From the Super Bowl to Facebook to billboards, sports betting platform ads like Fanduel, DraftKings, and Bet MGM want to help you land your “three leg parlay” and “make it rain.” Where before gambling took place on occasion in casinos or at gas station slot machines, today, people worldwide can make live bets from their phones—from NFL football all the way to ping pong games sponsored by the International Table Tennis Federation—anytime, anywhere. In 2024, more than $14 million dollars were placed on sports bets, a 29% increase from 2023. Since the Supreme Court overturned the Professional and Ametur Sports Protection Act in 2018, sports betting is legal in 38 states and Washington D.C. and Puerto Rico but remains controversial in mainstream society.  

In the battle to maintain the restrictions on online betting platforms, advocates have pointed out how the addictive nature of gambling creates a noxious cycle that harms sports fans while sports leagues, betting platforms, and politicians benefit financially.

There is a lot riding on the legality of gambling. Sports leagues like the NFL, NBA, and MLB have a vested interest in allowing sports betting to remain legal by advertising sports betting platforms. When gambling platforms sponsor repeat bettors, fans are encouraged to make live bets, increasing viewership on games and raising revenue for the leagues. 

Sports betting companies, like DraftKings, have the most to lose if sports betting ceases to be legal as they earn revenue through fees on losing gambling bets. According to ESPN, these sports betting platforms boasted a $13 billion dollar revenue in 2023. 

The final cashout in sports betting comes in the form of political campaign financing and lobbying. Lobbying seeks to influence candidates’ and parties’ positions on issues, with some companies donating large amounts of money to gather support for their own views and interests. At the beginning of this year, a coalition of Sports Betting giants (DraftKings, Bet MGM, and Fanduel) formed a legal alliance to hire lobbyists to work in the House of Representatives. These giants also spent over one million dollars combined on the 2024 presidential and congressional elections. Unfortunately, while governments and politicians benefit from sports gambling, consumers suffer the consequences of an unregulated online sports betting system. 

Sports betting is highly addictive and uses hits of dopamine to reinforce behaviors, while platforms sell gambling as an “easy and fun” way to make money. Platforms like DraftKings utilize advertisements to draw people in, like five-dollar coupons that make the first bet free and offering bonus bets for the completion of certain challenges. People end up chasing losses by trying to gamble more in order to break even, creating a harmful downward spiral. Research done by the University of Kansas indicates that betting is more likely to take place in low-income households, thus exacerbating poor economic conditions.

Fortunately, there are lawmakers opposed to this harmful practice. House Rep. Paul Tonko of New York’s 20th district has proposed a bill titled “S.A.F.E Bet” that would tighten restrictions on online gambling, making advertising guidelines stricter and preventing gamblers from making large consecutive bets. By restricting the amount and the frequency of bets gamblers can make in one night, S.A.F.E Bet can help mitigate the noxious cycle many bettors are stuck in. Rep. Tonko’s bill was proposed in the House and sent to committee as of September 2024.

Additionally, some health professionals have suggested that gambling addictions should be treated as an issue of public health. The combination of the stimulating nature of gambling and the accessibility of betting apps makes it addictive. As the popularity of online sports betting apps increases, advertising increases to attract more bettors, leading more people down the cycle of losing and chasing the money to win back losses. This cycle can result in debt, substance abuse, depression, and loss of relationships—it is both a financial and a mental health issue. The classification of sports betting addiction as a public health issue would help paint the image of how harmful the practice is and aid lawmakers like Rep. Tonko to make sports betting illegal.  

Online sports betting apps are regressive, invasive, and addictive. Sports betting apps are advertised as a quick and fun way to make money while your favorite teams play, but in reality, the bettor is the one getting played.

Image from Atlanta Journal-Constitution. Leo Frank and his wife Lucille in the courtroom for his murder trial, Georgia, 1913.

In a notorious episode of Georgia’s legal history, Leo Frank, a Jewish factory manager, was convicted of the murder of a young girl named Mary Phagan in Georgia in 1913 through a legal process steeped in anti-semitism and error. Despite doubts about his guilt, he was sentenced to death; in 1915, while on death row, his sentence was commuted by Georgia Governor John M. Slaton to life imprisonment. Frank was murdered by a lynch mob later that year, a crime for which no one was ever prosecuted. 

In the modern day, the consensus of investigators and legal scholars alike is that Leo Frank was innocent of murder. In 1986, Frank was pardoned by the State of Georgia. The state cited its lack of action to protect him and grant due process but did not comment on his guilt or innocence. 

As such, a decades-long effort to see Frank declared innocent via posthumous exoneration remains ongoing. The effort, pushed largely by community leaders such as Rabbi Steven Lebow and former Governor Roy Barnes, has led to the establishment of a task force to reinvestigate the case and renewed public interest. The one thing it has not led to is an exoneration. Yet. 

The lack of precedent for the posthumous exoneration being sought for Frank has long been an impediment to the movement. The recent exoneration of the Groveland Four in Florida, who faced a strikingly similar legal process, could change that. Despite the rarity of posthumous exonerations in America, the recent exoneration of the Groveland Four in Florida paves the way for the long-awaited exoneration of Leo Frank in Georgia. The two cases jointly prove that posthumous exoneration is essential to reconciling past injustices and that it is incumbent upon states to pursue them if justified. 

Background

Posthumous exonerations, distinct from pardons in that they completely acquit guilt, are extremely rare in America. In fact, less than 1% of all exonerations are granted after death, and the National Registry of Exonerations records only four individuals who have been exonerated explicitly by name. 

According to the University of Michigan School of Law’s report on posthumous and historical exonerations, this can be attributed to the court’s dismissal of proceedings as moot following a defendant’s death. In other words, there’s no established procedure for reconsidering guilt after death. As a result, many historical cases have been surrounded by outrage in light of modern evidence proving innocence without any exonerating action being taken by the state. 

The rarity of posthumous exonerations in America highlights the need for a structure by which they can be pursued and past injustices can be remedied after death. The recent exoneration of the Groveland Four in Florida demonstrates a positive step in this direction, emphasizing the importance of addressing glaring injustice in historical cases and providing complete acquittal of guilt even after death.

The Groveland Four and Leo Frank

The Groveland Four case involved four young African American men—Samuel Shepherd, Walter Irvin, Charles Greenlee, and Ernest Thomas—who were wrongfully accused of raping a white woman in Groveland, Florida, in 1949. Their convictions were marred by racial bias, coerced confessions, and lack of due process. If this sounds similar to Georgia’s Frank case, that’s because it is. The cases mirror one another strongly, mainly in their fundamentally flawed legal processes. 

