Michigan Supreme Court

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Michigan Supreme Court


Sitting Justices
Clifford Taylor
Michael Cavanagh
Elizabeth Weaver
Marilyn Jean Kelly
Maura Corrigan
Robert Young
Stephen Markman
2008 challengers
Diane Hathaway
Former justices
Michigan on Judgepedia


The Michigan Supreme Court is the court of last resort in Michigan. Seven justices sit on the court. The judges on the court are chosen in non-partisan elections but they can be nominated to run for justice at political party conventions or through a nominating petition.

The court receives over 2000 requests each year to consider lower court rulings on appeal. Its decisions take the form of orders, which are not required to include a written opinion on the case. A Supreme Court order either affirms or reverses the Court of Appeals, or remands the case to the trial court for further proceedings; an order may also adopt a Court of Appeals opinion as the correct rule of law.

Under its state constitution, Michigan organizes its court system as "one court of justice". Within this integrated system, trial court jurisdiction rests in Circuit, district, and probate courts. An intermediate appellate court, known as the Michigan Court of Appeals, hears appeals from the Circuit Court, and possesses discretion to hear other types of appeals. The Supreme Court’s jurisdiction includes discretionary power to hear appeals, primarily from the Court of Appeals. [1]

The Michigan judiciary consists of the supreme court, the court of appeals, the circuit court, and various trial courts of limited jurisdiction.[2]

Composition

Seven justices sit on the Michigan Supreme Court. On the ballot, incumbents are listed as "a 'Justice' of the 'Supreme Court', while their challengers have no such legitimacy-enhancing descriptions by their names.[3]

Political Recognition

Under Michigan’s unique system, political parties nominate candidates to run for election to the Supreme Court. In the election, however, candidates run on a non-partisan ballot.

Although Justices run on a non-partisan ballot, voter awareness exists of the candidate’s political affiliation. Recent costly and controversial campaigns (more akin to partisan gubernatorial races), reflect the oft-times partisan nature of these elections. At issue in recent elections is the proper role of the court in a constitutional democratic republic.[4]

Eligibility

"Eligible candidates for the Michigan Supreme Court include qualified electors under 70 years old, licensed to practice law in Michigan for at least five years. Justices on the Michigan Supreme Court serve eight-year terms and may run for re-election. Not all of the justices run for election at the same time. Every two years the terms of two justices begin, with the term of one justice beginning in the eighth year." [5]

The Governor's Role

"The Governor temporarily fills, by appointment, any vacancy occurring on the Court. The Governor’s appointment lasts until the general election, at which time the electoral process engages. The winner of the election fills the vacancy for the remainder of the term. Every two years members of the Court elect one of their own to serve as Chief Justice." [6]

Overview

"Each year, the Court receives over 2,000 new case filings. Cases come before the Court during a term that starts August 1 and runs through July 31 of the following year. The Court hears oral arguments in Lansing beginning in October of each term. Decisions are released throughout the term, following oral arguments."[7]

In most cases, the litigants seek review of Michigan Court of Appeals decisions, but the Supreme Court also hears cases of attorney and judicial misconduct, as well as a small number of matters over which the Court has original jurisdiction. The Court issues a decision by order or opinion in all cases filed with it.

The Court's other duties include overseeing the operations of all state trial courts; the Court is assisted by the Michigan State Court Administrative Office, an agency of the Court. The Court's responsibilities also include a public comment process for changes to court rules, rules of evidence, and other administrative matters. The court has broad superintending control power over all the state courts in Michigan.

Under Article 6, Section 30 of the Michigan Constitution, the Michigan Judicial Tenure Commission is created. This is an agency within the judiciary, which has jurisdiction over allegations of judicial misconduct, misbehavior, and infirmity. The Supreme Court is given original, superintending control power, and appellate jurisdiction over the issue of penalty (up to and including removal of judges from office).[8]

The Court is located in the Michigan Hall of Justice in Lansing, the state capital.

