Jones v. Illinois Central Railroad Company et al
Filing
52
ORDER & REASONS denying 38 Motion for Summary Judgment. Signed by Judge Lance M Africk on 10/7/2015. (mmm)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
DAVID E. JONES
CIVIL ACTION
VERSUS
No. 15-635
ILLINOIS CENTRAL RAILROAD COMPANY
ET AL.
SECTION I
ORDER AND REASONS
The remaining defendant, Illinois Central Railroad Company (“Illinois Central”), has
filed a motion 1 for partial summary judgment as to Count II of plaintiff’s two-count complaint.2
Illinois Central seeks summary judgment with respect to plaintiff, David Jones’ (“Jones”), claim
that Illinois Central violated subsection 20109(c)(1) of the Federal Railroad Safety Act
(“FRSA”). Illinois Central contends that the nature of Jones’ injury does not entitle Jones to the
protection of the FRSA. Illinois Central is not at this time seeking summary judgment with
respect to Count I of Jones’ complaint which asserts a claim pursuant to the Federal Employers
Liability Act, 45 U.S.C. § 51, et seq. (“FELA”). 3
For the reasons below, Illinois Central’s motion is DENIED.
The Court instead
concludes that Jones’ injury brings him within the scope of the FRSA’s protection. The Court
notes that it does not decide whether Illinois Central’s actions violated the FRSA, but only that
Jones does state a claim pursuant to that Act.
1
R. Doc. No. 38. Defendants, Andrea Davis and Ben Shannon, were also parties to the motion
for summary judgment, but they have been dismissed from the case. See R. Doc. Nos. 43, 44.
2
R. Doc. No. 28.
3
R. Doc. No. 38-3, at 2.
BACKGROUND
There is no dispute regarding the facts that are material to the Court’s resolution of this
motion. 4 Illinois Central is an interstate railroad carrier covered by the FRSA, 49 U.S.C. §
20109. Jones was employed by Illinois Central as a conductor. In late 2009 or early 2010, Jones
was diagnosed for the first time with high blood pressure. His physician told him that his
condition was probably hereditary.
On February 2, 2014, Jones was scheduled to start work at 5:00 or 5:30 PM. When he
arrived at work that day, he felt capable of doing his job and he did not tell anyone that he should
not be working. Jones worked the first hour or two of his shift without incident, and then began
to experience a headache. He took a break on the locomotive and he then resumed working.
After continuing work for a time, Jones returned to the engine and told the locomotive
engineer with whom he was working that he needed to take another break because his head was
hurting. At that time, Jones did not attribute his headache to any problem with his blood
pressure. He just knew that he had a headache. It is at this point that Jones’ and Illinois
Central’s versions of the events begin to diverge.
For the purpose of evaluating this motion, the evidence of Jones—the nonmovant—is to
be believed and all justifiable inferences are to be drawn in his favor. Tolan v. Cotton, 134 S. Ct.
1861, 1863 (2014) (citation omitted). Jones contends that another conductor employed by
Illinois Central saw the condition Jones was in at 9:15 PM and told Illinois Central’s yardmaster
on duty, Ben Shannon, to call an ambulance. 5 Jones also claims that Illinois Central’s assistant
trainmaster on duty, Andrea Davis, directed Shannon to call an ambulance for Jones if Shannon
4
These facts, which Jones does not contest, R. Doc. No. 45-1, at 1, were provided by Illinois
Central in its statement of material facts in support of its motion. R. Doc. No. 38-2, at 1–3.
5
R. Doc. No. 45-1, at 2.
2
thought it was necessary. 6 Jones asserts that despite these warnings, no ambulance was ever
called. 7
Ultimately, Jones was driven to the hospital. 8 Jones alleges that he suffered significant
brain damage and that he is now unable to work 9 Jones claims that Illinois Central’s delay in
obtaining medical treatment for him “caused, or at the very least, worsened [his] brain
hemorrhage and resulting brain damage.” 10
LAW AND ANALYSIS
I.