• Racial and Religious Bias: Leo Frank was Jewish, and the trial took place in a deeply anti-Semitic and racially charged environment in Georgia during the early twentieth century. The Groveland Four, black men with a white female accuser, faced a similarly highly prejudiced climate. 
• Coerced Testimonies: In both cases, witnesses were coerced or intimidated into giving false testimonies. In the Frank case, initial prime suspect Jim Conley was coached by the prosecution to give strikingly inconsistent testimony against Frank. In the Groveland Four case, defendants Samuel Shepherd and Walter Irvin were brutally beaten by law enforcement to secure coerced confessions. 
• Lack of Physical Evidence: No concrete physical evidence tied Frank to the murder of Mary Phagan nor the Groveland Four to the rape of their accuser, Norma Padgett. The cases were built completely on circumstantial evidence and coerced testimony, both marred by prejudice. 
• Inadequate Legal Representation: Leo Frank’s team faced threats to their safety and a judge who was openly biased against the defense. The Groveland Four were not provided with competent legal counsel during their initial trial.

Posthumous Exoneration

The Groveland Four were exonerated in November of 2021. Although there is no formal legal process for pursuing posthumous exonerations, the five key steps leading to the Groveland Four’s exoneration provide structure to the pursuit. 

1. Review: In 2018, Florida Attorney General Pam Bondi ordered a review of the Groveland Four case. The case was referred to law enforcement and Prosecutor Bill Gladson’s office. 
2. Pardon: In 2019, Governor DeSantis pardoned the Groveland Four after his campaign promise to do so. 
3. New evidence: In 2021, the grandson of the Groveland Four prosecutor informed investigators that he had found letters indicating that his grandfather and the case’s judge knew that no rape had occurred. 
4. Request for Exoneration: Prosecutor Bill Gladson filed to get rid of Thomas’ and Shepherd’s indictments and vacate sentences and judgments imposed on Greenlee and Irvin. He cited the letters from the original prosecutor and judge, as well as evidence that a primary witness’s testimony and provided evidence was fabricated.
5. Exoneration: Lake County Circuit Court Judge Heidi Davis cleared the charges against the men and issued a ruling that effectively exonerated them of the crime. 

Given the similarities between the cases, activists and lawmakers in the state of Georgia could find a path to posthumously exonerating  Leo Frank by following a similar structure. Although the Groveland Four exoneration does not directly establish legal precedent from a different state, it does establish that a framework exists by which posthumous exoneration efforts can be successful. This achievement offers a beacon of hope after decades of effort.

More broadly, the Groveland Four and Leo Frank cases serve as a powerful testament to the fact that resolving past injustice demands an established process for pursuing posthumous exoneration in American court systems. These cases, marred by prejudice, coerced testimonies, a lack of physical evidence, and inadequate legal representation, illustrate the inherent flaws in legal proceedings that failed to uphold the court’s fundamental duty to justice.

The exoneration of the Groveland Four demonstrates that with a structured approach, courts can right historical wrongs and provide complete acquittal of guilt, even after death. As we move forward, states must recognize their responsibility to pursue posthumous exonerations when justified and create clear legal pathways to do so.  Only such action can ensure that no one is denied the opportunity to be absolved of crimes they did not commit, even if they can no longer speak for themselves. 

INTRODUCTION

Georgia has 159 counties, most of any state besides Texas, a state 4.5 times larger.^[1] Of these 159 counties, forty-five have less than 10,000 residents and over a third lost population the last decade.^[2] Studies reveal inadequate employment opportunities, insufficient education, ineffective law enforcement, and deficient healthcare access contribute to the shrinking of these counties.^[3] Leaders proposed consolidating Georgia’s counties twice before, aiming to address these issues.^[4] This article seeks to provide the history, legal basis, advantages, challenges, and solutions to county-county consolidation in Georgia to inform Georgians and their leaders about county consolidation so they can deem the necessity of consolidation.

HISTORY OF COUNTY-COUNTY CONSOLIDATION IN GEORGIA

Before considering why Georgia should consider consolidating its counties, an understanding to why Georgia has so many counties must be established. Georgia has 159 counties for historical reasons embedded in geography, economics, and politics. Historians credit geography as to why Georgia has so many counties. Georgia folklore tells of a rule that county seats must sit no further than a “day’s mule ride away from any of its citizens”.^[5] Though no law ever enforced county creation based on these parameters, the “mule ride” holds some truth.^[6] During the 1800s and 1900s as Georgia expanded westward from the coast, the majority of citizens worked in dispersed areas in agriculture and few quality transportation options existed.^[7] In an effort to provide its citizens with access to local government, Georgia created more counties. ^[8]

Besides geography, motivated by economics and politics, leaders also created new counties. Most counties formed as “peel-off counties” or counties created from the land of larger counties to jumpstart the economy in less developed areas of the state or to gain political power.^[9] One newspaper said, “‘Give ‘em a courthouse and a separate school system and all the jobs that go with them.’ A piece of the pie if you will” in describing the economic boost generated through this county creation.^[10] This economic boost was significant pre-1940 because jobs outside of agriculture were scarce and coveted in Georgia’s largely agrarian economy.^[11] Those controlling these jobs held great power. One example of a person who used the creation of a new counties to harness power was Neil Gillis.^[12] Gillis successfully lobbied the creation of Treutlen County so his real estate holdings were separate from the other counties and he could have increased influence over the new county government.^[13] The family’s land holdings grew during the rest of the 1900s and Gillis’s son served as a state senator for the region.^[14] For local economic and political reasons, county creation continued.