History

Michigan became an independent territory in 1805. On July 24 of that same year, the first Supreme Court for the new Territory of Michigan was created. Its first Justices were Augustus B. Woodward, Frederick Bates, and James Witherell. The first session of the territorial Supreme Court was held on July 29, 1805. From July 9 through October 8, 1805, a series of statutes, known as the Woodward Code, was created to serve as the basis of Supreme Court legal procedure in the Michigan Territory. Complaints about the inadequacies of the Code soon began to mount. Some issues, such as indefinite tenure, were corrected; in March of 1823, an act was passed that limited the terms of Supreme Court justices to four years. However, many of the controversies surrounding the Woodward Code endured well past 1835, the year Michigan adopted its first Constitution.

The First Constitution

The Constitution of 1835 proposed a state judiciary centered around the Supreme and Circuit Courts. It established a peripatetic Supreme Court of three Justices, any two of whom constituted a quorum. One session of the Supreme Court was to be held annually in one of the three judicial circuits: Wayne, Washtenaw, and Kalamazoo. One of the primary duties assigned to the justices by the Constitution was to preside over the Circuit Courts in each of their representative districts. The Supreme Court was the only tribunal established by the Constitution. All others were provided by statute. Justices of the Court were appointed by the governor, with consent of the senate, for seven-year terms. Judges of the Probate and all County Courts, as well as Associate Judges of the Circuit Courts, were to be elected by the electors of the county in which they should reside.

The Constitution also provided the Supreme Court with both original and appellate jurisdiction in common law and equity cases. The jurisdiction of the Supreme Court established by the Constitution of 1835 was in many ways identical to the jurisdiction of the territorial Supreme Court. This included limited original jurisdiction over action of right and the extra legal remedies of mandamus, quo warranto, and habeas corpus. The Court was also granted appellate jurisdiction to review Circuit Court decisions by writs of certiorari. The Constitution also established a separate Court of Chancery, allowing for appeals from the Court of Chancery to be made to the Supreme Court. On July 18, 1836, Governor Stevens T. Mason nominated fellow Democratic Party members William A. Fletcher, George Morrell, and Epaphroditus Ransom to be Chief and Associate Justices of the Michigan Supreme Court, respectively. Morrell was assigned to the first Circuit Court, Fletcher to the second, and Ransom to the third. Each appointee was approved by an almost unanimous vote in the Senate.

Early Flaws

There were also flaws with the jurisdiction of the Supreme Court. The Constitution of 1835 extended Supreme Court jurisdiction only to those cases that might arise within the judicial circuit in which it was then sitting. Thus, a case that originated in the Kalamazoo district could not be heard in the Washtenaw or Wayne districts but only in Kalamazoo. Because the Detroit area was the most densely populated, and was at that time the "home" of the Supreme Court, the majority of the cases were heard in the Wayne district.

The need to correct these and other flaws led to the revision of the original Woodward Code. Circuit Court Judge and future Supreme Court Chief Justice William A. Fletcher was commissioned to revise the Code. Fletcher’s changes to the Code met limited success. He eased the geographic limitations of the Supreme Court's jurisdiction, extended both the original and appellate jurisdiction of the Court (to a certain degree), and created a fourth judicial circuit and a fourth Supreme Court Justiceship to help alleviate some of the workload. In adding a fourth Supreme Court Justice, however, Fletcher did not raise the numerical requirement for a quorum, meaning that only two out of the four Justices needed to be in agreement.[9]

Throughout the entire decade of the 1840s, the court system, in particular the Supreme Court, was under a constant barrage of political attacks. The Michigan Constitution of 1850 made several important changes to the Court, and more were amended as the legislative and political process slowly evolved. In the end, the Court, despite many setbacks and compromises, came out with more authority and independence, a trend that continued during the latter half of the 19th Century and well into the 20th. The most significant changes resulting from the constant pressure for judicial reform throughout the 1840s were the elimination of the separate Court of Chancery, the change from appointment of superior court Justices to popular elections, and a Supreme Court comprised of four members: one Chief Justice, and three associates.

Constitution of 1908

The Constitution of 1908 did not make any major changes to the Court. For the first time in its history, the state Supreme Court (and the judicial branch in general) survived a new constitution without being significantly altered. However, several items were added to the new constitution that would affect the Court. Soon after it was adopted, for example, several amendments were added pertaining to reapportionment, woman and child labor law, the direct primary election, and the election of the state highway commissioner. In 1913, additional amendments were added that strengthened the powers of initiative and referendum. The amendments passed in 1913 also granted voters the ability to propose constitutional amendments, which up until then could only be done by the legislature.

