Legal Docket: Mahanoy Area School District v Levy - S2.E6
A cheerleader’s vulgar post on social media lands her in trouble with the school, but judicial precedent from the 1960s and the First Amendment protects her right to free speech
FOR WHAT IT'S WORTH BY BUFFALO SPRINGFIELD: There’s battle lines being drawn/Nobody’s right if everybody’s wrong/young people speaking their minds/ getting so much resistance from behind/ I think it’s time we stop, hey, what’s the sound/everybody look what’s going down...
MARY REICHARD, HOST: What was going down in 1966 … when this song by Buffalo Springfield hit the charts … was a United States deep into war in Vietnam. Steven Stills wrote the song to protest curfew laws on the Sunset Strip in California. But the song took on greater meaning against the backdrop of the war and the huge toll it was taking on young people.
1960'S NEWSREEL MONTAGE:
MR: All this was not lost on two teenagers in Des Moines, Iowa. Fifteen year old John Tinker and his 13-year-old sister Mary Beth Tinker felt inspired to express their opposition to the Vietnam war. They and other students planned to protest by wearing black armbands at school. School officials responded quickly: banning the armbands from campus. And when the Tinkers and other students defied the ban by showing up with the armbands, the school suspended them. The Tinkers took their fight for freedom of speech to the US Supreme Court. And they won. The justices clarified the lines of free speech, student speech, and school authority.
JENNY ROUGH, HOST: Fifty-two years later, in 2017:
THUNDER BY IMAGINE DRAGONS: Just a young gun with the quick fuse/I was uptight, wanna let loose/I was dreaming of bigger things/And wanna leave my own life behind...
2017 NEWS MONTAGE
JR: Donald Trump is president, statues are toppled; and life goes on in Schuylkill County, Pennsylvania, in the eastern part of the state.
SOUND: CHEERLEADING SQUAD
JR: A junior-varsity cheerleader tries out for the varsity cheerleading team. But the squad turns her down, leaving her on JV for another year. So that cheerleader Brandi Levy decided to express herself the way millions of young people do today: she took to social media. And like too many of them, the way she took to social media was with a Snapchat post replete with vulgarities. School officials clearly disapproved, moving swiftly to suspend her even from the JV team. Did Levy have a free-speech case here? It wasn’t exactly a black armband. It was more like a blue streak. Still, she took her case to the US Supreme Court. And she won. The justices further clarified the lines of free speech, student speech, and school authority.
MR: This is a story of the long arc of judicial precedent. How today, we stand on the shoulders of those who came before. And how, appropriate for a cheerleader, Brandi Levy stands on the shoulders of the Tinker siblings.
BRANDI LEVY: I mean I’m still fighting because I want to prove a point that young kids like me and young adults should be able to express themselves without the school trying to punish them.
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MR: Brandi Levy very much wanted to be a varsity cheerleader at Mahanoy Junior/Senior High School in Pennsylvania. But in May 2017, Levy found out she didn’t make the cut. Instead, she’d stay on the junior varsity team for another year. That, on top of learning she’d not gotten the position she wanted on the softball team...and not to mention being nervous about final exams coming right up. A stressful time.
JR: In other words. Life. The weekend after receiving the news about not making varsity, Levy and a friend met up at a gas station convenience store in Mahanoy City. Population around 4,000. That’s where Levy decided to let off some steam. She took a picture of herself and the friend extending their middle fingers... along with an obscene caption griping about the school, and softball, and cheer, and everything.
MR: In no uncertain terms. Levy posted it to Snapchat and shared it with a group of her friends. Snapchat’s a social media platform in which posts disappear after 24 hours. She’s comfortable in that realm.
LEVY: I feel like it’s easier to express myself on social media than it is to walk up to someone and tell them how I feel.
MR: Besides, the snap would be gone before school started up again on Monday. At least, that’s what Brandi thought.
JR: Another cheerleader got hold of a screenshot of the snap and showed it to her mother, who happened to be one of the cheerleading coaches. Soon the other cheerleading coach saw the vulgar snap, as well. Not amused, the coaches pointed to school rules about respect and unsportsmanlike conduct. And a rule about not putting negative information about cheerleading on the internet.
MR: Right, and on that basis, the coaches suspended Levy from the junior varsity team. For her entire sophomore year. That seemed much too much to Larry Levy, her dad.
