laws tend to be lengthy and difficult to understand, with rigid structures and terms of art that make them inaccessible to the layman. Secular laws, even constitutions, can usually be updated or amended by their enacting bodies to deal with changed circumstances. Sometimes secular laws can be interpreted by judicial bodies to clarify or extend the application thereof.

God's laws tend to be relatively simple, even if they aren't exhaustively thorough. They are designed so that even a child can understand the basic principles. They aren't always crystal clear in structure or purpose, but like secular laws, religious laws can be clarified and expanded -- not by legislatures or judges, but by God's servants and messengers. And unlike secular laws, God's laws always have an element of subjective application. Thus, there is considerable variation within the Mormon Church with respect to certain practices, such as paying tithing on gross or net income, drinking or avoiding Coke, etc.

Even though a Word of Wisdom with a definition section would be easier to follow, it doesn't seem like a good idea. God's laws weren't meant to be subjected to textual analysis, but rather, inspired guidance and illustration by His servants. Attempting to quantify and dictate every aspect of worship was precisely what the Pharisees of Jesus' time were trying to do, and that didn't work out too well for them. Worship was never intended to require legal counsel -- it is a personal relationship with Deity. So now when the members of my Sunday School class question how much meat consumption qualifies as "sparingly," I sit back and smile. If that's what it takes in order to keep the Gospel of Jesus Christ from devolving into arcane legal discussions, then it's a small price to pay.

Friday, June 26, 2009

Best (or Worst) Law Suits Ever Filed

The Top Ten most ridiculous law suits ever filed was compiled by The Independent (UK).
  1. The man who sued Budweiser after drinking the beer which brought him no hot women.
  2. The prisoner who sued himself for violating his own civil liberties.
  3. The Judge, Roy Peterson, who sued the dry cleaners for $65M after they lost his pants.
  4. The Turkish city of Batman who sued "Batman" the movie.
  5. The 77 year old man who sued the 19 year old girl who said 'no' to his sexual advances.
  6. A driver who sued the family of the cyclist he killed for damages to his car.
  7. The Michael Jordan look-a-like who sued Nike for making Jordan too recognizable.
  8. The parents who sued Oliver Stone after their kids saw his movie and went on a crime spree.
  9. The man who demanded his cheating wife return the kidney he donated to her.
  10. The copyright battle over two separate recordings of silence.
Number ten on the list is pretty good but I don't think any of them can beat Mr. Jack Ass's law suit against Viacomm. In 1997, a Montana man legally changed his name to Jack Ass. A few years later, MTV began airing "jackass" the TV show. Mr. Ass claimed that MTV had plagiarized and defamed his name. Ass's lawsuit states that Viacomm is "liable for injury to my reputation that I have built and defamation of my character which I have worked hard to create."

Apparently, he had a hard time finding the "right" attorney for the case. "I couldn't find an attorney. Listen, lawyers are not just going to pipe up--they're not going to say they don't have courage. They give me lame excuses. One is too busy. They won't do it on contingency (what why not?). Some say I may have a case and they want to look deeper. Then they don't call back."

So what do you do when you've got a great case and you can't find an attorney to help you out? Well, you represent yourself. Ass filed the suit on his own and said "Anyone can do it. You do some research. And there's some rules you have to learn." Apparently

I wonder if in all his research he learned what a 12(b)6 motion is?

Monday, June 22, 2009

Legal Briefs: Former missionaries, SCOTUS, and the Christian Legal Society

  • A group of former LDS missionaries in Utah seek to foster dialogue among Mormons about about immigration and to repeal Utah SB81. Salt Lake Tribune
  • The AP has a round-up of the U.S. Supreme Court's activity today. Associated Press
  • The Christian Legal Society’s Center for Law & Religious Freedom and the Alliance Defense Fund Center for Academic Freedom are appealing to the Ninth Circuit the Montana District Court decision upholding the Montana Law School's refusal to recognize the Christian Legal Society based on its nondiscrimination and open membership policies. The J. Reuben Clark Law Society's membership policies are distinct from those of CLS, but similar enough that this case is worth watching. Alliance Defense Fund Press Release
  • Benjamin Speakman was sentenced to 36 months of probation for weapons violations in his threat to enter the Jordan River Temple and kill people. Speakman admitted to cutting down the barrel of a 12 gauge shot gun that was not registered to him. He agreed to turn over the shotgun, a 9mm pistol, and an AK-47 to authorities.