20th Century

A number of changes were made by another new constitution, the Constitution of 1963. The executive branch of the state government was consolidated into 20 departments, terms of office were expanded, and the legislature was expanded to 38 Senators and 110 Representatives, and the Court of Appeals was created in the judicial branch. In addition, the number of justices sitting on the Supreme Court was reduced from eight to seven, a level that it has since maintained (the actual reduction, however, did not occur until 1969). The most significant change, however, was the creation of the Civil Rights Commission, designed to secure equal protection of the law for all people.[10]

Revisions: Failed and Successful

"Four attempts were made to call a Constitutional Convention for the purpose of revising the Constitution of 1908 before the question was approved by the voters on April 3, 1961. A primary election for the purpose of electing delegates was held on July 25, 1961, and on September 12, 1961, one hundred forty-four delegates were elected. The delegates met at Convention Hall in the Civic Center, Lansing, on October 3, 1961 and adopted the proposed Constitution on August 1, 1962. The Constitution was submitted at the election of April 1, 1963, and adopted. A recount established the vote as 810,860 to 803,436. The effective date of the Constitution of 1963 is January 1, 1964."[11]

Elections

Supreme Court Agrees to Hear Ballot Measure Appeal

In August 2008, the Michigan Supreme Court agreed to hear an appeal by advocates for the Reform Michigan Government Now! ballot measure that was thrown off this year's November ballot by a three-judge panel. Because the measure was a "general revision" of the state constitution, the panel said the ideas must be considered at a constitutional convention. Assuming the high court agrees to put the measure on the ballot, and it passes, two Justices, Stephen Markman (R) and Robert Young (R)--both Democratic Party targets-- will be out of job December 20, 2008.

In an order, the justices said they have an obligation to hear the case, noting that: "RMGN has not asserted, nor do we believe there is any basis for a claim, that we harbor any 'actual bias' for or against any party."[12]

Trial Lawyer objects to Chamber's interest in the Courts

According to former Michigan Trial Lawyer Association president Jesse M. Reiter, over the last several election cycles, the U.S. Chamber of Commerce has been funding state Supreme Court seats across the country. As a result, many state supreme courts, which were "once fair and neutral", now favor big business interests. According to Reiter: "buying a new court... [is] far cheaper than changing the direction of fifty legislatures." [13]

2000 Election

The 1998 elections produced the first Republican-dominated supreme court since 1976. In this context the 2000 elections, in which three Republican incumbents were on the ballot, took on heightened significance. The 2000 races were the most expensive and contentious judicial contests in the state's history. A total of between $13 and $15 million was spent by the candidates, the Republican and Democratic Parties, and outside interest groups. The campaigns also featured controversial advertisements. A Democratic Party ad characterized three incumbent supreme court justices as "anti-family," while the GOP sponsored an ad that criticized a challenger for having joined in a decision upholding a light sentence for a pedophile.[14]

Important Cases

Supreme Court Rules on Government Liability (5/30/08)

On April 25, 2008, the Michigan Supreme Court issued its opinion in Estate of Chantell Buckner v. City of Lansing. In it, the Court applied statutory interpretation to further narrow an exception to governmental immunity. Three girls (ages 7, 13, and 14) were walking to a fast food restaurant from their house nearby. The sidewalk on which they were traveling became impassible due to an accumulation of ice and snow that had been deposited there by a plow operated by the City of Lansing. It was the policy of the City not to plow that stretch of sidewalk. The three girls ventured along the curb. Two of the girls were struck by a car. Both were very severely injured, and the youngest of the three died from her injuries.

In Michigan, governmental agencies such as cities enjoy immunity from tort liability except for six specific scenarios. One such exception is known as the "Highway Exception" and is explained by MCL 691.1402(1), which states that a governmental agency "shall maintain the highway in reasonable repair so that it is reasonably safe and convenient for public travel." The section goes on to explain that an individual who is injured "by reason of failure of a governmental agency to keep a highway ... in reasonable repair and in a condition reasonably safe and fit for travel" may recover from the governmental agency for those injuries. Importantly, MCL 691.1401 expressly includes sidewalks in the definition of "highway." The City of Lansing brought a motion to dismiss the case based on the argument that no actual structural defect existed in the sidewalk’s construction. The trial court denied the motion, and the Court of Appeals affirmed that decision. Both courts noted that while a structural defect requirement might be appropriate for natural accumulations of snow, this particular case differed because the city had placed the snow on the sidewalk deliberately.