LARRY LEVY: They should be concentrating on educating the students and not policing 24 hours a day. I mean their job is to educate, not be social media police you know and watch everything they do. That’s my job as a parent to do that.
MR: Larry Levy talked to the athletic director, the superintendent, and the coaches. He pointed out that his daughter’s post didn’t target anyone in particular. And after all, she didn’t post it while she was at school. It was the weekend. She was merely venting. Couldn’t they just rescind the decision to suspend her from the team?
JR: Answer: No. So Larry Levy took it up a level and explained the situation at a school board meeting. He asked the board to rescind the suspension. Answer, again: No. That’s when the Levys’ contacted the ACLU. Would it be able to vindicate Brandi’s right to free speech?
MR: Answer: yes! So the ACLU sent a letter to the school. A lawyer outlined case law in the Levys’ favor and asked that Brandi’s suspension be removed. The lawyer thought the school would think better of its position and lift the suspension. But that’s not what happened, to the Levys’ surprise.
LEVY: Today’s day and age everything’s social media. They don’t come to their parents and say, “Hey dad, I’m havin’ a bad day. I’m feelin’ depressed.” You know, they put it on social media. Sometimes that’s the only way that we as parents can get into our child’s heads and find out what’s going on.
JR: This father is primarily concerned about his daughter’s mental well being. You might be thinking, wait. The Tinkers were respectfully protesting a war. That’s one thing. But you mean to tell me that a teenage outburst about cheerleading winds up in a court of law? Well, yes...because as it’s so often the case, bigger principles are at stake. As one commentator put it: skeptics might look at the Levy case and think it’s unworthy of attention from the highest court in the land. But just like you can’t be a little bit pregnant, you can’t be a little bit constitutionally unprotected, either.
MR: So the Tinkers protest of the Vietnam War with armbands at school is constitutionally protected. Brandi Levy’s protest of not making varsity on a social media post? And a gross social media post, at that? Directed at her school? Is that constitutionally protected? That’s what the justices had to decide; where to draw that line.
JR: Let’s go back to 1968 when the Supreme Court heard oral argument in the Tinker case. You can hear the justices trying to work out the limits of speech rights for students. The boundaries of free speech for students in school, on campus. You’ll hear Chief Justice Earl Warren and then the Tinkers’ lawyer, Dan Johnston, joust over the armbands.
WARREN: I suppose you would concede that if it started fistfights or something of that kind and disrupted the school, that the principal could prevent the use of them?
JOHNSTON: The suggestion I believe we're making, Your Honor, is that there should not be any special rule for freedom of expression cases for schools.
JR: And then later on in the argument, a practical consideration: And then later on in the argument, a justice asked whether its a good idea for the Supreme Court to involve itself in the trenches of the day to day operation of a school. And still later, with Justice Hugo Black and lawyer for the school district, Allan Herrick:
BLACK: Now, does the person have any more right to have, say, make symbolic speech than he does actually to talk and engage in speech which the First Amendment protects? If not, why wouldn't these boys have a right to demand that the school let them talk about Vietnam
HERRICK: Oh, they would...
MR: The decision in Tinker came down to 7-2. The main takeaway? To justify suppressing the black armbands, the school would have to prove the conduct would “materially and substantially interfere” with the operation of the school. But what does “materially and substantially interfere” actually mean? Where are the lines to decide what interference is “material and substantial”? In Tinker, the court decided that mere fear of possible disruption didn’t interfere in fact with schooling. Fear of disruption isn’t good enough to justify suppressing speech. And that includes symbolic speech, like an armband.
JR: So the Tinker opinion drew some limits to student speech: substantial, actual disruption on school property. But in the Levy case, the conduct didn’t happen on school property. It happened off campus, on the internet. And there’s a question about just how disruptive the Snapchat post actually was. So what are the limits in that situation? Where does school authority begin and end in the context of digital media?
MR: The Levys’ lawyer, David Cole, argued to the US Supreme Court that it should not expand the contours of Tinker beyond the school campus. Here’s Cole in April 2021 during oral argument by phone:
COLE: Within the context of school supervision, whether it's an after-school program, whether it's a class trip, whether it's in the classroom, Tinker applies. And Tinker does mean that the school can shut down a speaker if that speaker, that those words are going to lead to disruption, period. Whether it's political, whether it's religious, that's the state of the law in the cases below. But outside of school, the priority is not to give the school discretion to regulate kids' speech. It's to protect people's freedom of speech outside of school. So our line is, I think, quite simple. In school, you can apply Tinker. Out of school, you can't.
