Law Commentator Issue 08 by Southwestern Law School

FALL 2023

aw school does more for prospective lawyers than prepare them to pass the Bar. In law school, JD candidates learn blackletter law and doctrine, practice their writing and research skills, develop their oral persuasion, and engage in extracurriculars to strengthen their network post-graduation and admission into their chosen state’s bar. From the outside, law schools appear primed to turn their aspiring students into intelligent, detail-oriented, and logical arguing machines. However, law schools worldwide face a notable deficit in their student body that burdens them long after students graduate and contributes to a decline in client care. Empathy.

The question we must ask ourselves is why. Why do many of our future attorneys, judges, and lawmakers overlook the presence of empathy in legal education? Legal education often favors emphasizing the blackletter law while ignoring the implications of the abovementioned factors and their understood bearing on the realistic application of legal standards.² Additionally, empathy is considered a soft or “squishy” skill compared to logical reasoning and, therefore, undervalued in a career colloquially known for its ruthless and “unfeeling” practitioners.³ Students who come to law school with a pronounced sense of empathy either cling to whatever remains of it when graduation rolls around or give up on it because of repeated and systemic training to turn the compassion off.⁴ Then, some students approach school with a lack of empathy entirely and are never encouraged to develop it further, ultimately finding their avoidance of feeling rewarded.

Nothing exists in a vacuum, not even "pure" theory. Even in the legal profession, where many of our cases and the outcomes of those cases are fact-dependent, theory ultimately bends to the will of real-life circumstances. Factors such as socioeconomic, political, and historical context are the reasons behind the creation of specific laws, while an intersectional analysis of race, class, gender, etc., is pivotal to developing more inclusive legislation and improving the care of our communities. Caring about our fellow humans is the reason behind the concept of justice, which our legal system intends to uphold.¹ Yet, discussions and consideration of how these factors impact law and legal services rarely enter the classrooms, thus leaving empathy without a seat at the table.

² Smith Ledesma, Stephanie. “Compassion: A Critical Skill for Law Students.” Marquette Benefits and Social Welfare Law Review 22, no. 2 Spring (2021): 182. ³ “The Power of Empathy | ABA Law Practice Today,” ABA Law Practice Today, January 15, 2021, https://www.lawpracticetoday.org/article/the-power-of-empathy/. ⁴ Ian Gallacher, “Thinking Like Non-Lawyers: Why Empathy Is a Core Lawyering Skill and Why Legal Education Should Change to Reflect Its Importance,” Journal of the Association of Legal Writing Directors 8 (season-03 2011): 9, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1693146.

¹ The American Prospect, “The Law School Empathy Deficit.,” The American Prospect, November 17, 2011, https://prospect.org/article/law-school-empathy-deficit./.

Furthermore, a lack of empathy among generations of lawyers contributes to a compounding problem related to emotional health within the profession. The emphasis on how a lawyer "should think" undermines law students' emotional intelligence and assessment capabilities.⁸ Lawyers and law students experience high risks of poor mental health with the onset of depression, anxiety, or other diagnoses and heightened substance abuse, primarily alcohol.⁹ Unlike students in medical programs such as pharmacy and nursing, law students have shown no growth in levels of empathy.¹⁰ The emotional toll law school imposes on its students is the first or earliest source of strained mental health and a culture of encouraged drinking, seen in "bar reviews" and other social functions hosted inside bars. How do we expect our lawyers to help one another and their clients when they can't show up for themselves? Thus, the empathy problem faces another complicated layer in blindness to a lack of empathy for one's self.

With lecture-based classes as the hallmark of a standard law school experience, classroom discussions follow the Socratic method. Such design gives credence to the loudest voice in the room, not necessarily defined for its empathy or critical examination of how the law impacts people.⁵ Many law classes teach doctrine requiring a more delicate touch, especially when prone to emotionally charged conversations. However, all law doctrines–no matter how removed from perceived social ails people believe them to be–have ties to historical oppression. These dialogues require openness and empathy simultaneously, echoing the adage that truth without compassion is cruelty. However, without an emphasis on empathy during these discussions from the teacher or the institution, conversations of sensitive legal matters negatively impact the quality of education for marginalized students and the safety of voicing their opinions without receiving hostility.⁶ Marginalized students, if asked, could undoubtedly provide several anecdotes about instances where their peers or teachers made them feel off-put or unsafe participating in classroom engagement or the legal profession at large. When harmful conversations proceed without moderation, the overwhelming focus on logic shields hostile points of view underneath a poor excuse of hyperintellectualism and demeans valid critiques as "taking it personally."⁷ Making an unsafe learning environment is the fastest route to stigmatize the law profession away from diversifying. Law should never become homogenous in its practicing body as those requiring its services are vast and diverse in their cultural backgrounds and identities, requiring lawyers who share such diversity or can understand the critical distinctions.