Saturday, June 20, 2009

$134 Billion Suitcase Follow-Up

Glenn Beck weighs in on the $134 Billion suitcase. This story just keeps getting weirder and weirder. Two men were arrested with 1% of the United States GDP in their suitcases and the NY Times has yet to weigh in on the subject.

Friday, June 19, 2009

Non-Legal Brief: What About the 134 Billion Found in a Suitcase?

  • This is a non-Mormon event but the story about the two Japanese men arrested in Italy attempting to smuggle $134.5 BILLION (yes, with a "B" not an "M") of U.S. bonds into Switzerland is such a fascinating story that if you haven't read about it yet here is a good summary of the situation. I can't wait to see how this story unfolds. William Pesek of

Thursday, June 18, 2009

Legal Briefs: Update to PBS Religious Programming Ban

In an update to a Legal Brief from May 19, PBS announced Tuesday that it would ban member stations from carrying new "sectarian" programs, but in most cases would allow existing programs to continue. This policy, which was a compromise from a proposed ban that would have terminated all such programming, allows stations such as KBYU to remain affiliated with PBS without forcing an immediate change in programming. Washington Post has more.

Tuesday, June 16, 2009

Legal Briefs: Possible Vegas-Mormon Hate Crime, Online Commenters and More

  • Las Vegas metro police and the FBI are investigating a possible hate crime in east Las Vegas. Someone drew slurs in front of a family's home that included "I hunt Mormons" and another one that indicated there was a bomb in the family's van. KNTV
  • LDS Spokesperson Michael Otterson: "In a democracy, we justifiably set the bar pretty high for freedom of religious expression and conscience. But our societies enact and enforce laws against antisocial behavior or extreme actions that threaten others, without which our communities would collapse. When people choose to cross the line, they face the consequences." Washington Post
  • Utah AG Mark Shurtleff's proposed settlement with FLDS church. Religion Clause
  • Vegas paper gets subpeona to ID online commenters. The subpeona bears the name of U.S. Assistant District Attorney J. Gregory Damm; to which commenters replied that "socialist, fascist Mormon" and "Nazi moron". Associated Press

Problems (and some solutions) with student debt

his week the New York Times has run a series of articles on the increasing costs of a college education. In an article Sunday entitled "How Much Student Debt is Too Much?", several student loan experts weighed in on the issues and costs of mounting student debt. One of those people was Robert Applebaum, a lawyer who advocates canceling student debts as a method for stimulating the economy. I thought his last two paragraphs were particularly good:
Until higher education becomes a safe investment again, prospective borrowers should give greater thought to the financial consequences of seeking an advanced degree. Community colleges and state schools are probably better places to “find oneself,” than expensive private institutions, particularly if the student doesn’t really know what he or she wants to do for a living. Associates degrees and trade schools are other avenues to consider.

None of this is to suggest that a liberal arts education isn’t good for the mind and spirit — but whether it’s as wise a financial investment as it once was requires serious consideration. 
I would be the last person to discourage a prospective law school student from pursuing that course. But given the uncertainty in the market and the changing face of the legal profession, any future lawyer should think long and hard about the costs associated with a legal education. This is particularly difficult for law students because the education costs are higher than almost any other discipline, and because school rank is such a large factor in finding employment.

There is a lot of frustration building with respect to student debt, especially since many colleges are raising tuition and slashing financial aid at the same time students and their parents feel the pinch from the economy. Some of the comments from the first NY Times article I mentioned were published yesterday in a collection entitled "Student Debt, Fool's Gold?"

It isn't all bad news, however. Beginning on July 1 of this year a new Income-Based Repayment program will go into effect for federal student loans. This will cap payments for borrowers based on income and family size. Previously, federal loans didn't take into account a borrower's number of dependents, which was especially hard on borrowers with larger families. There is also a new Public Service Loan Forgiveness program for borrowers of federal loans who work in the public sector or qualifying non-profits. Of course, these programs only apply to federal loans, which currently have a $18,500 per year cap. That isn't enough to cover tuition at many law schools, which often exceeds $40,000. But if you have a family, a public interest job, and six figures of student debt, every little bit helps.