LEGAL STANDARD
Summary judgment is proper when, after reviewing the pleadings, the discovery and
disclosure materials on file, and any affidavits, the court determines there is no genuine issue of
material fact. See Fed. R. Civ. P. 56. “[A] party seeking summary judgment always bears the
initial responsibility of informing the district court of the basis for its motion and identifying
those portions of [the record] which it believes demonstrate the absence of a genuine issue of
material fact.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The party seeking summary
judgment need not produce evidence negating the existence of material fact, but need only point
out the absence of evidence supporting the other party's case. Id.; Fontenot v. Upjohn Co., 780
F.2d 1190, 1195 (5th Cir. 1986).
Once the party seeking summary judgment carries its burden pursuant to Rule 56, the
nonmoving party must come forward with specific facts showing that there is a genuine issue of
material fact for trial. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587
(1986). The showing of a genuine issue is not satisfied by creating “‘some metaphysical doubt
6
R. Doc. No. 45-1, at 3.
R. Doc. No. 28, ¶ 19.
8
R. Doc. No. 28, ¶¶ 22–23.
9
R. Doc. No. 28, ¶ 24.
10
R. Doc. No. 45-1, at 4.
7
3
as to the material facts,’ by ‘conclusory allegations,’ by ‘unsubstantiated assertions,’ or by only a
‘scintilla’ of evidence.” Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994) (citations
omitted). Instead, a genuine issue of material fact exists when the “evidence is such that a
reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby,
Inc., 477 U.S. 242, 248 (1986). The party responding to the motion for summary judgment may
not rest upon the pleadings, but must identify specific facts that establish a genuine issue. Id.
The nonmoving party's evidence, however, “is to be believed, and all justifiable inferences are to
be drawn in [the nonmoving party's] favor.” Id. at 255; see also Hunt v. Cromartie, 526 U.S.
541, 552 (1999).
II.
ANALYSIS
Jones asserts in Count II of his amended complaint that Illinois Central violated section
20109 of the FRSA, in whole or in part, “by failing to provide immediate and prompt medical
attention to [Jones] when it was clear that such medical attention was urgently needed
considering [Jones’] deteriorating condition, which was known and witnessed by [Illinois
Central].” 11 The applicable subsection of the statute is subsection (c)(1), which provides as
follows:
(c) Prompt medical attention.—
(1) Prohibition. -- A railroad carrier or person covered under this section may not
deny, delay, or interfere with the medical or first aid treatment of an employee
who is injured during the course of employment. If transportation to a hospital
is requested by an employee who is injured during the course of employment,
the railroad shall promptly arrange to have the injured employee transported
to the nearest hospital where the employee can receive safe and appropriate
medical care.
49 U.S.C. § 20109(c)(1) (emphasis added).
11
R. Doc. No. 28, ¶ 27.
4
By its plain terms, subsection (c)(1) applies only to employees who are “injured during
the course of employment.” The outcome of this motion turns on whether Jones meets that
description. Illinois Central argues that Jones is not protected by subsection (c)(1) because in
order to be “injured during the course of employment” an employee must suffer a work-related
injury, which does not include the manifestation of a pre-existing condition. 12 Jones asserts that
the statute only imposes a temporal requirement of suffering an injury while at work. 13
A. There is no genuine issue of material fact with respect to this legal question.
Although Jones asserts that there are fact disputes precluding resolution of this motion,
such disputes are not material to the issue of statutory interpretation raised by Illinois Central.
Even assuming that Jones is correct that Illinois Central refused to call an ambulance for Jones
and that the delay “contributed substantially” to Jones’ ultimate injury, 14 there is no genuine
issue of material fact before the Court. An employee must first be “injured during the course of
employment” for an employer to owe a duty not to “deny, delay, or interfere with [the
employee’s] medical or first aid treatment.” 49 U.S.C. § 20109(c)(1).
