Law school jitters

Tempus fugit. Almost 6 months ago, jittery law graduates trooped to the University of Santo Tomas (UST) on España Boulevard to take the final test to become lawyers.

Today, the long wait is finally over. The “Gods of Faura” have released the much awaited verdict for this year, the final lap of the long obstacle course of legal education – the bar examination results.

Passing the bar exams – or flunking them, for that matter – may just be a facet of a law student’s journey to the portals of the legal profession.

The real adventure begins on the first day of class.

Ask any law student, and you’ll probably get a similar answer. For one, it is an entirely different academic arena, far from the usual classroom routine.

Society has its own way of showing its high regard for law students and I take pride in being one of them. The respect and courtesy that society has bestowed upon people in the legal profession, you must realize, is earned not from the time they pass the bar and become full fledged lawyers, but from the time they become students of the law.

Surviving law school

As a mere law student now, I have my own share of stories about struggling to keep such respect. Surviving it is one.
To survive law school you have to have a one-track mind – read, read and read.
Sometimes there seems to be no escape from this book-driven life.

In my case, I have to set aside my social life if any, even religious activities, just to devote more time reading voluminous cases being assigned to us by our professors.

But the more dangerous and fearful path for each law student is class recitation. Law students, even most established lawyers I know, have their own story of recitation mishaps to tell. I am happy to tell mine.

First mishap

It was Monday evening, first meeting for my environmental law class. The silence was deafening as I stood valiantly after my name was called. It was the start of a long night for class recitation.

The case dealt with the constitutionality of the IPRA law, a novel legislation that protects the ancestral land rights of indigenous peoples.

As I was about to discuss the court ruling, my mini-eccentric professor suddenly interrupted me and started to fire questions indiscriminately.

While still armored and battling, I seemed a helpless victim for a while. The adrenalin kept rushing as I searched for more answers in my head. Most of the questions were really tough and he was posturing, like he wrote the dissenting opinion of that case.

After his unwritten dissenting opinion, he out of the blue muttered, “Mr. Bonoan are you reading the book of Zaide?” I stood my ground and proudly said yes to the question. I had no choice but to defend my argument about the benefits of the Spanish inquisition, otherwise I would be in limbo.

I must not quiver at this point, I told myself over and over again.

Obviously, he was aghast at my answers. He ordered me to simply sit down and called on another student. I was totally devastated because I studied the case from all possible angles, or so I thought.

It was only later that I came to know that my professor was a fiery advocate of indigenous peoples' rights. Incidentally, he was among the lawyers who argued before the Supreme Court in the IPRA case. What was I thinking?

On second thought, I felt vindicated because I engaged him in a sword fight, although I ended up being slaughtered to death.

From then on, I bowed not to limit my readings simply to law books, and expand them to include history and other disciplines.

Second mishap

My next terrible experience was when I was taking up Tort law under a Jesuit-educated professor.
Tort law is a very interesting subject because it deals with mostly accidents and mishaps, and the facts of every case are fascinating and fun to read.

One such case was Picart v. Smith, a very old yet landmark case in tort law.

While it seemed an easy read at the start, the intertwined facts and colloquial language made it trivial.
When my professor shuffled the class cards, I suddenly found myself mumblng all over again, “Oh God, not me. Not me, please.”

But alas! I was the first one to be called! His next words were defeaning. “Chris Bonoan, where are you? Oh there you are! Please recite Picart v. Smith.”

In utter fear or confusion, in whatever order, I muttered to myself, “Oh God, Lord why have you forsaken me!” And like any good soldier, I kept the faith and kept trying to explain the case until my esteemed law professor asked me to visualize on the board what transpired in this popular pony accident case.

Unfortunately, I just could not hit the mark. He suddenly became impatient. But who would not be?

I was literally consuming more than the time allowed for each case. No wonder his expression turned sour as my voice trembled.
Finally, he said, “Sit down Sir, sit down!” in a tone that almost buried me alive.

My classmates definitely had a good laugh with my shocking and unforgettable experience that night.
Good thing for me, they had worse encounters.

As I said, there will always be a next time. But not too many next times. We have to earn the respect right now and not next time. We can always have room for that one time, and maybe another.

And this is the time! Congratulations to those who passed the 2013 Philippine Bar Exams. Indeed, you guys have been tested and found not wanting!