A 4-3 majority of the Michigan Supreme Court reversed the decisions of the lower courts. The three dissenting Justices, led by Justice Elizabeth Weaver, would have affirmed the lower courts and ruled on behalf of the plaintiff. Justice Weaver concludes that this expansion of governmental immunity "in a one-page order, instead of a full opinion, appears to be an attempt by the majority to conceal its latest example of judicial activism by unrestrained statutory interpretation."[15]

By contrast, in a concurring opinion Justice Stephen Markman noted that Justice Weaver's arguments in her dissent had "the potential to mislead future litigants and which seek to replace the policy determinations of the Legislature... with those of Justice Weaver."

Racial Voting Rights

An important judicial decision was rendered in 1866. The issue in the case, People v. Dean, was whether or not a man – who was part black – was eligible to vote. The Civil War had just ended, and advocates for black male suffrage and equal rights in general were at the peak of their influence. Dean, who was determined to be of approximately “one-sixteenth” African descent, was found to be in violation of a Michigan Constitutional provision granting suffrage only to “white male citizens”. In his written opinion, Campbell interpreted the law to include persons with “less than one-fourth of African-blood”. Under this ruling, Dean was eligible to vote because he was only one-sixteenth African. Explaining his reasoning in this decision, Campbell asserted, “…the right of the people to determine the qualification of electors is undisputed. We are bound to adhere to the rule they have established. The right to vote is granted to a certain designated class, and to no others”. While Justices Cooley and Christiancy both concurred with this ruling, George Martin dissented, calling the exclusion of blacks from the right to vote a “rule of slavery” and questioning the courts authority to exclude persons with any level of African blood from full citizenship.

Public Monies for Private Enterprise

Just four years after the Dean case, the Michigan Supreme Court ruled on another widely-debated issue. The case, People ex rel the Detroit and Howell Railroad Co. v The Township Board of Salem (popularly known as People v. Salem) not only reflected the growing reputation of the "Big Four" (then justices Christiancy, Campbell, Cooley and Graves) and their disregard for popular politics, but also further established the Court's independence and authority.

The case involved public use of money to aid the building of privately owned railroads. The Michigan constitution of 1850 severely limited the state's participation in internal improvements. By 1870, the railroad debate became one of the state's most politically charged issues. At stake in People v. Salem was an application for mandamus by the Detroit and Howell Railroad Company to compel the Township Board of Salem to execute and issue bonds to aid in the construction of the proposed railroad. The Circuit Court of Washtenaw County ruled in favor of the railroad, and the case was then brought to the Michigan Supreme Court for appeal. The Court overturned the decision and deemed it unconstitutional. In his written opinion, Chief Justice Cooley addressed the issue of whether or not the railroads were a public entity. He concluded that in one sense they were "public highways" because they aided the public in travel, but otherwise:

They are not, when in private hands, the people's highways; but they are private property, whose owners make it their business to transport persons and merchandise in their own carriages, over their own land, for such pecuniary compensation as may be stipulated.

Both Justices Campbell and Christiancy concurred with Cooley's decision, although Campbell differed in his interpretation of "obligation of contracts." Justice Benjamin Graves dissented.