Beyond the negative impacts of the empathy gap, scholarly research highlights the benefits and positive effects of empathy on a lawyer, legal thinking, and lawyer-client interaction. Empathy, at its core, requires people to regulate their emotions, understand the point of view of another person, and balance the two emotional states without blurring the lines. Empathy benefits communication between lawyers, who understand the complex law, and their clients, laypeople without the requisite training to understand the law on their own. Client satisfaction increases when lawyers demonstrate empathy in their communications. Additionally, empathy facilitates the development of vital lawyering skills in negotiation, mediation, and even litigation and benefits the profession overall when contributing to the professional or ethical standards of lawyering. Ultimately, more empathetic lawyers are better off than those who subscribe to a methodology of cynicism, standoffishness, and dissatisfaction in law school and post-graduation. ⁸ Cindy L. James, “Exploring Changes in the Emotional Intelligence of Law Students,” Legal Education Review 28, no. 1 (2018): 2 ⁹ James, “Exploring Changes in the Emotional Intelligence of Law Students.” 2 ¹⁰ Brett Williams, Adiva Sifris, and Marty Lynch, “A Psychometric Appraisal of the Jefferson Scale of Empathy Using Law Students,” Psychology Research and Behavior Management, July 1, 2016, https://doi.org/10.2147/prbm.s108036.

⁵ Gallacher, “Thinking Like Non-Lawyers: Why Empathy Is a Core Lawyering Skill and Why Legal Education Should Change to Reflect Its Importance.” 33-35 ⁶ The American Prospect, “The Law School Empathy Deficit.” ⁷ The American Prospect, “The Law School Empathy Deficit.”

Law schools, by design, are supposed to prepare students to be successful upon entry into the legal field. But, compared to the traditional fare of the classroom, schools need to introduce better education related to empathy, cultural compassion, and the interpersonal relationships between lawyers and their clients. A shift in the curriculum to benefit law students and their future clients should include empathy in the conversation on what it means to "think like a lawyer."

WORKS CITED: Gallacher, Ian. “Thinking Like Non-Lawyers: Why Empathy Is a Core Lawyering Skill and Why Legal Education Should Change to Reflect Its Importance.” Journal of the Association of Legal Writing Directors 8 (season-03 2011): 1–49. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1693146. James, Cindy L. “Exploring Changes in the Emotional Intelligence of Law Students.” Legal Education Review 28, no. 1 (2018): 1–18. Smith Ledesma, Stephanie. “Compassion: A Critical Skill for Law Students.” Marquette Benefits and Social Welfare Law Review 22, no. 2 Spring (2021): 181– 208. The American Prospect. “The Law School Empathy Deficit.” The American Prospect, November 17, 2011. https://prospect.org/article/law-school-empathydeficit./. ABA Law Practice Today. “The Power of Empathy | ABA Law Practice Today,” January 15, 2021. https://www.lawpracticetoday.org/article/the-power-ofempathy/. Williams, Brett, Adiva Sifris, and Marty Lynch. “A Psychometric Appraisal of the Jefferson Scale of Empathy Using Law Students.” Psychology Research and Behavior Management, July 1, 2016. https://doi.org/10.2147/prbm.s108036.

Whether we like it or not, we are perceived by others based on our interactions. This combination of multiple perceptions leads to a reputation. Understanding this, I remind myself that “my name is my name” during every interaction.¹ A lawyer’s reputation is associated with his name. Although it takes time and effort, fashioning a desirable reputation is achievable–and easier than legally changing your name.

Although most of us might not consider it, social media is an extension of our identities. The messages conveyed from these accounts are interpreted as direct reflections of our own views. Maintaining decorum is important to having a good reputation and an ill-used social media account can ruin a carefully built reputation. One solution would be to completely rid ourselves of these accounts. However, we live in the age of social media and this option may be unfeasible. To those people, I suggest adhering to strict scrutiny of the material they share because, like obscenity, people will know unprofessional content when they see it.²

A law student is to a lawyer as a caterpillar is to a butterfly. We begin building our reputation as a lawyer in law school. I understand that law school is stressful, and this might feel like an extra headache but following one simple rule may guarantee a great reputation, not just in law school but for the career that follows. The rule: treat every interaction with the same professionalism that you’d demonstrate during a job interview.