The “peel-off” movement accelerated when Georgia began implementing the county-unit system in 1898.^[15] The county-unit system gave small counties a proportionately larger voice in state-level elections by assigning every county two votes, regardless of size.^[16] The maximum number of votes even the largest counties could have was six.^[17] Therefore, despite rural counties accounting for 32% of the state population, they controlled 59% of the vote.^[18] Former Georgia Governor Eugene Talmadge said, “I can carry any county…that ain’t got street cars” showing the strong influence the county-unit system had on state politics.^[19] Twenty-three counties were added between the time the county-unit system was established and abolished.^[20] Many counties followed this movement, the last being in Peach County in 1924.^[21] In 1945, the Georgia Constitution capped the number of counties at 159.^[22]

Today, changes in connectivity, urbanization, and a movement away from agrarianism has led to declining populations in rural counties, minimizing the power of those in control of these counties.^[23]  In addition, the “one man, one vote” decision by the 1964 U.S. Supreme Court [AD3] further clawed back economic and political power of county leadership.^[24]  Despite these changes, the creation of Fulton County in 1932 is the only example of county-county consolidation, which merged Campbell, Milton, and the previous Fulton county during the Great Depression to prevent bankruptcy.^[25]

County consolidation was not considered seriously at the state level until state representative, Kiliaen Townsend, first in 1985 and second in 1990, proposed a plan to convert Georgia’s 159 counties into eighty-seven counties.^[26] Townsend’s plan called for a constitutional amendment to institute these change, keeping the largest forty-two counties as they were while realigning the other 117 smaller counties into forty-five counties.^[27] Townsend introduced the plan to the legislature twice but it failed to make it through committee on both attempts.^[28]

TODAY’S CONSOLIDATION EFFORTS

While Townsend’s efforts in the 1990s could predict the fate of a modern consolidation effort, some members of the Georgia General Assembly remain undaunted.^[29] In the 2022 session, Representative Darlene Taylor sponsored a resolution to create a Committee for Consolidation of County Governments and School Systems, which seeks to incentivize consolidation rather than mandate it.^[30] Unlike previous attempts at consolidation, Taylor’s plan is sponsored by rural, Republican representatives, as opposed to solely urban representatives from the minority party.^[31] The committee will include individuals outside the legislature to ensure comprehensive engagement with Georgia’s leadership impacted by consolidations.^[32] The plan aims to give counties the means to consolidate on their own and offers incentives rather than obligations.^[33] While previous attempts at consolidation were unpopular and dubbed “forced-consolidation,” Taylor’s more flexible plan presents a new approach that could have a greater chance of success.^[34]

LEGAL FEASIBILITY

Precedent and a constitutional framework show consolidating is legally feasible. While uncertainty exists around what modern consolidation would look like, Georgia has past examples to draw upon. The consolidation of Fulton, Campbell, and Milton counties is most relevant, which required a two-thirds majority.^{37, 38} However, consolidation only requires a simple majority today. Legal challenges to this 1932 consolidation were dismissed in Hines v. Etheridge, upholding the constitutionality of consolidation and providing case law to prevent future challenges.^[35] Modern examples of consolidation also exist in Georgia, with eight city-county consolidations.^[36] While these consolidations used a different framework, they provide insight into how county-county consolidation might look regarding consolidating laws, constitutional officers, debt, tax collection, and county services. Overall, while consolidation is legally feasible, there may be legal challenges, and the specifics of a consolidation would depend on the counties involved and the terms of the consolidation agreement.

VARIETIES OF CONSOLIDATION

The same precedent legalizing consolidation shows consolidations do not take a single form.^[37] This section addresses the different approaches to consolidating counties. Each approach is not mutually exclusive, but can be combined and used in a future consolidation. Approaches to consolidation differ in terms of legal implementation and government operation.

APPROACHES TO LEGAL IMPLEMENTATION: ORGANIC-CONSOLIDATION AND FORCED-CONSOLIDATION

Consolidating counties can be approached in namely two ways: organic-consolidation and forced-consolidation. Organic-consolidation involves following the legal process set forth by the constitution and precedent. ^[38] It requires passing a law for consolidation in the General Assembly and obtaining a majority vote in favor of consolidation in a local referendum in each consolidating county.^[39] The consolidation law must also include a charter that outlines the terms of the consolidation, which is negotiated by a delegation of leaders from the consolidating counties. ^[40]

Forced-consolidation, which follows the Townsend approach, requires amending the constitution to give the General Assembly complete authority to determine which counties should be consolidated.^[41]  A constitutional amendment must pass by a two-thirds vote in the General Assembly’s House and the Senate. ^[42] It would then need to pass by a simple majority vote in a constitutional referendum. ^[43] If the amendment passes, the General Assembly could determine which counties should be consolidated. Laws would need to be passed to provide for the consolidating counties using the same procedure as for organic-consolidation.^[44] While organic-consolidation follows a traditional legal process, forced-consolidation requires amending the constitution, which is more challenging. However, constitutional referendums in Georgia are not uncommon, as over 60 amendments have been adopted since 1983.^[45]

APPROACHES TO GOVERNMENT OPERATION: COMPLETE CONSOLIDATION AND SERVICE DISTRICT CONSOLIDATION[AD4] 

Two approaches can be taken for operating the government in terms of allocating debt, collecting taxes, and providing county services: the complete-consolidation-approach and the service-district-approach. The complete-consolidation-approach combines all the dissolved counties’ debts into one collective pool. In contrast, the service-district-approach allows for debt to be maintained separately, different levels of tax to be levied, and distinctive services to be provided depending on where a citizen resides within the newly formed county.^[46] Before counties dissolve and consolidate, they likely have different levels of indebtedness, tax rate, and county services. Rather than combining debt, altering the tax rate, and offering the same services, by using special districts, citizens of dissolved counties can become citizens of the newly formed county while still enjoying the tax rate and services before consolidation. Georgia’s three largest city-county consolidations utilized the service-district-approach.^[47] For example, in the Columbus-Muscogee consolidation, the newly formed county has special districts made up of areas were within the old city-limits and then a general service district encompassing the entire county.^[48] When the city and county were consolidated, debt from the city went to the special service districts while debt from the county went to the general service district.^[49] Because the indebtedness is higher for the special service districts, the tax rate is also higher. The general service district provides a minimum level of services, while each special service district offers a higher level of county services.^[50]

The service-district-approach works differently in a county-county consolidation than a city-county consolidation. Unlike a city, which before consolidation occurs, exists within the county, county-county consolidations bring together two geographically district territories. If counties consolidate using the special-district-approach, the general service district encompasses the entire area of the new county. This general service district takes on any new debt brought on by the county for county-wide expenditures, provide some minimum level of service, and levy a base tax rate for the administration of the consolidated county. Then, the areas within the territorial footprint of each dissolved county would be put into a special service district that retains the debt from the dissolved county, charges its own rate of taxes, and provides its own level of county services.

ARGUMENTS FOR CONSOLIDATION

Understanding that consolidation is legal in Georgia and the flexible approaches to consolidation, should consolidation efforts take place? The following sections explore the advantages and challenges of consolidation.