PS: CONGRATULATIONS APRIL JADE A. BONOAN FOR PASSING THE 2013 BAR EXAMS, WE ARE SO PROUD OF YOU!!!

Article courtesy of RAPPLER (3/17/14)

Dear Nards: A quick recourse on Doy and Macoy

Dear fellow Filipino,

Hi Nards, sorry for the late reply. Point well taken, but I assure you that there are no inconsistencies here. My admiration for Salvador H. Laurel on one hand and Ferdinand E. Marcos on the other is in fact a reflection of my own idea of what “nationalism” should be, and my objectivism in relation to history.

With your permission, allow me to repost your enlightening comments here in toto:

I only learned about your blog not so long ago upon stumbling with your article on Marcos. I must say it's great and it's enlightening. I'm not into politics but I am so much interested about Marcos, the EDSA and its aftermath and what is really the truth. By continuously knowing the person, Marcos, through and by his works, writings, philosophies, ideologies, speeches and stature in life, you wouldn't believe he was capable of doing those atrocities that the people have been throwing at him since. The fact that those accusers cannot present a single evidence to finally convict him or her family is likewise a mystery...

I was enjoying your entries until i came across your write ups on Doy Laurel, hence this comment of mine. There seems to be a contrasting idea between your belief or earlier admiration on Marcos from your Marcos entry and on how you pictured the Marcos regime in this article of Doy, especially when you wrote on a conclusive note "oppressive regime that terrorized the nation for a long time". I hope this is not your personal opinion but was stated on the perspective of the Aquinos and their allies or Doy for that matter. I never find any reasonable justification of the EDSA other than politics and power struggle. I see EDSA as a great deception, self-serving and the culmination of great betrayals. Doy was one of them and while he had genuine intention, "karma" got the best of him when Cory betrayed him as well. EDSA was never for the people, but left the common tao to pick up the pieces wondering when it will be whole again. Marcos vision was a lost opportunity for me. He was setting the stage for a greater purpose, but we took that stage and rebel against him because of what they "said so".

This is just my piece and would be happy to be refuted/corrected.

Thanks for sharing your great mind and knowledge to everybody.

Before plunging into the gist of your comment, let me state briefly the political backdrop of Doy and Marcos, a principled political relationship that is barely touched on by yellow historians.



The special political relationship of the Laurels and Marcos is no secret. They had always been fair-weather political allies for as long as I can remember. Marcos admired wartime Philippine President Jose P. Laurel for his intellectual prowess juxtaposed with the courage he displayed during the Japanese Occupation. (Not to mention the ponecia of Justice Laurel in the Nalundasan Murder Case, acquitting the young Ferdinand Marcos on appeal.) The Laurels were also responsible for Marcos’ entry in the NP that ultimately made him president in 1965. And when Marcos sought re-election against the weakling Serging Osmena (LP) in 1969, the old guards of NP (the Laurels) rallied behind him. Marcos won a second term.

Prelude to a fallout

Eventually, Marcos declared martial law in 1972 and at the outset, the Laurels opposed it─ privately. Nonetheless, the Laurels gave Marcos the benefit of the doubt but only under the assumption that martial law was just a temporary measure to bring order to the country.

Upon his return from the United States, Senator Doy received word that Marcos wanted to see him in the Palace. As the outspoken opponent of Marcos within the NP, he braced himself for the usual rhetoric. But Marcos went straight to the jugular. Without missing a beat, Marcos told Doy not to “rock the boat” because he had already burned his bridges; there’s no way he could turn back. Doy tossed up a repartee, cautioning Marcos that “martial law” is a double edge sword: it can be used to cut for good or evil. If Marcos used it to cut for good, then Doy (now a jobless senator) assured the President that he has nothing to worry about.

Divide and rule

Years later, sensing the ship of state was drifting off course, cracks began to surface in their political relationship. History has recorded what happened. The first confrontation between the Laurels and Marcos took place in Malacañang─ the year was 1978.