It is imperative to continue acting professionally regardless of the medium of interaction. Professionalism should become a part of your identity. Your professors, peers, employers, and coworkers will appreciate associating with a professional.

Professionalism constitutes a substantial aspect of a lawyer’s reputation. Even as law students, we must comply with a degree of professionalism. Oftentimes, this expectation of professionalism is implicit. By coming to law school, we have tacitly agreed to abide by this expectation. Therefore, if you are wondering when to act with professionalism, the answer is: always.

Although this op-ed aims to encourage all of you to be mindful of your professionalism during law school, I will throw in an extra incentive. Fully embracing professionalism as a part of your identity will allow you to become a more ethical lawyer. By being more ethical, you safeguard yourself from running afoul of the ABA Model Rules of Professional Conduct. Remember, a disgraced lawyer is the quintessence of unprofessionalism.

After all, we are attempting to be part of the legal profession and our conduct should comport with that degree of professionalism. Plus, having a reputation as a professional goes a long way. Clients prefer a lawyer who is professional because it fits their idea of what the profession symbolizes.

Learning how to be a professional can be difficult. Some of us have not been exposed to a professional environment prior to attending law school. Some of us suffer from imposter syndrome which further perpetuates that sense of inadequacy and lack of professionalism. However, I encourage you to embrace your peers and the bison family. Embrace one another as professionals and treat one another with the same respect and dignity as officers of the court do. Hold yourself to a higher standard and carry on the tradition of this noble profession. Although hard to define, professionalism is easy to practice!

Professionalism is developed throughout your law school career. You can perfect it during your daily law school tasks. For example, you can practice professionalism every time you write an email. This is a communication with another person and influences the recipient’s perception of you. Additionally, interacting with a fellow student can impact how a third party perceives you based on witnessing that interaction. That’s why you should always be mindful of and practice professionalism in the simplest communications. ¹ The Wire: Late Editions (HBO television broadcast March 2, 2008).

² See Jacobelis v. State of Ohio, 378 U.S. 184, 197 (1964) (Stewart, J., concurring).

A young woman ends a relationship, only to find that her now ex-boyfriend has created a fake profile on Yahoo with nude pictures of her that is viewable by anyone with an internet connection.¹ A man with a sterling reputation in his community finds false stories painting him as a pedophile and an abuser available to anyone doing a Google search of his name.² An innocent man’s phone number is posted in an advertisement for shirts praising a heinous terrorist act, making him the target of incessant death threats and harassment.³ Facebook’s algorithms recommend extremist content to impressionable young men, inspiring them to join a terrorist faction and carry out acts of violence toward unsuspecting victims.⁴ Meanwhile, Silicon Valley shrugged as courts gave tech companies who control the online platforms a free pass, proclaiming that the owners of the online platforms are immune in tort because of the specter of crushing liability. While tech giants like Google, Meta, and Twitter/X allow us to stay connected to our loved ones and to meet new people online, they have also been the medium for devastating conduct such as the incidents described above. These websites and apps, fueled by algorithms and user-friendly interfaces, entice people to participate in social media, but their creators are often protected from being held responsible when these online interactions go awry. Who should be held responsible for the emerging social and psychological injury social media is causing to its users? As potential plaintiffs are stalked, defamed, and have their intellectual property rights infringed online, who can we point the finger of culpability to when teams of engineers and executives hide behind algorithms, artificial intelligence, and First Amendment protections? Are the perils of deterring innovation through litigation outweighed by the necessity to compensate those injured by unprecedented means? Currently, Congress and the courts have decided that the tech industry is too important to the economy and should not be held vicariously liable for online tortious conduct, even though they have the exclusive right and control to regulate such conduct on their platforms.

¹ Barnes v. Yahoo!, Inc., 570 F.3d 1096 (9th Cir. 2009). ² Yousif, Nadine. “Google to Pay Canadian Businessman for Destructive Search Result.” BBC News, BBC, 20 Apr. 2023, https://www.bbc.com/news/world-us-canada-65340444. ³ Zeran v. Am. Online, Inc., 129 F.3d 327 (4th Cir. 1997). ⁴ Force v. Facebook, Inc., 934 F.3d 53, 56 (2d Cir. 2019).