BENEFITS OF CONSOLIDATION

Proponents of consolidation argue that it will create more prosperous communities by gaining efficiencies and cost savings, enhancing planning capacity, addressing corruption, and providing greater representation for minority populations.

Efficiencies and Cost Savings

Some argue that consolidating counties could help struggling counties provide services more efficiently. Consolidation eliminates duplicate services, amalgamates facilities, and allows counties to purchase goods in bulk, resulting in significant cost savings. A study by Townsend in 1985 estimated that consolidation could save $1 billion in local and state taxpayer money, which, adjusted for inflation, is $2,266,036,725 today.^[51] While this number represents the savings if nearly two-thirds of Georgia counties consolidated, which is unrealistic, cost savings from consolidation would still be significant.^[52]

However, at the time of the Townsend study, Georgia had one of the most expensive per capita payrolls in the country, having nearly 600 state and local government employees per 10,000 people.^[53] Times have changed though. Georgia is now operated more efficiently, having only 216 state and local government employees per 10,000 residents.^[54] In fact, when looking at the total general expenses for running local governments in Georgia, Georgia spends less than any of its neighboring states, spending $123.46 per resident in 2020.^[55]

While some argue that this efficient governance reduces the need for consolidation, others claim that it could provide additional funds to improve the quality of services provided to Georgians. Georgia ranks thirty out of fifty in public safety.^[56] Specifically, for violent crime and human trafficking, Georgia ranks tenth worst in both categories.^[57] In terms of quality of public education, Georgia ranks thirty-six in the nation.^[58] This especially impacts rural communities, where Georgia is positioned seventh worst in the country in quality of education provided to rural students.^[59] Savings achieved from consolidation could improve these services counties deliver to their citizens. For example, consolidating payroll costs for administrative roles could allow consolidated counties to offer higher salaries and retain higher-quality candidates in education and public safety. For instance, the superintendents in Warren, Glascock, and McDuffie counties are paid $99,672, $116,590, and $170,454 respectively. Instead of paying these three salaries, the counties could combine these payroll costs and hire multiple teachers.^[60] [AD7] 

Consolidation also provides non-economic efficiencies. Larger school districts facilitate better quality education, as programs that are too small are limited in the interactions and advanced course work they can provide. A study by the Governor’s Education Review Commission determined that to facilitate quality education, a system needs at least 2,500 students.^[61] David Lewis, superintendent of Muscogee County Schools bolsters these results, saying, “In a broad stroke, from efficiency and programmatic standpoint, there is benefit from scalability. Programs that are too small are limited in the advanced course work they can provide.”^[62] Overall, consolidation has the potential to produce cost savings, economic efficiencies, and non-economic efficiencies.

Enhanced Planning Capacity

A consolidated county government has greater capacity to generate regional plans, rather than several individual government plans per region. A study on city-county consolidations in Georgia found that a single government can establish a single legislative agenda and speak with one voice in economic development, reaping all the benefits of such development.^[63] For instance, rather than having two zoning boards, long-range planning can take place in one place. Leaders in Columbus-Muscogee saw this advantage, as they could respond to change better.^[64] The single government was better prepared to address the rapid economic changes, and a county is apt to respond to grant and economic development opportunities because there are fewer elected officials to deal with. ^[65] Enhanced planning can be extremely valuable, as many of the issues facing rural Georgia are regional rather than confined to a single county.

Eliminating Corruption

Corruption cannot be completely eradicated, but consolidated governments offer more oversight through additional checks and segregated duties. Small governments are more prone to corruption due to their limited size and resources that impede oversight and enforcement mechanisms.^[66] Georgia’s Constitution^[67], statutes^[68], and Attorney’s General^[69] offer penalties and resources to prevent corruption, but absent a specific complaint about “egregious conduct” deemed important enough for officials to pursue corruption, an investigation will not take place.^[70] [AD8]  Consolidated governments provide higher transparency about the job performance of elected officials and prompt officials to take action when corruption occurs.^[71] The prevention of corruption bolsters the government efficiency argument. A study determined if states with higher-than-average corruption had only the average amount of corruption, they would have spent 5.2% less over ten years.^[72]

Greater Representation for Minority Populations

Studies suggest that minorities benefit from the consolidation of governments, as changes in government structure historically have given them more representation.^[73] Recent consolidations around the country have resulted in many African-Americans being appointed or elected to regional administrative and legislative positions due to redistricting.^[74] For example, after the Columbus-Muscogee consolidation, an African-American councilor was elected mayor, the first African-American to be elected to the position.^[75] After the Macon-Bibb consolidation, African Americans made up a higher percentage of the new council-commission than before.^[76] [AD9] Consolidation also gives minorities who did not have a voice in the charter-making process an opportunity to bring their concerns to the table.^[77] Research finds African-Americans experience an increase in their “symbolic political representation” when minority representation is successful in a referendum.^[78] Given their history of being excluded from office, consolidation can redress this grievance and benefit counties.

CHALLENGES

Several challenges exist regarding consolidation. County costs could increase in the short-term, local government might be wary to let go of their position, and citizens might have fears of losing local identity.

Initial Cost Increases

Creating a new government comes with start-up costs and, like any new initiative, comes with growing pains. Research shows cost savings from consolidation are likely attained only after one or several years.^[79] Examples of start-up costs range from changing signage to equalizing salaries and benefits and integrating financial systems.^[80] Without long-term vision, consolidation is a non-starter.

Local Government Wariness to Let Go of Their Power and Employment

Some local officials will not want to lose their power. Former Senator Floyd Hodgins said during Townsend’s consolidation effort, “Georgia must force counties to consolidate because…counties are never going to do it themselves”.^[81] A more recent leader, former Columbus Mayor, Teresa Tomlinson, more optimistically, yet realistically states, “if you can get the elected officials with power and the money that backs them to support you, with education the community can be brought on board.”^[82] Columbus-Muscogee proved this notion true after ten officials voted themselves out of a job under their consolidation plan.^[83] Not every consolidation will have elected officials willing to leave their job though. For instance, while conducting research on consolidation in 1966, one researcher was bribed to cease his research in Wheeler County.^[84] When the researcher failed to cease his work, the sheriff threatened him with jail time, showing the internal politics of consolidation.