As a precursor to his so-called “politics of transition,” President Marcos saw the need to abolish existing political parties and tried to form a new political party of his own; initially he called it, “Lapian ng Bagong Lipunan” or the “New Society Party.” Surely, the Laurels opposed this move, believing that this was just one of Marcos' Napoleonic ploys to disintegrate the political opposition─divide et impera. The Laurels, speaking through former Speaker Pepito Laurel, reminded Marcos that it was the Nacionalista that made him president twice. And so Speaker Laurel came up with an idea; a win-win solution that would merely place the NP (and other opposition groups) in suspended animation. “Don’t kill it (Nacionalista), Mr. President. Just let it rest, let it sleep for a while” said Pepito Laurel. “The same with the Liberal Party, let it rest and sleep for a while…until political normalcy is back, it’s pointless anyway to have political parties. There can be no real politics, when all politics is controlled.” Marcos, after some thought, bought the Speaker's 'umbrella' idea.

Soon afterward, a movement, not a political party, was born in the form of Kilusan bagong Lipunan or KBL.

The ghost of KBL

On his end, Doy Laurel felt uncomfortable with the whole setup. But since most of the leading traditional oppositionists (e.g., Tanada, Roxas, Salonga, and Macapagal) supported the seminal boycott movement, Doy was compelled to run as a Nacionalista candidate under the KBL umbrella. Doy believed that that the interim Batasan elections would speed up the return to normalcy; that was his primary reason why he chose to go along with Marcos. When asked candidly by President Marcos why he was hitting him during sorties, Doy Laurel quipped: "I will support you when you are right Mr. President but I will criticize and oppose you when you are wrong.”

Doy won a seat in the 1978 Batasan elections. For this, Doy was severely criticized many years later when he led the active Opposition in the 80s; and to this day only a handful of people know the real score about his stolid affiliation with KBL.

Untying the political knot with Marcos

A year later, however, President Marcos changed his position. Unbeknownst to Doy, KBL was now a political party. This development forced Assemblyman Doy to confront Marcos face-to-face for the last time. The KBL members present during the Imelda-for Deputy caucus in Malacanang gobbled up on Doy until President Marcos came to the fore. After going over every detail of Doy's legal arguments, Marcos finally muttered," “If the Nacionalista Party does not wish to become part of the KBL, then let it play the role of the opposition!” To which Doy replied so poignantly, “So let it be Mr. President…so let it be!” Then he politely walked out.

Doy Laurel regards that confrontation as his final split with Marcos. From thence, Doy Laurel spearheaded the active Opposition, and formed Unido.

I understand, as you have pointed out, that there seems to be a contrasting view for my admiration of Marcos vis a vis the way I described the “Marcos regime” when I wrote the article, “The Honorable Doy Laurel.” Now let me state categorically that indeed the “regime” of President Marcos at that time was a far cry from the hopes and dreams he envisioned under the “New Society.” In the waning years of martial rule, the regime became oppressive, abusive and oblivious to the democratic principles that Marcos stood for in “Mandate for Greatness.” Ironically, for Doy Laurel, he came into the picture at a time when President Marcos was already losing his hold or control on the levers of power. It was his twilight years, and personally, I believe that the phrase “oppressive regime” is an apt description of the situation.

Like what I always use to say in my write-ups, I’m not a blind follower nor a loyalist; I subscribed more on “ideology” or “philosophy” rather than personalities. (Notice that my article on Marcos is titled “Marcosian Ideology,” emphasis is made on his political thought.)

In my RAPPLER article (published on 2/25/14) titled, “Doy Laurel: EDSA’s unsung hero,” note how I viewed EDSA revolution (if at all you can regard it as a “revolution”) from the vantage point of someone who never witnessed EDSA first hand: “Today marks the EDSA Revolution’s 28th year yet our vision is still blurred, if not myopic. I state with no intention to undermine the church, EDSA was far from being miraculous. It was bloodless not because of divinity but of overflowing patriotism with the AILING MARCOS TO NO EXCEPTION.” (Here's the link: http://www.rappler.com/move-ph/ispeak/51532-doy-laurel-edsa-unsung-hero)

I hope I was able to clarify things with you Nards.

Again, thank you for visiting my blogs and for posting your intriguing comments as well. (Re Doy’s letter to Cory, I’ve already read it many years ago, it was also highlighted in Doy’s book of revelation titled “Neither Trumpets Nor Drums: Summing Up the Cory Government.”)