Photo credit: AMSA.

Monday, June 15, 2009

Legal Brief: The DOMA Brief, W. Scott Simpson, and Mormon Lawyers

There has been a firestorm of comments from around the internet in response to the Defense of Marriage Age Brief (especially because a Mormon lawyer seems to be involved, oh no!). Here are some articles on the subject.
  • Andrew Sullivan publishes a dissent to his original article The Daily Dish
  • "It was (the DOMA brief) breathtakingly bigoted, like something written by a graduate of Jerry Falwell's madrassa, Liberty University. Well guess what? It was written by the Bush Administration, W. Scott Simpson and guess what else? He's a Mormon" the Stranger
  • Obama on DOMA He is keeping his promise Daily Kos

Saturday, June 13, 2009

TIME Magazine on the Mormon Church

Next week's issue of TIME Magazine has a pretty lengthy piece on the LDS Church.  Entitled "The Storm Over the Mormons," the article discusses some of the fallout and criticism surrounding the California Proposition 8 campaign, as well as the mission and structure of the Mormon Church.  The main focus of the article isn't legal, but it does touch on some topics such as religious political activism and the Mormon Church's tax-exempt status.  The article cites at length the experience of Jay Pimentel, a lawyer and bishop in Almeda, California.  Nothing in the article is particularly earth-shaking, but it's a fairly well-written and interesting piece with no major factual innaccuracies, which I can appreciate. The article is available here.

Job of the Week: General Counsel in San Jose

Health care is faring relatively well in the recession. The latest Job of the Week is a position with a leading company in the field.

Lateral Link is where you will find useful information on the top law firms as well as various resources, including articles and career coaching information. New in the Resource section this week is an article by Tricia McGrath entitled Keeping Your Career "On Track" in a Down Market.

Position: General Counsel

Location: San Jose, CA

Description: A major provider of innovative medical products for use in the field of women's health is seeking a General Counsel. The attorney will head the legal department and will be responsible for providing legal and business advice to senior management and will lead and coordinate the general corporate policy needs of the company. The candidate must be a member of the California bar and have a minimum of 10 years experience, preferably in the health care or medical device Industry. In addition, a combination of in-house and top tier law firm experience is preferred, but exceptional candidates that do not have diverse experience will be considered. Experience with international contracts is also preferred.

Interested applicants can also contact Theresa DeLoach at to discuss this position. Membership in Lateral Link is free, and you can apply at

Friday, June 12, 2009

Hackers hijack the LDS Church News Twitter Account

LDS Church News revealed that hackers hijacked the Church News Twitter account last weekend. Twitter staffers took down the site because the infiltrators had gained total control over the feed.

Charlie Crane, director of interactive media for the Deseret News, said he realized Sunday night that the Church News account had been compromised. "We tried to get it back," he said, but he soon realized that the hacker had even been able to change the password and lock him out. "I don't know how they got the password," Crane said. "I'm very skeptical (of Twitter) now." He expressed concern for other Twitter accounts the Deseret News operates.

Crane said the hacker posted some anti-Mormon material on the site earlier this week. The Church News and Deseret News are owned by The Church of Jesus Christ of Latter-day Saints through Deseret Management Corp. There's no indication yet when the feed will be up again, but Twitter administrators said they would be contacting the Deseret News later today about restoring the Church News account.

Other Twitter accounts have been hacked into recently, including that of the New York Times and baseball coach Tony LaRussa. Unlike many online accounts, like those for Facebook, Twitter does not send a confirmation e-mail when a user changes a password, Crane said. We commented on this problem several months ago after someone had set up a Twitter account to impersonate President Thomas S. Monson. Twitter needs to come up with some solution to this problem or they may find themselves in a lawsuit or alienating their users.

I want everyone to sleep well tonight, the Mormon Lawyers Twitter account has not been hijacked.