In smaller Georgia counties, county government drives the economy, making some officials and citizens hesitant to relinquish power and jobs. While not every duplicate job is eliminated during consolidation, most higher-paying administrative roles are combined into one role.^[85] In rural counties, the county manager, sheriff, and superintendent are the highest-paid positions, and local government jobs are often the only employment opportunities outside of agriculture.^[86] For instance in Taliaferro County, county employees make up 24% of the labor force.^[87] This strong dependence on county jobs makes some citizens resistant to consolidation, as it threatens their livelihoods.

Fears of Losing Local Identity

Not only are opponents to consolidation afraid of losing money, power, and profession, but of losing local identity. Looking back at Townsend’s attempt at forced-consolidation, fears of losing local identity were the most glaring challenges to consolidation.^[88] One newspaper captures the extent of fear consolidation proposals ignited saying “logical as the [consolidation] amendment may seem to those who foresee more economic county government through consolidation, residents of counties which would be swallowed up into larger bodies will fight with a vengeance which would make World War II resemble a neighborhood skirmish”^[89] With generations of family history and lives full of experiences, many citizens will be afraid to lose their county’s identity to a larger region.

PRACTICAL FEASIBILITY

Georgia’s economy and city-county consolidation within Georgia predict the feasibility of county consolidation. Forced-consolidation will likely fail to pass the legislature, as Georgia’s economy is now better off than during Townsend’s consolidation effort. However, Georgia’s successful city-county consolidations, with eight of the most in the country besides Alaska, show promise for county consolidation.^[90] The success of Georgia’s county consolidation movement depends on a light-touch and collaborative approach like that set forth in H.R.630.

To ensure the success of county consolidation, the consolidation commission must educate citizens on the benefits of consolidation, tailor arguments to specific county needs, and collaborate with counties to establish a consolidation that works for all stakeholders.^[91] The state should streamline the consolidation process and provide incentives for counties to consolidate, such as offering grants or awarding a percentage of saved funds to the first counties to consolidate.^[92]

CONCLUSION

Consolidation is legally and practically feasible. Consolidation boasts many benefits like creating efficiencies and cost savings, enhancing planning capacity, addressing corruption, and providing greater representation for minority populations while also bound to face challenges such as short-term cost increases, pushback from local officials and employees, and fears of losing local identity. However, educating, collaborating, streamlining, and incentivizing elected officials and Georgia residents to support county consolidation is the best approach to a better future for their county.

^[1] U.S. Census Bureau, Georgia: 2020 Census (2021); U.S. Census Bureau, Texas: 2020 Census (2021).

^[2] U.S. Census Bureau, Georgia: 2020 Census (2021).

^[3] Interview by Sheryl Vogt with Kilaen Townsend, former Ga. State Rep. (Nov. 17, 2006) [hereinafter Townsend Interview].

^[4] H.R. 397, 138th Leg. (Ga. 1985).

^[5] Jim Tharpe, Lawmaker wants to create Milton County, Atlanta J. Const (Feb. 16, 2010), https://www.ajc.com/news/local-govt–politics/lawmaker-wants-create-milton-county/FqNOGQTg3ReiGSSpHajc4O/ [hereinafter Milton County].

^[6] Stephannie Stokes, Why Ga. Has The Second Highest Number Of Counties In The US, WABE (Apr. 4, 2016) https://www.wabe.org/why-ga-has-second-highest-number-counties-us/.

^[7] Id.

^[8] Id.

^[9] Milton County, supra note 5.

^[10] Donald E. Harwood, Keep County Merger Alive; It Makes Good Sense, Savannah Morning News, Feb. 14, 1985, at 1.

^[11] William P. Flatt, Agriculture in Georgia, New Ga. Encyclopedia (May 25, 2004), https://www.georgiaencyclopedia.org/articles/business-economy/agriculture-in-georgia-overview/.

^[12] Elizabeth B. Cooksey, Treutlen County, New Ga. Encyclopedia (Sept. 30, 2006),

https://www.georgiaencyclopedia.org/articles/counties-cities-neighborhoods/treutlen-county/.

^[13] Milton County, supra note 5.

^[14] Id.

^[15] Interview by Sheryl Vogt with Kilaen Townsend, former Ga. State Rep. (Nov. 17, 2006) [hereinafter Townsend Interview].

^[16] Scott E. Buchanan, County Unit System, New Ga. Encyclopedia (Apr. 15, 2005), https://www.georgiaencyclopedia.org/articles/counties-cities-neighborhoods/county-unit-system/.

^[17] Id.

^[18] Id.

^[19] Ga. Hist. Soc’y, Eugene Talmadge, Ga. Pub. Broad (Dec. 9, 2013), https://www.todayingeorgiahistory.org/tih-georgia-day/eugene-talmadge/.

^[20] U.S. Census Bureau, Georgia: 2020 Census (2021).

^[21] Terry Dickson, County Consolidation Plan Gets New Attention, Brunswick News (Feb. 21, 2022), https://thebrunswicknews.com/news/local_news/column-perspective-county-consolidation-planit-gets-new-attention/article_857edccf-aa5c-5bc3-baa1-76f91fb27c25.html [hereinafter County Consolidation Plan Gets New Attention].

^[22] Ga. Const. art XI, para II (1945).

^[23] Telephone interview with Terry England, Ga. State Rep. (Nov. 2, 2022) [hereinafter England Interview].

^[24] Reynolds v. Sims, 377 U.S. 533, 554 (1964).

^[25] 1929 Ga. Laws 251 (the law to consolidate Fulton and Campbell counties passed August 9, 1929, and consolidation was voted on and approved by Campbell County voters on February 17, 1931, and by Fulton County voters on April 22, 1931); 1929 Ga. Laws 551 (the law to consolidate Fulton and Milton counties passed August 9, 1929, and consolidation was voted on and approved by Milton County voters on February 17, 1931, and by Fulton County voters on April 22, 1931); State of Ga., Georgia’s Official Register 452, 472, & 492-93 (1931).

^[26] County Consolidation Plan Gets New Attention, supra note 21; Proposal in House to Reduce Counties to 87, Ga. Cnty Govt. Mag., Mar. 1985, at 2.

^[27] Kiliaen V. Townsend, Update For All Legislators (Mar. 7, 1990) [hereinafter Townsend Legislative Update].

^[28] H.R. 397, 138th Leg. (Ga. 1985); 2 State of Ga., Journal of the House of Representatives of the State of Georgia at the Regular Session (1985); 2 State of Ga., Journal of the House of Representatives of the State of Georgia at the Regular Session (1990).

^[29] England Interview, supra note 23.