JR: In other words, Cole argued, it’s a question of who is in charge of the student when the speech is made. Who has supervision authority over the minor child? When parents are in charge, that’s the line over which schools must not cross.
COLE: What does that mean? It means you can't punish out-of-school speech because listeners in school might be disrupted by the message. What we have then is a tailored approach which deals with the specific problems at issue rather than a sledgehammer approach which says: we're not going to try to define bullying or harassment or cheating or threats; we're just going to say, if the school can call it disruption, they can punish it, even if it occurs on the weekend.
MR: And that, Cole argued, is just too much license for schools, to be able to regulate student speech that occurs off campus. That’s what the lower appeals court decided and he argued the Supreme Court should affirm that reasoning. But Chief Justice John Roberts seemed to see a new line to draw, to account for social media:
CHEIF JUSTICE ROBERTS: Mr. Cole, that sharp line I think you're trying to draw between on campus and off campus, how does that fit with modern technology? I mean, if a text or a Snap that you send, you send from the park and it's read in the cafeteria, is that off campus or on campus?
JR: Cole replied just go back to the supervision test; Snap sent while in school is one thing; Snap sent outside of school is another.
COLE: The Internet doesn't change that your Honor. If anything, the Internet underscores the importance of assuring that kids outside of school have the right to speak freely because that's where kids speak. If any time they do that and that means that somebody in school at some point might read it, the school can, therefore, regulate it. If it's a swear word or if it's disruptive or if people object to it at school in a way that causes problems for the school, then kids won't have free speech, period. They will essentially be carrying the schoolhouse with them wherever they go. It would essentially reverse Tinker.
MR: But wait a minute. Justice Clarence Thomas wondered not about where the student created the message, but where other students would see it:
JUSTICE THOMAS: And you could send the exact same messages that could cause problems from your local 7-11 or you could send it to classmates who happen to be in class. You could send it over the weekend, but it still has a permanence that would certainly allow it to be used in class. So I don't know how you locate the conduct in school versus out of school when you have social media…(later)...So does the speech occur when it’s written or posted or when it’s read or downloaded?
COLE: It occurs when the speaker acts...
JR: In other words, when Levy hit “send” on Snapchat from the convenience store, that’s where the speech occurred. Not where someone happened to read it. So that’s one line the court could draw, as far as when internet speech begins.
MR: Justice Samuel Alito picked up the bullying thread. He asked How are schools supposed to deal with that in this internet age? Lawyer Cole (for the Levys) pointed to bullying codes in states and schools that’ll deal with bullying. I looked up Pennsylvania’s bullying policy and some others, including the Centers for Disease Control. From what I can tell, these codes describe different kinds of bullying, like tripping someone on purpose, relentless insults, spreading rumors or breaking confidences. Bullying typically means unwanted aggressive behavior between people where there’s a power imbalance. And it includes the likelihood of repeat bullying.
JR: But Cole argued that on the facts of this case, with what Brandi Levy did? That wasn’t bullying. So the school went too far … the petitioner, as he calls them:
COLE: But what the Petitioner's approach would do is say we don't even have to address the question of, you know, how you define bullying because we'll just call it disruption and the school can regulate it wherever it happens. And that makes no distinction between what's mean and what is bullying.
MR: On the other side, for the school district, lawyer Lisa Blatt, argued online communication requires special consideration.
BLATT: First, off-campus speech, particularly on social media, can be disruptive. The Internet's ubiquity, instantaneous and mass dissemination, and potential permanence make the speaker's location irrelevant. Yet, the decision below arbitrarily treats location as dispositive.
JR: Location of the speech, she argued, isn’t a good place to draw the line. That’s because disruption is one of the key points of the Tinker decision. Yes, students have First Amendment speech rights at school, so long as the speech doesn’t disrupt the educational process.
Blatt pounded on the effect Brandi Levy’s post had on others, in essence, how she targeted the school and cheerleading. That wasn’t nothing.
MR: Justice Sonia Sotomayor picked up on that disruption thread: The coaches didn’t actually spend that much time on the incident.