With utmost sincerity,

C.D Bonoan

Doy Laurel: EDSA's unsung hero

02/25/14 As published in Rappler.com

Much has been said about the 1986 EDSA Revolution that ended the 20-year Marcos dictatorship. Yet there a good number of stories left unsaid, stories of unsung heroes that were systematically suppressed by the victors of history. While many people tend to associate that popular revolt with Cory, I chose to go the other way around. Thus, when I hear the song Impossible Dream, I can’t help but recall a quintessential statesman long forgotten by history. No, I don’t mean the perceived martyr Ninoy, but the distinguished Batangueño whose dream to selflessly serve our country as president (and probably could have been one of the best Philippine presidents in our history) was made impossible by an unfortunate string of historical events.

Today marks the EDSA Revolution’s 28th year yet our vision is still blurred, if not myopic. I state with no intention to undermine the church, EDSA was far from being miraculous. It was bloodless not because of divinity but of overflowing patriotism with the ailing Marcos to no exception. EDSA therefore is not singly the Aquinos, nor the church but also the other unsung heroes who marshalled the people into this noble fray - one of whom is Salvador “Doy” Laurel.

Unido

Flashback to the ‘80s. Because most of the opposition cowed in fear, Doy et. al. had no choice but to continue the fight even on dangerous grounds. Some even went to the extent of supporting the red armed struggle. Doy of course disagreed. His unfettered optimism, devotion to constitutional principles and faith in the Filipino people inspired him to do what he was destined to do; and so came the United Nationalist Democratic Organization (UNIDO).

The genesis of this organization was to foster the marriage of convenience between two erstwhile formidable opposition parties: Liberal and Nacionalista, under the joint leadership of Senator Gerry Roxas (Liberal) and Speaker Pepe Laurel (Nacionalista), older brother of Doy. But with the untimely death of Senator Roxas, the party, disregarded the previous dual leadership arrangement and ended with Doy’s election as the new sole president. UNIDO was to become the opposition’s potent umbrella organization in the ‘80s under Doy’s audacious tutelage; cobbling together disparate opposition groups seeking to remove Marcos from power through peaceful means.

UNIDO despite its limited resources, managed to win the elections entirely dominated by KBL candidates. From makeshift stages, rallies in Plaza Miranda to noise barrage, UNIDO under his leadership became the people’s sounding board against the repressive regime. Finally in 1983, UNIDO came out of its cocoon and became a full grown opposition party with capabilities of destroying the manacles of dictatorship.

The turning point

The nation was stunned when Ninoy Aquino was shot dead in broad daylight. Naturally, Anti-Marcos protests soon reached its peak. In utter disgust, Doy Laurel resigned immediately from the farcical parliament of Marcos. A few days later, as he was about to deliver his valedictory speech in the halls of Batasan, lights were shut off but Doy refused to be silenced. In front of local and foreign media, Doy Laurel stepped outside of the building and right there and then delivered his fiery speech in honour of his fallen comrade.

Cory and Doy

Fast forward to the days following President Marcos’ call for a snap election. Undoubtedly, Doy was the logical candidate to represent the Opposition for no other person had the balls to stand up squarely against Marcos except him. At this juncture, rumours had been going around that Ninoy’s widow intends to run as president. Of course, Doy, ever the gentleman that he is, went out of his way to sort it out with Cory. This was denied a number of times over by her and if I may so, has denied it even up to her very last breath. Much to Doy’s surprise, Cory endorsed his candidacy on June 12, 1985 at the unprecedented UNIDO national convention attended by 25,000 delegates from all over the country.

Later however, it was Cory who became the opposition’s banner holder. Doy peacefully acceded and slided to the vice presidency. And the rest, as they say is history. Living what his father reared him to be, it was not surprising that Doy faithfully followed, “Ang bayan, higit sa lahat.”

Opposition united?

To my end, it is not about if Doy could indeed beat Marcos in the 1986 snap election. In fact, given Marcos’ unbounded powers, resources and machinery, Doy surely would have been defeated. But the decisive question is who led the opposition when everyone else was silenced by fear? Who inflamed the hearts and minds of Filipinos at a critical time when they needed someone to look up to? EDSA Revolution therefore is the culmination of that long arduous anti-Marcos struggle led by Doy and other opposition figures who were with him one way or another.