^[30] H.R. 630, 153d Leg. (Ga. 2022) (in the 2021-22 Session of the Georgia General Assembly, H.R. 630 made it through the House Committee on Governmental Affairs and was put in the House Hopper. HR 630 never made it to the House Floor for a full vote.).

^[31] Townsend was a Republican from Buckhead in Democratically controlled Georgia. Further anger ensued from the fact neither county Townsend represented was a candidate for consolidation. County Consolidation Plan Gets New Attention, supra note 21; Townsend Interview, supra note 15.

^[32] Id. (according to the resolution, the committee will be made up of three state House representatives, three state senators, the executive director of the Georgia Municipal Association, the executive director of the Association County Commissioners of Georgia, the executive director of the Georgia School Superintendents Association, the executive director of the Georgia School Superintendents Association, and two members appointed by the president of the Constitutional Officers Association of Georgia.).

^[33] England Interview, supra note 23.

^[34] Id.

^[35] Hines v. Etheridge, 162 S.E. 113, 113 (Ga. 1931).

^[36] 1977 Ga. Laws 3776 (Macon-Bibb consolidation); 1968 Ga. Laws 3571 (Columbus-Muscogee consolidation); 1997 Ga. Laws 4024 (Augusta-Richmond consolidation); 1979 Ga. Laws 3770 (Athens-Clarke consolidation); 1975 Ga. Laws 3617 (Cusseta-Chattahoochee consolidation); H.B. 1630, 147th Leg. (Ga. 2004) (Webster consolidation); H.B. 757, 148^th Leg. (Ga. 2005) (Quitman consolidation); 2012 Ga. Laws 4575 (Echols consolidation).

^[37] See 1929 Ga. Laws 251, but see 1977 Ga. Laws 3776.

^[38] Ga Const. Art. IX § I para. II(c).

^[39] Id.

^[40] Ga Const. Art. IX § II para. I(c); R. Lucas, Types of County Government (2021) https://www.dekalbcountyga.gov/sites/default/files/users/user3566/RLucas_07.13.21_FINAL_Types%20of%20CouCou%20Government.pdf, [hereinafter Types of County Government] (the new charter must outline the government structure, specific powers, functions, essential procedures, and legal control of the newly formed county).

^[41] H.R. 397, 138th Leg. (Ga. 1985); Ga Const. Art. IX § I para. II(c).

^[42] Id.

^[43] Id.

^[44] Id.

^[45] Initiative & Referendum Inst., Georgia (2022), http://www.iandrinstitute.org/states/state.cfm?id=31.

^[46] Ga. Const. Art. IX § II para VI.

^[47] Columbus, Ga., Code § 1-103 (2022); Macon, Ga., Code § 1-105 (2022), Augusta, Ga., Code § 1-7 (2022); Carl Vinson Inst. of Gov’t, A Review and Comparison of Georgia’s Three Largest Consolidated Governments 5 (2011), https://www.cviog.uga.edu/_resources/documents/publications/2011-georgia-three-largest-consolidated-governments.pdf, [hereinafter Comparison of Consolidated Governments].  

^[48] Columbus, Ga., Code § 1-103 (2022).

^[49] Id.

^[50] Id.

^[51] Kiliaen V. R. Townsend, Update For All Legislators, Mar. 7, 1990. Fed. Rsrv Bank, Inflation, consumer prices for the United States (2022) (the dollar had an average inflation rate of 2.59% per year between 1990 and today, producing a cumulative rate of inflation of 126.60%).

^[52] England Interview, supra note 23.

^[53] Bill Shipp, Will Miller Go Dinosaur Hunting? Daily News, Feb. 3, 1990.

^[54] Michael Maciag, States With Most Government Employees: Totals and Per Capita Rates, Governing (Mar. 21, 2014) https://www.governing.com/archive/states-most-government-workers-public-employees-by-job-type.html.

^[55] Urban Inst., Georgia (2022) https://www.urban.org/policy-centers/cross-center-initiatives/state-and-local-finance-initiative/projects/state-fiscal-briefs/georgia#:~:text=Per%20the%20US%20Census%20Bureau,between%20state%20and%20local%20governments.

^[56] Crime & Corrections Rankings, U.S. News & World Rep. (2019) https://www.usnews.com/news/best-states/rankings/crime-and-corrections.

^[57] Samuel Stebbins, How the Murder Rate in Georgia Compares to the Rest of the Country, Ctr. Square, (Dec 10, 2021) https://www.thecentersquare.com/georgia/how-the-murder-rate-in-georgia-compares-to-the-rest-of-the-country/article_196234bd-2bdf-5099-be60-2170ff1382a5.html#:~:text=Though%20Georgia%20has%20a%20higher,to%20399%20per%20100%2C000%20natination; Human Trafficking Statistics by State, World Population Rev. (2022) https://worldpopulationreview.com/state-rankings/human-trafficking-statistics-by-state.

^[58] Adam McCann, States with the Best & Worst School Systems, Wallet Hub (July 25, 2022), https://wallethub.com/edu/e/states-with-the-best-schools/5335.

^[59] Daniel Showalter, et. al, Why Rural Matters 5 (2019) https://www.ruraledu.org/WhyRuralMatters.pdf.

^[60] Telephone interview with David Lewis, Superintendent of the Muscogee County School District (Nov. 2, 2022); Townsend Interview, supra note 15.

^[61] Townsend Legislative Update, supra note 27.

^[62] Telephone interview with David Lewis, Superintendent of the Muscogee County School District (Nov. 2, 2022).

^[63] Comparison of Consolidated Governments supra note 47, at 5.

^[64] Id.

^[65] Id.; The single government was better prepared to address the rapid economic changes, and a county is apt to respond to grant and economic development opportunities because there are fewer elected officials to deal with.

^[66] Ctr. for the Advancement of Pub. Integrity, Fighting “Small Town” Corruption: How to Obtain Accountability, Oversight, and Transparency (2016), https://web.law.columbia.edu/sites/default/files/microsites/public-integrity/files/fighting_small_town_corruption_-_capi_practitioner_toolkit_-_august_2016.pdf.

^[67] Ga. Const. Art. I, § 2 para 1.

^[68] Ga. Code Ann. §§ 36-30-4, 6, & 23 § 36-30-6, § 36-60-23; Ga. Code Ann. §§ 16-10-1—6.

^[69] Off. of the Att’y Gen., Public Corruption, https://law.georgia.gov/public-corruption.