The Communications Decency Act (CDA) was passed in 1996 as part of the Telecommunications Act of 1996. The CDA largely provides tort and criminal immunity for internet service providers and tech companies regarding the content proliferated on their websites emanating from their users. Section 230 of the CDA specifically protects tech companies from civil liability if they make a good-faith effort to remove or moderate third-party text, photos, videos, or other forms of communications they consider “obscene, lewd, lascivious, filthy, excessively violent, harassing, or otherwise objectionable, whether or not such material is constitutionally protected.”⁵ In effect, if a company can demonstrate that it has implemented even minimal procedures to curb the posting or spread of discriminatory, defamatory, or otherwise inappropriate content on its website, with some exceptions⁶, it may shield itself from tort liability by showing characteristics of a publisher and invoking Section 230. Section 230’s effect of largely eliminating liability for negligence claims for these internet companies has allowed them to reap massive profits. Meanwhile, the detrimental effects Instagram, Reddit, Twitter/X, Facebook, and other popular online services have on the masses are rearing their ugly head in the form of extremism, humiliation, stalking, invasion of privacy and, in rare instances, death. It is time to rein in these profiteers hiding behind Section 230 and their deflection of responsibility to algorithms. There are people running these services, benefiting from their use, and creating these algorithms and they must be held accountable for the damage they facilitate. There is no doubt that the internet has been positive for society in so many ways, but that doesn’t mean we can’t do more to mitigate the negative consequences this tech boom has burdened the masses with. Modifying Section 230 to impose a higher duty of care on these companies and mandating that they do more to minimize tortious behavior on their websites and apps is imperative in an era where seemingly everyone is living more and more online. As the public square is increasingly privatized and digitized, we can and must do better and hold those who have exclusive control of the public square accountable. Andres Navarro

⁵ 47 U.S.C. § 230. ⁶ Id. at § 230(e)(1) – (5). These clauses minimize the immunizing effect of the section for causes of action and criminal charges pertaining to the sexual exploitation of children, violation of sex trafficking laws, and for not doing enough to help intellectual property owners from enforcing their exclusive rights due to the proliferation of their protected work on the internet.

Sunrise

Who am I? I'm Raul, one of your fellow second-year peers. Currently, I wear multiple hats at our law school. I serve as a student advocate at the Community Lawyering Clinic, where I've had the privilege of working closely with clients and gaining invaluable practical experience. Additionally, I'm a research assistant for Professor Andrea Freeman, focusing on constitutional law—a role that has deepened my understanding of our legal system. Lastly, I'm an active member of the Southwestern Inn of Court, where I engage in meaningful discussions and networking within the legal community.

Why Include a Narration? I include a narration because I made this comic by hand and could not fit the complete story in snippets like some comics do. The narration tells the story and describes much of the metaphors. The snippets are like a supplement of detail for the fiction-story and facts of people who face similar situations.

I grew up in Oxnard, California, a community often overshadowed by unrealized dreams. Growing up there has profoundly shaped my personal journey and my aspirations as a legal professional.

Assumption of Empowerment; Objective; Origin Generally, and if feminism’s fundamental quest is equality, the comic is an insight to the emergence of feminist art manifested in the wake of traumatic experiences. I use metaphors of trauma analyzing visual manifestations of anguish, persistence, and reckoning that populate and coalesce within my comic, a fictitious narrative taken from the many voices of my lived reality as a resident of Oxnard, California.

The roots of my personal history have driven my academic and professional achievements, fostering an unwavering commitment to my origins. My mission is clear: to amplify the voices of my community and champion human rights through legal advocacy. Pursuing my path, I aspire to leverage my experience for a judgeship that objectively applies the law considering individuals' lived realities.

Character Jose Luis is the main character expressing voices of Oxnard and reflective of other voices across the USA.

Narration of Comic My comic is titled “ include a metaphor.

🍓 xnard USA: The Ordinary Life of a Latinx” that I prepared with much thought to

In the word Oxnard I use a strawberry instead of an O to reflect the limited employment options for certain groups of people. Take a guess on the identity of the group? Wait. Hold that thought. I chose to include the acronym “USA” because when I wrote this story, the USA made me feel a sense of the American Dream, whatever that means. More importantly, I used “USA” because I assume that this story is evident across the states. I used the word “Ordinary” because ordinary humans suffer when they discover they are deemed “Aliens”, whatever that means. In reality, they are actually human beings, raised their whole lives and learn their reality in missing legal status documentation. Furthermore, the word “Ordinary” works in tandem with Jose Luis, the main character, because his name is just as common a name as what occurs to people like Jose Luis.