The events that happened from 1980 to 1983 are the “missing links” in Philippine history. Those crucial moments were deliberately expunged from the collective memory of Filipinos. Surely, these are the times when Doy was at his best! On my end, more than his accomplishments as a senator during the pre-martial law years, not even his magnanimous decision to step aside as a presidential contender in favour of Cory would equal his role as a freedom fighter and opposition leader at the onset of the ‘80s.

When the mists of partisan passion gradually lift with time, the full extent of Doy’s service to his nation will be revealed. In his acceptance speech at the UNIDO convention dubbed as “The Final Battle,” Doy, the champion orator, delivered an impassionate plea: “Democracy cannot take root amidst violence. Bloody revolution is not the only path to freedom. All confrontation must end in reconciliation.” He could not have said it better because these very same words had served as pattern for the rest of his political life.

The 1986 People Power Revolution now belongs to the entire nation, and not just a few personalities who claim to be its posthumous heroes. No political clan can therefore rightfully claim notoriety to it. EDSA is also about the forlorn heroes and heroines, Doy being one of them, a first-rate Filipino leader with a masterful grasp of our nation's destiny.

Ultimately though, EDSA belongs to the people, as its name verily suggests. I bet to this, Doy Laurel would agree no less.

PS: The author would like to thank RAPPLER.COM for publishing this article.

Concerning Nukes and International Law

Sovereignty has long been defined as the supreme, uncontrollable power inherent in a state by which that state is governed. To be precise, it is the supreme power of the state to command and enforce obedience, the power to which, legally speaking, all interest are practically subject and all wills subordinate. Under international law, sovereignty or independence has two aspects, namely, internal and external sovereignty. The latter signifies the freedom of state to control its own foreign affairs while the former refers to the power of the state to direct its domestic affairs. Obviously, domestic independence enable states to organize its form of government, enact its own constitution and laws suitable to its needs, and adopt national policies consistent with its national interest. In the same vein, the second aspect of independence concerns the right of the State to conduct its foreign relations with other States without interference by other States. Charles G. Fenwick, one of the noted authorities in the field of international law, offers one vital qualification to the word ‘independence’; he said: “Independence only means freedom from control by any other state and not freedom from the restrictions that are binding on all states forming the family of nations.” Thus, as a rule, sovereignty is absolute and all-encompassing on the domestic level but subject to restrictions and limitations voluntarily agreed by States expressly or impliedly, as a member of the family of nations.

It is undeniable fact that State practice for some fifty (50) years clearly demonstrates the idea that possession of nuclear weapon per se is not illegal under international law. It is for this reason that most States consented and even supported the possession of nuclear weapons by the “Big Five” pursuant to the Treaty on Non-Proliferation of Nuclear Weapons (NPT). The perceived acquiescence by the international community of NPT has created the impression that these nuclear powers are legally entitled not only to possess, but also to use nuclear weapons under certain circumstances and to threaten their use. Vice-President Stephen Schwebel of the International Court of Justice opined:

This nuclear practice is not a practice of a lone and secondary persistent objector. This is not a practice of a pariah Government crying out in the wilderness of otherwise adverse international opinion. This is the practice five of the world’s major powers, of the permanent members of the Security Council, significantly supported for almost 50 years by their allies and other States sheltering under their nuclear umbrellas.

From the foregoing observation, it is crystal clear that this practice has been recognized, accommodated and to some extent, accepted by the majority of States forming part of the international community. The arguments posed by nuclear-weapons States are mainly based on the fundamental principle of independence and respect in the conduct of their foreign relations. It is precisely for this reason that they adopted the so- called, “policy of deterrence” to justify their position. Under this policy, in order to lessen or eliminate the risk of unlawful attack, states signal that they possess certain weapons to use in self-defense against any State violating their territorial integrity or political independence.