Thursday, June 11, 2009

A Man for All Seasons movie review

My A Man for All Seasons, movie review. I thought this was a really well written, well acted, thought provoking movie. Before watching the movie I didn’t know anything about the story of Sir Thomas More or his impact on world history. (I watched the 1966 version of the movie which won 6 academy awards). Attending a Catholic law school I think was the only person who didn’t know that attorney Thomas More was canonized by the Roman Catholic Church (1935) and declared patron saint of politicians and statesmen (2000).

I enjoyed this conversation between Saint Thomas More and a former friend, Norfolk:

"Norfolk: Oh, confound all this.... I'm not a scholar, and frankly I don't know whether the marriage was lawful or not. But damn it, Thomas, look at those names.... You know those men! Can't you do what I did, and come with us, for fellowship?

More: And when we stand before God, and you are sent to Paradise for doing according to your conscience, and I am damned for not doing according to mine, will you come with me, for fellowship?"

Later, More's future son-in-law, Roper, urges him to arrest Richard Rich, whose perjury will eventually lead to More's execution.

More answers that Rich has broken no law, "And go he should if he were the Devil himself until he broke the law!" Roper is appalled at the idea of granting the Devil the benefit of law, but More is adamant.

"What would you do? Cut a great road through the law to get after the Devil? ... And when the last law was down, and the Devil turned round on you - where would you hide, Roper, the laws all being flat? This country is planted thick with laws from coast to coast, Man's laws, not God's, and if you cut them down -- and you're just the man to do it -- do you really think you could stand upright in the winds that would blow then? Yes, I give the Devil benefit of law, for my own safety's sake!"

As attorneys (or future attorneys) there will be times that we are asked to do things that are legal but against our own moral beliefs. If we aren’t true to ourselves it will be hard to live with ourselves.

Holy Spirit lawsuits

I live in the Southeastern United States, where Mormons are a small minority compared to other evangelical denominations. One comment I have heard from people who visited my church for the first time is how different the services are from some other churches. Many of these first-time visitors to LDS church meetings are struck by the absence of church bands, congregational utterances ("Amen!"), or public displays of spiritual experiences. The Mormon concept of "Holy Spirit" is a much more subdued affair than in some evangelical denominations, where fainting, convulsions, and speaking in tongues are not uncommon.

It turns out that the Mormon approach has at least one advantage: less injuries. One of my favorite legal blogs, Kevin Underhill's excellent Lowering the Bar, has recently reported on a couple personal injury suits arising from incidents in churches where a congregant was "taken by the Holy Spirit" and fell backwards. Apparently this is a common enough occurrence that the congregations have "catchers" ready to catch the falling people, but they don't always work. In one case the catchers dropped the falling man, and in another case, the falling person injured one of the catchers. Yikes! Who knew going to church could be so dangerous? Fortunately, most Mormons are only in danger of falling asleep during a long-winded talk on High Council Sunday.

Photo credit: Riveroyster.

Monday, June 8, 2009

9th Cir. rejects challenge to SF anti-Catholic resolution

(Note: This is a more thorough treatment of last week's Legal Brief about Catholic League for Religious and Civil Rights v. City and County of San Francisco.)

In 2006 the City Council of San Francisco adopted a resolution that criticized the Catholic Church's stance on homosexuality. Catholic Charities, like LDS Social Services, acts as an adoption agency. The Archdiocese of San Francisco had instructed the agency to not place children with gay couples, and the San Francisco City Council's response called the policy an "insult to all San Franciscans" and "unacceptable to the citizenry of San Francisco, and also stated:
Such hateful and discriminatory rhetoric is both insulting and callous, and shows a level of insensitivity and ignorance which has seldom been encountered by this Board of Supervisors 
The Catholic League for Religious and Civil Rights filed a 42 U.S.C. § 1983 civil rights suit against the City for violations of the Establishment Clause. That action was quickly tossed out on a 12(b)(6) motion for failure to state a claim, and the Catholic League appealed to the Ninth Circuit Court of appeals. The Ninth Circuit issued its ruing on Wednesday, and once again rejected the Catholic League's claims.