On the cover, I tried to give a preview of the environment, a strawberry field in Oxnard, CA that surrounds Jose Luis. Oxnard is known for a specific form of labor that undocumented families participate in: planting, picking, and packaging fruits and vegetables for the consumption of “legal” consumers.

In 2006, Jose Luis, an ordinary child, was brought illegally into this country at the age of three. This is my interpretation of how it looks. His parents made the courageous act of navigating the unbearable terrain in search of opportunity. You can see joy in this family portrait taken once they settled in the states.

Jose’s parents made it across the border with their children and begin their new life in Oxnard where they work the fields. They enjoy their new life despite the enormous workload, and the presence of overt violence. The strawberry is meant to reflect that possibility since the crop has offered an opportunity in honest work. I drew the “Yes We Can” political slogan because in Spanish it stands for “Si se puede”, which is a political slogan used throughout Mexican culture to strike hope on a given matter. The United Farm Workers movement, for example, used it to demand economic and social justice during the civil rights movement. The slogan was also used during the 2008 and 2012 Obama presidential campaigns, “Yes We Can!” It mobilized millions of Latinx voters and it was thus the symbolic slogan of change. Was there other intentions behind the use of the slogan? Wait, hold the thought. This traffic stop I drew is meant to foreshadow Jose’s violent experience. Jose’s father received a traffic ticket for having no license when driving home from work. The Officer cut him a break by not towing his vehicle. However, it turned into something much more devastating.

ICE had developed a deportation case against his father after the traffic violation. I drew this ICE agent to reflect what the father saw when he opened the door. Could you imagine what flashes of thoughts and emotions Jose’s father felt? Does a human, wait, pardon me, that’s politically incorrect. Is an Alien deserving of militarized style apprehension? It’s okay, no need to think about it, many don’t.

I drew this couch, slightly shaded because that’s where Jose sat as a witness to an event that forever changed him: watching his father viciously get taken away while his family sat on the couch.

The emotional damage of that arrest was detrimental to Jose’s physical and mental health. Sitting on that couch is something he has never forgotten. Notice how the couch here is shaded a little darker, it’s a reflection of his emotions. This happened to Jose in 2012 and it is why I drew these images. This image of a slogan from Obama’s campaign for reelection in the top left says “2012, Yes We Can, Again.” Underneath I respond with the drawing of my own real version of the Political campaign slogans underlying agenda in “Yes, It Happened, 419,384 humans were deported and separated- the most in US history.” I also drew an example of a warrant for deportation in which I added certain types of names. Can you take an informed guess of what group it reflects and why? Let’s think to ourselves a little and answer it in our minds. But wait you don’t have to; many don’t give it the time of day. As a result, in center, you see Jose, as a child, in a depressed state constantly reliving the moment he saw his father taken away.

That same anguish persisted into his teenage years, which is why I drew him sitting at his desk at school with hopelessness and thirst to reunite with his father, his mentor, his guidance, his role model. His teens were also filled with labor to support his family, depicted by this middle drawing. Here, in the top left corner of you can see the letters M,T,W,T,F,S,S to indicate what he does most of the week. Labor as a teen is never ending in his shoes. Labor is survival, shelter, and food for him. Nevertheless, Jose is expected to graduate high school. He, not surprisingly, ends up graduating with very poor grades, see the report card on the left. What class marks the highest grade? Interesting huh? How did he graduate with poor grades? Jose strikes a deal to graduate using work hours as credits. “All that matters is that he graduates,” they say.

After high school Jose discovers that he cannot get a job outside the family janitorial business. Why? He learns that he’s undocumented. Wait, wait, pardon me, that is politically incorrect. He discovers that he is an Alien. So, I drew him with hands holding his head in anguish and hate for his status. Notice how I shaded him brown and used the same brown for the sole of his shoes. That is because I convey his feelings as worthless, similar to the dirt on his shoes. His dreams to reunite with his father are shattered, the sentiment expressed by these broken alcohol bottles. The one on the right is shattered and the pieces reflect his tears. Jose takes it out on himself by chronically drinking. He has never felt so powerless. He thinks he could be picked up by ICE when he least expects it, meeting the same fate as his father, and leaving his siblings behind. Also broken are the never realized dreams that young people like himself aspire to: going to college, experiencing dorm or Greek life. Nor can he aspire to be an engineer or fly as a pilot. But Jose never even HAD the ordinary opportunity to make these dreams. All that Jose dreamed of was the ability to work, save some money to fly and reunite with his father. See how the couch is shaded darker. It’s meant to mark persistent anguish and fear of deportation. Ultimately, he feels broken, lost, and confused about the direction of this fate.