Under Article 2, par. 4 of the UN Charter, members of the United Nations shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any state. This provision must be read in conjunction with Article 51 of the same charter recognizing every state’s inherent right of individual or collective self-defense if an armed conflict occurs. Clearly, the provisions cited do not refer to specific weapons. They apply to any use of force, regardless of the type of weapon employed. In the advisory opinion rendered by the World Court concerning the legality of nuclear weapons, it noted that the UN Charter neither expressly prohibits nor permits the use of any specific weapon. Accordingly, whatever the means of forced used in self-defense, the dual customary condition of necessity and proportionality and the law applicable to armed conflict apply, including such further considerations as to the very nature of nuclear weapons and the profound risk associated with their use. This pronouncement by the International Court of Justice implicitly affirms the right to use nuclear weapons under extreme circumstances in the exercise of legitimate self-defense. But as vividly pointed out by the court, the invocation of self-defense must comply with the principles of necessity and proportionality. As held in case of Nicaragua v. United States of America,” there is a specific rule whereby self-defense would only warrant measures which are proportional to the armed attack and necessary to respond to it, a rule well established in customary law.” Verily, the Proportionality principle thus not in itself excludes the use of nuclear weapons in all circumstances so long it complies with the principles and rules of humanitarian law. It must be stressed that in the said advisory opinion the court pointed out that mere possession of nuclear weapons would not constitute unlawful “threat” to use force contrary to Article 2 (4), unless the particular use of force envisaged would be directed against the territorial integrity or political independence of any state; or in any event that it were intended as a means of defense; such envisaged use of force would violate the principles of necessity and proportionality. Settled is the rule under international law that opinions rendered by the International Court of Justice are highly persuasive and entitled to great respect in resolving issues pertaining to international law. Likewise, decisions and opinions of the World Court offer direct evidence of the existence of a rule of international law.

One of the recognized primary sources of international law is customary law. In many occasions, international tribunals have been using international customs in resolving controversies involving questions and application of international law. In accordance with Article 38, par.1 (b), the International Court of Justice is directed to apply international custom in deciding disputes involving interpretation of international law. In addition, even national courts of most States when confronted with issues pertaining to general principles of international law, the most decisive and effective way in deciding the case is to rely on international customary law.

In legal parlance, international customary law is defined as the "general and consistent practice of states followed by them a sense of legal obligation.” From this definition, the elements of customary law are the following: duration, consistency, generality of practice and the belief that such practice is obligatory. The most important element to consider in determining whether a practice has been transformed into customary law is the existence of opinio juris or the belief that a certain form of behavior is obligatory. Sans this element, practice is not law. As the Nicaragua case puts it: “for a new customary rule to be formed, not only must the acts concerned amount to a settled practice, but they must be accompanied by the opinio juris sive necessitates.” Corollary, a very important question needs to be answered: does prohibition against the use of nuclear weapons amount to international customary law? In answering this question, the General Assembly of the United Nations attempted to forge a consensus in the form of Resolution 1653, aptly titled, “Declaration on the Prohibition of Use of Nuclear and Thermonuclear Weapons.” To support its claim, Resolution 1653 painstakingly enumerated several age-old international declarations and treaties from the Declaration of St. Petersburg of 1868 to the Geneva Protocol of 1925. It only goes to show, however, that there has been no specific rule under customary international law that expressly prohibits the use of nuclear weapons; otherwise if such a rule existed, the General Assembly could simply have referred to it and would not have needed to undertake such an exercise of legal qualification.

Declarations of legal principles and resolutions by the United Nations General Assembly are generally considered “recommendatory” in nature. As a rule, the General Assembly has no authority to enact international law; but if these resolutions are supported by all states they are an expression of opinio juris communis─ thus it becomes part of customary law. Clearly then, did Resolution 1653 gain overwhelming support from member-states? The response leaves much to be desired; for not only did it fail to gather support from all member-states, it likewise failed to secure the approval of all nuclear-weapon States.

It is therefore the view of this writer that a contrary opinion prevails. To support this contention, one need not look further; the Treaty on the Non-Proliferation of Nuclear Weapons provides us with an answer. The fact that said treaty allows possession of nuclear weapons by the five nuclear-weapon States highlights a startling recognition that such dangerous weapons may be used under highly extreme circumstances. It is imperative to note that in so far as customary law is concerned, there appears to be no hard-and-fast rule authorizing the threat or use of nuclear weapon or any other weapon in general. But if the situation calls for it, international customary law impliedly sanctions its ‘use’ on two compelling grounds: in the exercise of legitimate self-defense and if the dual customary conditions of “proportionality” and “necessity” are complied.

In sum, there can be no doubt that nuclear weapons may be used under the most looming circumstances signalling a major conflict─ when the very survival of a state is at stake. International law therefore must strike a balance between two compelling interests: state's inherent right to existence and self-defense vis a vis right to life.

NB: This is a recycled material. I've written this piece way back in 2002, one year before I entered law school.