JUSTICE SOTOMAYOR: How is that a substantial disruption, number one? And how is this, the nature of the speech, such that it intends to provoke disrespect when she put it to a page that was supposed to disappear and it was only a classmate taking a snapshot who showed it to anybody?
BLATT: Yeah. Well, Justice Sotomayor, I'm not impressed with the Snapchat defense because she could do the same thing to a thousand people and say, “oops, it disappeared and I'm going to do this every night to my coaches.” They don't like it. It's disrespectful. My teammates are afraid of me. I don't really care. And the answer is because she's a cheerleader and it's an extracurricular program where she consented to an extra degree of regulation, because she's a school ambassador. It's a self-contained program that teaches not just teamwork but respect for coaches.
MR: Blatt further asserted it makes zero sense to limit the school’s authority only to what’s said on campus. That was Tinker, eons ago.
These days, the better test is to consider just how disruptive a student’s speech is. And Levy’s post caused enough disruption to count. No matter if on campus or off campus.
JR: Well, in June 2021, the justices handed victory to Brandi Levy. An 8-1 opinion in favor of her right to freedom of speech under these facts. The court said the special interests offered by the school are not sufficient to overcome Brandi Levy’s interest in free expression in this case. That, while acknowledging that public schools may have a special interest in regulating some off-campus student speech.
MR: Once the decision came down, my mind immediately went to the Tinker siblings. What did they think about the court’s decision? I called them up. First, John Tinker:
JOHN TINKER: I have to applaud their decision….And I think that was a wise decision. I give, I give them all credit for doing that. I saw in it a real authentic conservatism among the conservative justices and I give them credit for that. They didn't overstep their bounds, and they weren't acting from primarily an authoritarian perspective. They were really looking at the legal issues and, and deciding the case accordingly, and I thought that was good.
JR: And Mary Beth Tinker, who’s a nurse and brings her health and medical perspective:
MARY BETH TINKER: Expression is a very important part of health. And to be able to advocate for your own interests is very important for your health. Brandi may have said things in a way that some people did not like. Her cursing was not acceptable to some people, but it's important for young people to express their feelings.
MR: Their lawyer Robert Corn Revere wrote an amicus brief in support of the Levys. He helped to break down the opinion.
REVERE: So the court was really conflicted on where to draw the line. And in particular Justice Breyer who ultimately wrote the decision for the court, who is not known for being the strongest justice when it comes to First Amendment matters. And he affirmed that there are going to be certain circumstances where the special characteristics of the school give schools additional license to regulate student speech. They don't disappear just because speech is off campus. So he nods toward those other kinds of cases, threats or harassment or you know, things like that. But he says, there are three factors that generally limit the ability of schools to regulate student speech when it's off campus.
JR: Factor one: Justice Breyer wrote that geographically speaking, off campus speech is typically within the zone of parental authority. Factor two: courts need to be skeptical when a school wants to regulate off campus speech. That’s because political or religious speech often happens off campus, and the government must overcome a heavy burden to interfere with speech like that.
MR: For factor three, I’ll let lawyer Revere explain Justice Breyer’s majority opinion:
REVERE: And then finally, he says that America's public schools are nurseries of democracy. And that means that this only works if we protect the marketplace of ideas. And the protection must include the protection for unpopular ideas or ideas that have or because popular ideas have less need of protection.
MR: Revere added that the disruption aspect brought out in the Levy case is quite significant. The school district put forth extremes to make the case that it should have authority to police off campus speech. For example, what if there’s a death threat?
REVERE: Or a bomb threat? The fact that it's called in from off campus shouldn't matter? What if you have students harassing each other, you know, all of these parade of horribles that you would think to a reasonable person well, of course, the school should be able to address that. It’s interesting too, Justice Alito wrote a long concurring opinion...And he explained that you can't make the price of public education, the relinquishment of First Amendment rights. Right? You can't say that public school students have fewer first amendment rights than private school students.
MR: But what about the school’s argument that it would only regulate when absolutely necessary? The justices factored that into its analysis; the phrase “absolutely necessary” leaves no real limits on the school’s authority.
REVERE: Here, the school was arguing that because a couple of people at school were visibly upset that that was enough to trigger the question of whether or not that was a substantial disruption. And so this would put everything that students communicate to each other, anything that they put on their social media posts, under the jurisdiction of the school.