Jose ends up working the strawberry fields. But look–-they’re the same fields his father worked, they’re not colorful. It’s a reflection of his trauma bottled in over the course of his life. Never being able to speak about his situation for fear of being separated from his family. At this point, his life is black and white since he has learned to drown his sorrows, making his life feel mundane. It is there where Jose met Esperanza, a young fellow picker who was also a fulltime community college student. She struck hope into Jose Luis when she often encouraged him that it is possible to do both, “¡Si se Puede!” The colors here are meant to express hope and recourse.

Jose signs up for college and does not perform well. A visit to his counselor was due because he was being placed on academic probation. Here, I drew DACA posters to highlight that Counselor Martinez is aware. His counselor heard his story and pointed Jose in the right direction for relief. He became a DACA recipient and gained a work permit and now works at the front desk of student services and is a full-time student majoring in sociology and anthropology with aspirations to become an immigration lawyer. The facts on DACA are listed: improved psychological well-being, declines in levels of distress, negative emotions, and fear of deportation.

Here, Jose is now expressing his newfound peace of mind and hope. His facial expression is meant to show that relief while simultaneously not letting his guard down. Jose’s story is ultimately about hope and courage--to find a path to a better future. He returns to education thanks to Esperanza, whose name in English translates to hope. Jose finds peace of mind by becoming a DACA recipient with help of his counselor and is now working towards changing the narrative affixed to people of his status. Notably, DACA does not provide a pathway to U.S. citizenship. DACA recipients are not U.S. citizens nor are they lawful permanent residents. It is temporary relief renewable every two years. On September 13, 2023, a Federal District Court in Texas issued a ruling in Texas v. United States declaring DACA unlawful once again. The holding creates new questions and confusion felt by recipients and potential recipients of DACA. For the time being, current DACA recipients can continue to renew, but applications for new enrollees are at a halt.

Across 1 Spanish “I love” 4 Assc. 7 MinuteClinic chain 10 Give up 12 Convicted murderer Jodi 14 Polite title 15 Colors 16 ___-Dixon line 17 Maladies 18 Body of the crime, latin (or a French goth band) 21 Earnings 22 Little troublemaker 25 Slangy OK 26 Circus performers 29 Cease living 30 The place in which, latin 34 ___ alia 37 MTV music video countdown show 38 Taqueria option 39 Cookie sellers in green 42 Scrooge cry 43 "This Old House" contractor Tom 44 Rule, for short 46 ___ START (Tobias's oftmisinterpreted license plate on "Arrested Development") 47 By the fact itself, latin 51 Manner of operation, latin 55 Future atty's exam 57 Audibly 58 Greek Pan, e.g. 59 Ernie's pal 60 A kilo of water, in England. 61 Align 62 A right, power, or authority, latin 63 Dec. 31 64 Neptune's realm

Down 1 "Back in Black" rockers 2 Spanish month 3 Kaput 4 Yearbook feat. 5 Step part 6 Sao ___, Brazil

7 Left Coast state, informally (read: incorrectly) 8 Batman after Michael 9 Text, briefly 11 Armchair athlete's channel 12 River painted by Rembrandt 13 Detects as Dalmatians do 14 Hand warmers 19 180° turn, slangily 20 Tiny hairs 22 Hippie's "Got it!" 23 Small versions 24 Lab dish 27 Jordan's only seaport 28 Darfur's nation 31 Grand ___ (wine phrase) 32 Super fresh 33 Honolulu's island 35 Rapper Missy or Singer Smith

36 Answered an e-vite 40 Like some Friday work attire 41 Break off 45 Nissan sportscar 48 K.T. who sang "80's Ladies" 49 Australian rules game 50 Fools 51 The Red Planet 52 Anti votes 53 Herbert classic 54 Early Peruvian 55 JFK's veep 56 Brazilian singer ___ Jorge

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