Abortion Cases

In November of 1972, immediately prior to the Supreme Court's decision in Roe v. Wade, the people of Michigan overwhelmingly voted to uphold their ban on abortion--i.e. abortions were still considered illegal unless executed in order to save the mother's life (the ban had only been amended a few times since its inception in 1846, and with little consequence).[16]

"In the decades since Roe v. Wade...the Supreme Court of Michigan has only addressed the question of abortion rights directly in two June 1973 companion cases: People v. Bricker and Larkin v. Calahan. In Bricker, the defendant was charged and convicted of attempting to perform the abortion procedure in violation of Michigan’s penal code under section 750.14 of the Michigan Compiled Laws. Since the defendant’s crime had taken place in 1967, his appeal to the Court in 1973 was premised on the notion that Michigan’s pre-Roe... criminal ban on abortions was now inapplicable due to the U.S. Supreme Court’s rulings in those two aforementioned cases. The Bricker Court acknowledged that 'the judicial opinions filed by the United States Supreme Court in Roe....[is] binding upon us under the Supremacy Clause.' Yet, the Court held that in the case at hand the defendant was still criminally responsible under Michigan’s pre-Roe statutory abortion ban, section 750.14....Thus, the Bricker Court preserved section 750.14 so as to continue to attach criminal responsibility to those persons who would perform abortions--all persons, except that is, licensed medical physicians, in accordance with the Roe...[holding].

"In Larkin --the companion case to Bricker--...the Court held that section 750.14, as discussed in Bricker, was constitutional and applicable against all persons except licensed medical physicians. With regard to section 750.15, which expressly prohibited the providing, advertising, publishing, selling or publicly exposing for sale of any “pills, powder, drugs or combination of drugs” (i.e. abortifacients) used for procuring an abortion, the Court ruled this statute was also constitutional. Yet, the Court preserved section 750.15 because the statute--unlike the statutory language contained within section 750.14--specifically excluded physicians who could provide an abortifacient via prescription: '[It] would appear to be entirely consistent with the rationale of Roe v Wade. It makes the sale of drugs or medicines designed to produce abortion a medical rather than a commercial activity.'" [17]

Abortion Legislation

"In the late 1990s, the Legislature passed the 'Prenatal Protection Act,' which 'punishes individuals who harm or kill fetuses or embryos under various circumstances,' with penalties up to and including life imprisonment. In 2000, the Legislature next enacted the “Safe Delivery of Newborns” law, which provides that a parent may 'surrender' a newborn (a child not more than seventy-two hours old) to an emergency service provider 'without expressing an intent to return for the newborn.' Finally, in 2002 the Legislature enacted the “Born Alive Infant Protection Act,” which establishes that if an abortion results in a live birth of a child (as that term is commonly understood) then the medical physicians in attendance have a legal duty to see to it that the newborn child receives adequate and immediate medical care.

"The Michigan Supreme Court has not yet ruled directly upon any of these three recent laws, but the Michigan Court of Appeals has done so regarding Michigan’s 'Prenatal Protection Act.' In a 2002 case, People v Kurr, the defendant appealed her conviction of voluntary manslaughter for stabbing her boyfriend. The defendant argued that the trial court erred in not allowing the defense of others jury instruction, which the defendant allegedly deprived her of her right to present a defense – a defense that was premised on her protection of her fetuses from assault by her boyfriend. The Court of Appeals reversed the defendant’s conviction and remanded for new trial, holding that in Michigan:

The defense [of others] should also extend to the protection of a fetus, viable or non-viable, from an assault against the mother, and we base this conclusion primarily on the fetal protection act adopted by the Legislature in 1998.
The plain language of these provisions evidences the Legislature’s conclusion that fetuses are worthy of protection as living entities as a matter of public policy.

Consequently, the significance of the Kurr decision is that the Court of Appeals affirmed that non-viable, as well as viable, fetuses were protected under Michigan’s 'Prenatal Protection Act.'"[18]

Assisted Suicide

"In a lengthy 1994 decision, the Michigan Supreme Court ruled on the constitutionality of Michigan’s prohibition against assisted suicides. In the case of People v. Kevorkian; Hobbins v. Attorney General the Court dealt with a number of consolidated cases, several arising from court actions that developed out of Dr. Kevorkian’s participation in assisted suicides both prior to and after section 752.1027 was enacted. The Court held the assisted suicide provisions of section 752.1027 were validly enacted and did not violate the Michigan Constitution. Second, 'the United States Constitution does not prohibit a state from imposing criminal penalties on one who assists another in committing suicide.'

"After a commission study, the Michigan Legislature established a permanent law criminalizing the act of assisted suicide in 1998 (section 750.329a). In November 1998, Michigan citizens voted overwhelmingly against a ballot measure that would have legalized assisted suicide in Michigan." [19]

Human Cloning

While the Michigan Supreme Court has yet to hear a case on human cloning, the Michigan Court of Appeals has heard a case involving surrogacy.