^[70] Ctr. for the Advancement of Pub. Integrity, Fighting “Small Town” Corruption: How to Obtain Accountability, Oversight, and Transparency (2016), https://web.law.columbia.edu/sites/default/files/microsites/public-integrity/files/fighting_small_town_corruption_-_capi_practitioner_toolkit_-_august_2016.pdf.

^[71] Id.

^[72] Alexandria Fisher, Study: Corruption Costs Taxpayers More than $1,300 Per Person, NBC Chi. (July 15, 2015), http://www.nbcchicago.com/blogs/ward-room/Study-Determines-Cost-of-Corruption-in-Illinois-267165861.html.

^[73] K. B. Dankwa & T. Sweet-Holp, The Effects of Race and Space on City-County Consolidation: The Albany-Dougherty Georgia Experience, 247, 250 Urban Studies (2015).

^[74] Id.

^[75] Comparison of Consolidated Governments supra note 47, at 4.

^[76] Mike Stucka, Macon-Bibb County consolidation wins with strong majorities, The Tel. (July 31, 2012), http://www.macon.com/news/politics-government/election/article 30109740.html.

^[77] Tobe Johnson, Metropolitan Government: A Black Analytical Perspective, 1972, at 6.

^[78] Id.

^[79] Comparison of Consolidated Governments supra note 47, at 9.

^[80] Id., at 9, 16.

^[81] Jim Houston, Merging Counties Good Idea That’s Doomed, Ledger-Enquirer, Feb. 10, 1985, at C11.

^[82] Telephone interview with Teresa Tomlinson, Former Columbus-Muscogee Mayor (Oct. 27, 2022).

^[83] Comparison of Consolidated Governments supra note 47, at 3-4.

^[84] Jim Galloway, Counties Have Grown Like Kudzu during Georgia’s History Apr. 28, 1995, at 13A.

^[85] Townsend Interview, supra note 15; England Interview, supra note 23.

^[86] England Interview, supra note 23; William P. Flatt, Agriculture in Georgia, New Ga. Encyclopedia (May 25, 2004), https://www.georgiaencyclopedia.org/articles/business-economy/agriculture-in-georgia-overview/.

^[87] Ga. Dept. Labor, Georgia Area Labor Profile: Taliaferro County, 2021.

^[88] Townsend Interview, supra note 15.

^[89] County Consolidation Not A Popular Idea, Times-Enterprise, Feb. 9, 1985, at 4.

^[90] National Association of Counties, Consolidated City-Counties (Oct. 27, 2021) https://www.naco.org/resources/consolidated-city-counties.

^[91] England Interview, supra note 23; Telephone interview with Teresa Tomlinson, Former Columbus-Muscogee Mayor (Oct. 27, 2022); Citizens Research Council of Michigan, Government Consolidation: A Historically Unpopular Solution to Local Fiscal Strain (Oct. 23, 2020), https://crcmich.org/government-consolidation-a-historically-unpopular-solution-to-local-fiscal-strain.^[92] Telephone interview with Teresa Tomlinson, Former Columbus-Muscogee Mayor (Oct. 27, 2022) (suggesting using an incentive); Comparison of Consolidated Governments supra note 47, at 5; Robin Toner & Jim Galloway, Pride Twarts County Mergers, Apr. 28, 1985, at 12A (another representative who supported Townsend’s plan suggested amending the plan to add incentives for consolidation); Ginger Gibson, Newt shoots for the moon Politico (Jan. 25, 2012), https://www.politico.com/story/2012/01/newt-shoots-for-the-moon-071991 (suggesting using an large monetary incentive to induce a certain action).

The first Monday in October marks the end of the Supreme Court’s summer recess. Following a year in which the court handed down landmark rulings with vast political implications (Obergefell v. Hodges, which legalized same-sex marriage, and King v. Burwell, which upheld the legality of a critical portion of Obamacare, among others), it is hard to imagine another term with equivalent political consequence. However, the slate of cases already on the court’s docket, Evenwel v. Abbott in particular, may galvanize politics once again.

Equal representation is the basis of a democratic government, however until the early 1960s “silent gerrymanders” engendered political districts with vast population disparities. California’s senate districts in the early 1960s, which had a standard deviation of 900,000 people, exemplified the egregious population deviations among voting districts that were once commonplace across the United States. In Baker v. Carr, 1962, the Supreme Court decided to “enter into the political thicket” in an effort to preserve the integrity of voting. In distorted voting districts, a district with 200,000 people versus a district with 2,000 people for example, the voters in the district with a smaller population have more political clout because their votes are comparatively “worth more.” That is, fewer voters can decide an election. The Baker decision, in which the court determined that redistricting cases were justiciable under federal courts, initiated the redistricting revolution.

Redistricting questions following Baker initially revolved around which voting districts needed to be redrawn. The court’s decisions in Reynolds v. Sims and Wesberry v. Sanders mandated that the districts for both houses of a bicameral state legislature and United States Congressional districts had to be drawn according to equal population. While these decisions mandated redistricting be considerate of population deviations, it was not explicit how “equal” the districts must be.

The question of equality in redistricting practices has rearisen with the Supreme Court agreeing to hear the case Evenwel v. Abbott. While an abundance of Supreme Court precedents have been devoted to ensuring that population deviations are as minimal as possible, the appellants in Evenwel argue the fundamental baseline of these decisions is flawed. Sue Evenwel challenges that in order to achieve substantive equality, the citizen voting age population (CVAP) of a district should be the baseline for redistricting practices rather than total population, which is the current practice.

Evenwel resides in a rural Texas voting district, and argues that because a higher percentage of rural residents are registered to vote, her vote is diluted when compared to an urban voter’s vote (see the following figure). The disparity between the two measures, CVAP and total population, is the members of the population who are ineligible to vote – namely illegal immigrants, children, and felons. Evenwel’s argument rests on the fact that urban voting districts have much higher concentrations of those ineligible to vote, hence redistricting according to total population dilutes the comparative influence of rural voters by allowing fewer urban voters to decide election outcomes in their districts.

Redistricting cases have revolved around the equality of total populations since the 1960s when redistricting became mandated. According to Dr. Charles Bullock, a UGA professor and renowned redistricting expert, “If the Supreme Court comes down in favor of Evenwel, it will initiate a flurry of redistricting questions that the court will have to address. This decision has the potential to ignite a redistricting revolution akin to the one in the 1960s.”