At its heart, this case is an application of the misnomered Lemon test. As the Ninth Circuit cites it, the Lemon test permits government action if  it “(1) has a secular purpose; (2) has a principal or primary effect that neither advances nor disapproves of religion; and (3) does not foster excessive governmental entanglement with religion.” Failure to meet any of the three factors will cause the action to fail constitutional scrutiny.

In what I believe is a flawed analysis, the Ninth Circuit held that the City's statement passed the Lemon test. As an initial matter, it is worth pointing out that the so-called Lemon test can be somewhat misleading, since the balancing process was really established in two previous Supreme Court cases. Under U.S. v. O'Brien and Clark v. Community for Creative Non-Violence, the courts are to balance the secular purposes of the government with the principal or primary effect of advances/prohibits religion. This is essentially the same framework the Supreme Court established to deal with accidental interferences with religion or free speech. Under the O'Brien/Clark doctrine, an interference with religion is unconstitutional if the interference is intentional. I think it is clear that the City of San Francisco's pointed statement intentionally targeted a specific denomination and criticized its beliefs.

The Ninth Circuit found that the City's purpose was primarily secular. I can see good arguments on both sides, since sexual orientation equality is a valid secular purpose under California law. I'm not sure I agree that the City's purpose was to establish equality -- more likely it was to criticize the Catholic Church -- but reasonably minds could differ. What I find untenable is the Ninth Circuit's finding that the primary effect of the City's resolution did not disapprove of religion.

This is not a well-crafted opinion. The Ninth Circuit's language on pages 11-12 of the preliminary copy of the opinion is ambiguous at best, and may even evince the judges' predispositions. That portion of the decision refers to the City's secular interest in promoting same-sex adoption; if the City indeed had such a goal to support same-sex adoptions over heterosexual adoptions it would be unconstitutional.

Another significant flaw in the decision was pointed out by Richard Thompson, who argued the case on behalf of the Catholic League:
“This dismissal was based on grounds that the pleadings failed to state a claim under the rules of civil procedure.  Although the panel correctly posited the rule that they must accept all of Plaintiffs’ allegations as true and draw all reasonable inferences in favor of the Plaintiffs, the court totally ignored the rule in its opinion and drew all inferences in favor the San Francisco including their intent in enacting the resolution without allowing Plaintiffs to engage in any discovery.”

Even though the decision was unanimous, Judge Marsha Berzon filed a concurring opinion that signaled at least some discomfort with government criticism of religious views. Citing Judge John Noonan's dissent in the similar case American Family Association v. City and County of San Francisco, Judge Berzon wrote:
". . .I am acutely aware that ‘the Constitution assures religious believers that units of government will not take positions that amount to the establishment of a policy condemning their religious belief,’ . . . and that resolutions such as the ones in American Family and the one in this case are near – if not at – the line that separates establishment of such a policy."
In my opinion, that line was crossed in both American Family and Catholic League.

The issue is probably not settled yet -- the Thomas Moore Law Center, which conducted the appeal, plans on seeking rehearing en banc.

                                                                                                                                                                                              Catholic League for Religious and Civil Righst v. City and County of San Francisco            peterrtenn                             A Ninth Circuit Court of Appeals ruling rejecting a challenge to a San Francisco City Board resolution that criticized the Catholic Church's policies on homosexuality.                                       
Photo credit: brothergrimm.

Saturday, June 6, 2009

Job of the Week: Corporate Counsel in Seattle Washington

Wow! An in-house job for a junior attorney with a company that we know you've used before (but we can't post too much revealing information about the company here). Check out the details below.

As always, the Job Of the Week is brought to you by Lateral Link. Lateral Link is continually identifying opportunities for qualified attorneys at all levels throughout the U.S., Europe and Asia. In addition, Lateral Link has recently obtained openings with prominent media, technology, and real estate companies for attorneys who have elected to participate in a firm sponsored deferment program.

Position: Corporate Counsel

Location: Seattle, WA

Description: This world-famous internet company is searching for a talented corporate counsel. This attorney structures, drafts, negotiates and counsels the business teams on a broad range of commercial transactions related to design and construction, equipment procurement and leasing, fulfillment logistics, services, product supply, distribution, and general corporate services. This position also provides day-to-day business law counseling; researches regulatory issues and manages compliance initiatives; administers and resolves legal issues that arise in existing commercial relationships; and handles pre-litigation legal disputes and inquiries.