JR: Let’s take a moment here. The Bible says in Ephesians 5:4 that Christians ought to guard their speech. It says there should be no “obscenity, foolish talk or crude joking, which are out of place.” There’s no list of “bad words” to avoid in there; those change over time. Rather, it’s a principle for Christians to follow. To avoid that which is dishonorable to God..
MR: Contemporary America is immersed in profanity—on tv, in music and movies—so that filthy language gets desensitized to our ears. To teenagers’ ears. No Biblical inclinations came to bear in the Levy case. But Revere was careful to delineate what the Constitution says about it.
REVERE: The First Amendment doesn't grade on a curve, giving greater protection to what is called to be important speech and less protection to trivial speech. The First Amendment is to protect us from government power. And every First Amendment case when you're telling people what they can think or say, is an important case. And so, Justice Breyer, I was glad to see, picked up this notion. And he wrote that while it might be tempting to dismiss BL's words as unworthy of robust first amendment protection, sometimes it is necessary to protect the superfluous in order to preserve the necessary.
JR: B-L’s words--Brandi Levy’s words--superfluous, sure. But in protecting the superfluous, you preserve the necessary. Meaning, when Brandi Levy’s speech is protected from government overreach, that is further protection for all of us. We wondered what lawyers who filed briefs in support of the school thought of the decision. One of them was Gregory Garre. He filed an amicus brief on behalf of the National School Boards Association and others in support of the school in the Levy case. His clients wanted to make sure the Supreme Court left room for schools to address bullying and harassment via social media aimed at teachers and administrators. What Justice Alito asked about during oral argument.
MR: Garre said off campus speech still matters to schools. Did Garre think what Brandi Levy did was bullying? No, he did not. Bullying involves sustained, targeted harassment over time. But his clients, the educational groups, didn’t want the lower court’s categorical rule to stand: that Tinker’s disruption test never applies to off-campus speech.
GREGORY GARRE: And you know, in this case, I think the schools lost the battle in the form of whether they could regulate this particular cheerleader's vulgar social media post, but essentially won the war in what they were concerned about, which was the elimination of the Third Circuit's inflexible categorical prohibition on the application of Tinker to any speech that originates off campus, even when it's in the form of a social media post.
MR: So he’s pretty pleased with the decision because it rejects that categorical rule, and it looks at the nature of the speech in question, and doesn’t say it’s off limits just because it originates off campus. As to the vulgarity of Brandi Levy’s post?
GARRE: I think most people would agree that, you know, parents, you know, can and do have a primary role in, you know, making sure their their children aren't sending inappropriate texts, whether or not those texts rise to the level of disruptive speech that schools can reach under Tinker or not. I mean, parents are really the first line defense to all of this.
JR: Several other organizations filed in support of the school as well. One such amicus brief came from David Rubin on behalf of several anti-bullying organizations. Rubin had an interesting perspective about how times have changed:
DAVID RUBIN: And it's interesting how views of bullying have changed over the generations. I'm a child of the 60s myself. And when I was growing up in the late 50s, and 60s going to school, what was drummed into us at that time, “sticks and stones will break my bones, but words will never hurt me.” That's how we were brought up to deal with that sort of bullying.
JR: Rubin noted that’s all changed in the digital age. Kids have smartphones and they can harass, intimidate and bully without supervision 24/7, 365 days a year to a worldwide audience. And they can do it anonymously.
RUBIN: And the data has shown us that bullying rarely takes place either on campus or off campus in isolation. It typically is a pattern of behavior where one or a bunch of kids are taunting a particular student at school, off campus, in person, online, back and forth. So to talk about whether bullying is happening on campus or off campus, it is really an arbitrary distinction these days in the digital age because of the hazy boundary line between what's happening on campus and off campus, online or in person.
MR: So Rubin was pleased with the ruling in Levy, as well. The disruption of Levy’s post just didn’t rise to the level that required a year’s suspension from cheerleading. Still, the Supreme Court left it to the lower courts to sort out what a “substantial disruption” means, outside the facts of Brandi Levy’s case. He offered some guidelines based on the law as developed so far:
RUBIN: And it requires more than just some eye rolling or some hurt feelings. It has to be some level of disruption that significantly interferes with the orderly operation of the school. You know, school had to be shut down because fistfights were breaking out in the hallway. A teacher couldn't get through a class because the kids were so distracted by what had happened online that they were talking to each other throughout the class and the teacher couldn't get any education done.