This decision carries the potential to have unparalleled political ramifications. A decision in favor of Evenwel could significantly alter the political landscape by instigating a “power shift almost perfectly calibrated to benefit the Republican Party.” Because urban populations have higher concentrations of immigrants and children, a switch to CVAP over total population would transfer power to suburban, whiter areas. In essence, cities which are generally safe-havens for democratic candidates would see voting power shift to more republican strong-holds. Democrats stand to lose greatly in a decision for Evenwel, “Of the 20 districts with the fewest eligible voters in them, Democrats have representatives in 19 of them.” A ruling in favor of Evenwel could drastically alter the make-up of state legislatures and the United States House of Representatives.

While the Democratic Party stands to lose at the benefit of Republicans, the biggest loss would be to those ineligible to vote. Legislators are supposed to protect the interest of everyone in their districts, but “according to analysis of census data by the California Civic Engagement Project at the UC Davis Center for Regional Change, counting only eligible voters would mean that nearly a third of the U.S. population would lose legislative representation.” This is the crux of the issue in Evenwel: whether or not the equal protection clause requires legislators to represent the interest of those ineligible to vote such as children – or if equality on a “per-vote” basis is more important.

The Supreme Court has decided to hear the controversial equal protection question of Evenwel v. Abbott in attempts to clarify the meaning of “one person, one vote.” Along with Evenwel, the court will hear other politically significant cases throughout the 2015-2016 term. A previous case regarding affirmative action in college admissions (Fischer v. University of Texas at Austin) has returned for a court decision. Public employee unions will also appeal before the Supreme Court in attempts to continue collecting money from those they represent through collective bargaining (Friedrichs v. California Teachers Association). The court has not yet completed its docket, but cases involving abortion and the death penalty are sure to reach the court as well. However, the political ramifications of the Evenwel decision are massive. A ruling in favor of Evenwel would assuredly reduce the amount of urban voting districts (generally Democratic) and increase the amount of suburban and rural voting districts (generally Republican). While on its face the case may not be as politically consequential as Obergefell or Burwell was last session, a closer review reveals that a decision for Evenwel could drastically alter the partisan balance in nearly every state legislature and in Washington.

Photo: Pew Research Center

When the not guilty verdict in George Zimmerman’s trial was announced, a flood of outrage erupted.  Rallies and protests supporting Trayvon Martin, the teenager Zimmerman was charged with murdering, were held in cities ranging from Atlanta to Los Angeles to Minneapolis.  Celebrities like Rihanna and athletes like Atlanta Falcons receiver Roddy White tweeted their disappointment and anger about the verdict.  The NAACP created a petition demanding that the Department of Justice file federal civil rights charges against Zimmerman, which has gathered over 1 million signatures.

Much of this outrage can be traced to the frequently inflammatory and sometimes erroneous way the media reported the case.  From the beginning, the incident between Zimmerman and Martin was portrayed as racial, even though one jury member told Anderson Cooper that the jury did not believe race was an issue in the case.  NBC News edited Zimmerman’s call to the police to make Zimmerman sound like a racial profiler: Zimmerman told the police about Martin, “This guy looks like he’s up to no good.  Or he’s on drugs or something.  It’s raining and he’s just walking around, looking about.”  The police dispatcher then asked Zimmerman what race Martin appeared to be, and Zimmerman said, “He looks black.”  NBC, however, edited out the dispatcher’s question and played the audio as “This guy looks like he’s up to no good.  He looks black.”  ABC News reported initially that Zimmerman had suffered no injuries from the incident, which would make it doubtful that he was acting in self-defense, even though Zimmerman had in fact been injured.  Finally, Zimmerman was described in the media as a “white Hispanic”; a rarely used term that was used to maintain the media storyline of a white “wannabe cop” targeting a young black man.  Sirius XM radio host Joe Madison said the incident was “nothing more than a modern-day lynching.”

The media’s misrepresentation of the case led to widespread condemnation of Zimmerman despite the fact he was acquitted of murder and manslaughter in trial.  Zimmerman is actually suing NBC for defamation and claims that the way they edited his call to the police caused him to receive death threats and be forced into hiding.

The Zimmerman trial is the most recent in a long line of legal cases that have been sensationalized, exaggerated, or misrepresented by the media.  In famous cases like Casey Anthony’s murder trial in 2011 and Michael Jackson’s child molestation trial in 2005, the media also portrayed the defendants as clear-cut and guilty villains even though juries would also find them innocent.   Then there was the media disaster around the Supreme Court’s decision on the Affordable Care Act: in their rush to break the news first, news outlets mistakenly reported that the act had been entirely struck down and entirely upheld before finally reporting the correct decision.

Unfortunately, while the legal world and the journalistic world have needs of each other, they are also structurally incompatible with the other.  The media is charged with publicizing important legal decisions, and the law is a source of stories for journalists.  However, the two fields have so many differences that fiascos are almost inevitable.

The first difficulty, particularly prevalent in the Zimmerman trial, is how the law and the media cast different people in an incident.  The media aims to tell a story and so it has a tendency to search for and characterize a villain and a victim or a hero in each situation.  The law, though it does assign a final verdict of guilty or not guilty, is not so black and white.  The media told the story of a villainous Zimmerman killing the victim Martin; the law ruled that both parties made mistakes in judgment that unhappily resulted in Martin’s death.  In addition, as much as the media and its consumers desire a satisfying ending to the story—in this case, justice for Martin in the form of a guilty verdict—the trial gave no such ending.

Then there is the speed at which both fields work.  The law is a notoriously deliberate pursuit in which cases often take years to decide while the media requires speed even at the expense of accuracy.  That difference has been exacerbated in recent years with the onset of Internet news and social media.  In its reporting of cases, the media simply cannot spare the time to fully review the law’s painstaking examination of facts and precedent.

Law also has a tendency to be overly esoteric and detail-oriented, which makes it ill-suited for media adaptation for a wider audience.  The technical details and complicated, unclear writing often involved in law make it difficult for journalists without formal legal training to interpret it correctly, hence blunders like that surrounding the Affordable Care Act decision.  In addition, in trials, the the facts are examined within the framework of applicable laws, even when controversial, whereas consumers of media are oftentimes more interested in the larger issues (i.e. “Stand Your Ground”).

Unfortunately, because legal affairs will never cease to be so important or fascinating to the public, the law and the media will continue to have to be bedfellows, and as they are unlikely to become more like each other, the public can probably look forward to more sensationalism and misrepresentation.