Jones admits that his “brain hemorrhage was triggered by high blood pressure” and that
his “hypertension is not ‘work-related.’” 15 Accordingly, Jones concedes that, even if it was later
aggravated by Illinois Central’s lack of response, his injury was triggered by the manifestation of
a pre-existing condition while he was at work. Whether an injury, triggered while an employee
is at work but not caused by the employee’s work, can be considered an injury sustained “during
12
R. Doc. Nos. 38-3, 38-4.
R. Doc. No. 45, at 2–3. Jones also asserts that genuine issues of material fact prevent the
Court from resolving this dispute at the summary judgment stage. R. Doc. No. 45, at 14.
14
R. Doc. No. 45, at 3.
15
R. Doc. No. 45, at 2. The Court does not imply that Jones concedes that his injury was not
“work-related” in the legal sense, but rather only that Jones has admitted that the factor that
triggered his brain hemorrhage—his hypertension—was not caused by work.
13
5
the course of employment” is precisely the question of law Illinois Central asks this Court to
resolve. There is, therefore, no genuine dispute regarding a fact material to the Court’s inquiry.
B. The manifestation of Jones’ pre-existing condition while Jones was at work
constitutes an injury “during the course of employment” within the meaning of
subsection (c)(1).
a. The Court is unaware of any cases directly addressing this issue.
The parties have not cited, and the Court’s own research has not revealed, any cases
directly addressing this issue.
Illinois Central claims that the U.S. Third Circuit Court of
Appeals decision in Port Authority Trans-Hudson Corp. v. Dep’t of Labor, 776 F.3d 157 (3d Cir.
2015) (“PATH v. DOL”) supports its interpretation. 16 But that case does not address the question
before the Court.
In PATH v. DOL, the Third Circuit addressed subsection 20109(c)(2) of the FRSA—the
provision adjacent to the subsection at issue in this case. 776 F.3d 157. Subsection (c)(2)
prohibits a railroad carrier from disciplining an employee “for following orders or a treatment
plan of a treating physician.” 17 49 U.S.C. § 20109(c)(2). Unlike subsection (c)(1) of the FRSA,
however, subsection (c)(2) does not explicitly limit its protections to treatment plans for injuries
16
17
R. Doc. No. 38-3, at 5–6.
49 U.S.C. § 20109(c)(2) provides in its entirety:
(c) Prompt medical attention.—
(2) Discipline.-- A railroad carrier or person covered under this section may not
discipline, or threaten discipline to, an employee for requesting medical or first
aid treatment, or for following orders or a treatment plan of a treating physician,
except that a railroad carrier's refusal to permit an employee to return to work
following medical treatment shall not be considered a violation of this section if
the refusal is pursuant to Federal Railroad Administration medical standards for
fitness of duty or, if there are no pertinent Federal Railroad Administration
standards, a carrier's medical standards for fitness for duty. For purposes of this
paragraph, the term “discipline” means to bring charges against a person in a
disciplinary proceeding, suspend, terminate, place on probation, or make note of
reprimand on an employee's record.
6
sustained “during the course of employment.” The issue before the Third Circuit in PATH v.
DOL was whether the “treatment” referred to in subsection (c)(2) refers back to the “treatment”
in subsection (c)(1), thereby incorporating the “during the course of employment” limitation into
subsection (c)(2). PATH v. DOL, 776 F.3d at 162.
The Third Circuit concluded that subsection (c)(2) applies only to orders or treatment
plans related to injuries that, as in subsection (c)(1), are sustained “during the course of
employment.” Id. The Third Circuit therefore rejected the plaintiff’s argument that subsection
(c)(2) prevented his employer from disciplining him for following a treatment plan that stemmed
from an off-duty injury. Id. at 159. Throughout its opinion, the Third Circuit refers to the
requirement that an injury occur “during the course of employment” as a requirement that the
injury be obtained “on-duty” or that it be “work-related.” Id. at 159, 162, 163, 165, 166, 168,
169. Illinois Central cites these references as authority for its position that the injury must be
caused by work in order to fall within the scope of subsection (c)(1). 18 But Illinois Central’s
reliance on this phraseology is misplaced.