"In the late 1980s, in response to national attention regarding surrogacy issues, the Michigan Legislature enacted the Surrogate Parenting Act. The Michigan Court of Appeals addressed the constitutionality of this act in the 1992 case, Doe v. Attorney General. In Doe, infertile couples and prospective surrogate mothers sought a declaratory action interpreting the Surrogate Parentage Act as invalid and unconstitutional due to an alleged violation of the 'due process guarantee of freedom from government interference in matters of marriage, family, procreation, and intimate association.'

The Court of Appeals rejected plaintiffs’ claim of a due process violation, reasoning that 'the Legislature [had] a compelling state interest sufficient to justify intrusion into plaintiffs’ right to procreate in the surrogacy context.' [The] Court determined that the Legislature had three compelling reasons that justified the government intrusion. First, the Legislature had an interest in preventing children from becoming mere commodities. Second, the Legislature had a concern with the best interests of the child born to a surrogacy arrangement. Third, the Legislature had a compelling interest in preventing the exploitation of women. Ultimately, the Michigan Court of Appeals held that the Act stood for the following propositions: 1. A surrogate parentage contract is void and unenforceable per MCL 722.855. 2. A surrogate parentage contract entered into for compensation is unlawful and prohibited by MCL 722.859. 3. For a surrogate parentage contract to exist there must be present the elements of (1) conception, through either natural or artificial insemination, of, or surrogate gestation by a female and (2) the voluntary relinquishment of her parental rights to the child. 4. A contract, agreement, or arrangement that does not contain both elements set forth in 3 above is neither void and unenforceable under MCL 722.855 nor unlawful and prohibited by MCL 722.859, even when entered into for compensation.[20]

Home Schooling

In People v. DeJonge, 501 N.W.2d 127 (Mich. 1993), the Michigan Supreme Court generally held that there is a constitutional right to home-school, though with some regulations (not including a requirement that one parent be a certified teacher, which is the very requirement that the Michigan Supreme Court struck down).

Judges

Justices of the Michigan Supreme Court
Justices of the Michigan Supreme Court
Candidates are nominated by political parties and are elected on a nonpartisan ballot. Supreme Court candidates must be qualified electors, licensed to practice law in Michigan for at least five years, and under 70 years of age at the time of election. Vacancies are filled by appointment of the Governor until the next general election. Every two years, the justices elect a member of the Court to serve as Chief Justice.

Current Justices

Compensation

In 2007, the Michigan Supreme Court released salary information for the court and employees of the judicial branch on the internet, after an information request from the Lansing State Journal.[21] The Supreme Court's seven justices are paid $164,610 per year.

Removal From Office

"Michigan judges may be removed in one of three ways:

Judges may be impeached by a majority vote of the house of representatives and convicted by a two-thirds vote of the senate. The governor may remove a judge upon the concurrent resolution of two thirds of the members of both houses of the legislature. On the recommendation of the Judicial Tenure Commission, the supreme court may censure, suspend, retire, or remove a judge. However, the Judicial Tenure Commission cannot deal with Supreme Court Justices. There is currently no mechanism to deal with misbehavior by Supreme Court Jusices."[22]

See Also

External Links

References

  1. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  2. ↑ The American Judicature Society: Judicial Selection Map
  3. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  4. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  5. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  6. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  7. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  8. ↑ See, Matter of Del Rio, 400 Mich. 665.
  9. ↑ Michigan Supreme Court History
  10. ↑ Michigan Court History Page
  11. ↑ Full Constitution: 1963
  12. ↑ Michigan justices agree to hear arguments on government overhaul measure
  13. ↑ Buzz Flash
  14. ↑ Judicial Selection: Overview; American Judicature Society
  15. ↑ Michigan Supreme Court rules in favor of government
  16. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  17. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  18. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  19. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  20. ↑ Michigan Law and the Scales of Justice: Life in the Balance.
  21. ↑ http://courts.michigan.gov/supremecourt/Press/SalaryInfo.pdf Salary info. press release
  22. ↑ Methods of Selection: Removal of Judges


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