MR: During oral argument, Justice Breyer talked about how parents have ceded a lot of control to schools. Providing meals, after-school care, healthcare, for example. That blurs the lines of authority in many ways. Rubin told me the court’s grappled with the bounds of school authority for decades.
RUBIN: Even if you go back to the Tinker decision in 1969, even then, if you read the court's opinion, and the other opinion, separate opinions of the other justices, there's disagreement among them even back then as to what the role of the public schools are. You know, there were in one of the opinions, there's a discussion about schools supposedly, being a, you know, a crucible, a marketplace of ideas and a place where kids should be able to express themselves and maybe serve as teachers themselves to other people by expressing their views. And then there's a contrary view by one or more of the other justices saying no, no, no, no. Schools are where you go to learn how to read, write and learn arithmetic. Students are there to learn, not to teach. And this idea of schools being that as they are today, you know, sort of an all purpose social service agency, as many schools have come to be by out of necessity, was something that really was not the case back then.
MR: Bottom line of the Levy decision?
RUBIN: Well, the court made it very clear that they were not gonna come up with an exhaustive list of scenarios that school districts could or couldn’t regulate when it came to off-campus or on line conduct they encourage school districts to be mindful of their own mission and before they try to shut it down determine whether perhaps this is an opportunity for a teachable moment. Maybe rather than discipline them, have a conversation with them about what they were thinking, maybe acquaint them with how hurtful what they said might have been to some folks. And approach more in a discussion or counseling or teachable moment mode rather than discipline. The net takeaway, if you will, from the decision was no blanket ban on regulation of off campus speech, but school districts are going to have a higher bar to persuade a court in a particular case that they had a legitimate interest in regulating that off campus speech.
MR: We’ll end with the very people who started us off: the Tinkers and the Levys. Families who, 52 years apart in time, have their names on free-speech cases. First, Mary Beth Tinker, now in her late 60s:
TINKER: I never dreamed that I would be talking and about this 50 years later, that's for sure. I mean, again, it goes back to the idea of just ordinary people, you know, doing their small actions.
JR: And her brother, John Tinker:
TINKER: The ability to just say what's on your mind is a really priceless right that we have. And even if it's said crudely, with offensive words, I think that the principle of freedom of speech is a very valuable principle and that it needs to be circumscribed only with a great deal of circumspection. How can we have a democracy really, if we can't exchange our opinions with each other, even if they're crude?
MR: And what might he say to Brandi Levy, reaching a hand out across 52 years of law that he helped to create?
TINKER: What would I say to Brandi? I don't know what I'd say except for like, “right on!” You know, I'm, you know, I'm glad you I'm glad you pursued this. I think it's really important that kids be able to talk among their friends however they like without an adult, school especially, presence. Without the long arm of the school board, reaching into your Snapchat. We had a, you know, it was free speech for political reasons. And the war later, of course, became condemned almost universally. And so we were early on that, and were seen as heroic. Now, Brandi Levy is not going to be seen as heroic especially, except that she did stand up for her right. And that I think is really valuable.
JR: As for Brandi Levy herself? She graduated high school in 2020 and now majors in accounting at university. She’s a little older now, a bit more circumspect. And probably wouldn’t use that language these days. Still...
LEVY: Like from my standpoint today I’m older and I know more. I don’t know like, that’s how all 14 year olds spoke, like that. That’s how all of my friends used to talk, like that. But I’m proud of sticking through it all the way to here. I really am because it’s going to prove a point that schools shouldn’t be able to punish students for how they express their feelings and how they want to.
MR: Legal Docket is produced by the creative team at WORLD Radio. I’m Mary Reichard.
JR: And I’m Jenny Rough. We’re the hosts each week.
MR: Our script editor is Nick Eicher. Technical engineer is Rich Roszel, and our producer is Paul Butler.
JR: Our thanks to those people who offered their time and expertise to this episode: David Rubin, Robert Corn Revere, Gregory Garre, John Tinker, Mary Beth Tinker. And to organizations that provided audio: Oyez.org and Supremecourt.gov.
MR: Also, music artists Buffalo Springfield and Imagine Dragons. We’ve been so encouraged by the ratings and reviews you’ve left for us! We’re a small team competing with some really big players! So if you haven’t left us a review on whatever platform you use, would you consider doing that right now? It really makes a difference to help others find us. Thank you.
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