For more information on this position or to apply, please see position #24979 on Lateral Link. Interested applicants can also contact their personal search consultant to discuss this position. Membership in Lateral Link is free, and you can apply at

Legal Briefs: No Establishment Clause Violation in San Francisco's Condemning the Catholic Church's Refusal To Help With Adoptions by Same-Sex Couples

Thursday, June 4, 2009

New Hampshire Governor John Lynch signs same-sex marriage bill

Last month we covered the debate in New Hampshire over Governor John Lynch's proposed amendments to a same-sex marriage bill that would provide certain religious protections for clergy and religious organizations. The New Hampshire house refused to accept Governor Lynch's proposed language and the bill had stalled. Today various media outlets are reporting that the bill has been signed into law, and that most of the religious protections survived committee review.

I think this is an encouraging first step in reconciling religious liberties and the seemingly inevitable expansion of same-sex marriage. As his signing statement indicated, Governor Lynch clearly recognized this tension and sought to address it in a way that had not been done in any other state so far. (This, by the way, is one of the reasons why such measures are best performed by the legislature rather than the judiciary.) Governor Lynch's proposed language didn't go far enough in my opinion because it fails to protect the religious liberties of individual that are not clergy or managed by a religious organization. But at least New Hampshire recognized those religious rights, which is more than can be said for Massachusetts or California.

Photo credit: marcn.

Wednesday, June 3, 2009

Professors Say the Darndest Things...

Yesterday one of my professors said "dot your j's...ahhh lower case j's that is ". This reminded me of some of my favorite things professors have said during class; "Using this statute is like wearing a belt and suspenders at the same time", "if you're going to sue someone under this tort you better go after them whole hog", "sack of snakes"-- I never did understand what my professor was trying to say when she used this phrase, but she said it all the time and it would make me giggle each time she did. I look forward to adding more phrases to this list over the next year! Let us hear of the funny things you've heard professors say.

Bybee, Mormons and Torture, the debate continues

It has been weeks since we first began discussing Judge Bybee's role in the Bush administration's rough interrogation tactics but the debate still rages on. Ann Wright recently wrote an article for the Huffington Post; Two Mormons, Two Different Ethics on Torture. Wright says in part;

"In September 2003, another Mormon, a woman soldier U.S. Army Specialist Alyssa Peterson, said she refused to use the interrogation techniques Bybee had authorized on Iraqi prisoners. An Arabic linguist with the U.S. Army's 101st Airborne Division at Tal Afar base, Iraq, 27-year-old Peterson refused to take part in interrogations in the "cage" where Iraqis were stripped naked in front of female soldiers, mocked and their manhood degraded and burned with cigarettes, among other things. Three days later, on September 15, 2003, Peterson was found dead of a gunshot wound at Tal Afar base. The Army has classified her death as suicide."

"Jay Bybee, in thanks for his being the loyal soldier to the Bush administration's policies of torture, was nominated and confirmed by the U.S. Senate as a judge on the Ninth Circuit Court of Appeals, where he sits to this day in his lifetime appointment. Jay Bybee, an author of torture, reportedly has a placard in his home for his children "We don't hurt each other."

“Alyssa Peterson, for saying no to torture, is dead, perhaps by her own hand.”

“To help Alyssa Peterson rest in peace, I say we should demand accountability from our officials and impeach the torture judge, Jay Bybee.”

Should the fact that Bybee is Mormon be such a focal point? Are all Christians held to the same standard or is more expected from Mormons?

Monday, June 1, 2009

A confusion of categories

I occasionally use a couple blog aggregators to find interesting posts in the Bloggernacle. Some of them group blogs by popularity; others by category. Imagine my surprise when a few of our recent posts ended up in the Sexuality category of one such aggregator.

Really? Does anything related to Prop 8 have to do with sexuality? I guess remotely, but that's not exactly the focus. Although it would be interesting to see if our readership increased as a result. They say sex sells.