The Third Circuit nowhere indicated that an “on-duty injury” or “work-related injury”
meant anything more than that the injury must have occurred while the plaintiff was working.19
The injury in PATH v. DOL took place in the plaintiff’s home while he was moving boxes. 776
F.3d at 159. Accordingly, there was no need for the Third Circuit to decide whether an injury
18
See generally R. Doc. No. 38-3.
Although the Third Circuit seemingly uses the phrases “on-duty injury” and “work-related
injury” interchangeably in its opinion, it may be possible that an injury occurs “during the course
of employment” either if it occurred “on duty” or was “work-related” in the sense that it was
caused by work. The Third Circuit did not consider this possible distinction because it did not
need to; the injury in PATH v. DOL clearly did not occur while the plaintiff was “on duty” and it
was not “work-related.” In this case, the Court simply decides that an injury occurring while an
employee is on duty is sufficient to bring that employee within the scope of subsection (c)(1)’s
protection. This Court does not decide whether an injury that occurs off duty but that is caused
by work renders an employer potentially liable pursuant to subsection (c)(1).
19
7
occurring at work must also be caused by work in order to resolve the issue before it, as the
plaintiff’s injury in that case did not occur “during the course of employment” under either
interpretation offered by the parties in this case. It is worth noting, however, that at one point the
Third Circuit actually refers to the prerequisite for protection under subsection (c)(1) as a
“temporal limitation.” Id. at 162. PATH v. DOL is at least as supportive of Jones’ position as it
is of Illinois Central’s, if not more so.
b. The plain meaning of the statute supports Jones’ interpretation.
In the absence of binding or persuasive authority, the Court turns first to the language of
the statute itself in order to resolve its meaning. The U.S. Supreme Court has explained that of
all the canons of construction employed by courts to interpret statutes, giving the statute its plain
meaning is the “cardinal canon before all others.” Connecticut Nat. Bank v. Germain, 503 U.S.
249, 253 (1992). The reason is “that courts must presume that a legislature says in a statute what
it means and means in a statute what it says.” Id. at 253–54 (citations omitted). “When the
words of a statute are unambiguous, then, this first canon is also the last: judicial inquiry is
complete.” Id. at 254 (citations and internal quotations omitted). In determining whether the
words of a statute are unambiguous, courts look to “the language itself, the specific context in
which that language is used, and the broader context of the statute as a whole.” Robinson v.
Shell Oil Co., 519 U.S. 337, 341 (1997) (citations omitted).
Subsection (c)(1) states that “[a] railroad carrier . . . may not deny, delay, or interfere
with the medical or first aid treatment of an employee who is injured during the course of
employment.” (emphasis added). The Court holds that this language unambiguously covers
employees who suffer injury while on duty at their place of employment, irrespective of the
injury’s cause. This interpretation accords the statute its plain meaning by construing the term
“during” in its ordinary sense as a temporal requirement. The Court’s view is supported by the
8
dictionary definition of the term “during,” which is defined as “throughout the entire term of”
and “at some time in the course of.”
Merriam—Webster’s Online Dictionary,
http://www.merriam-webster.com/dictionary/during (last visited October 7, 2015).
These
definitions buttress Jones’ contention that the statute intends “during the course of employment”
to create only a time-based requirement that the injury occur “at some time in the course of
employment.”
If this Court were to decide, as Illinois Central urges, that the statute excludes injuries
occurring during the course of employment that are not caused by the course of employment, an
additional burden would be placed on plaintiffs that is not justified by the text of the statute
itself. If Congress had intended that the FRSA cover only some employees “injured during the
course of employment” but not others, surely it would have said so. Absent such an express
limitation, the Court finds it inappropriate to conclude that Congress meant what it did not state.
Because the language of the statute is clear, references to legislative history and
regulatory purpose are unnecessary to determine its meaning; “judicial inquiry is complete.”
Connecticut Nat. Bank, 503 U.S. at 254. Nevertheless, the legislative history and regulatory
purpose of subsection (c)(1) support the Court’s interpretation, and provide an alternative basis
for the Court’s holding.
c. The regulatory purpose of subsection (c)(1), as evidenced by the legislative
history, also supports Jones’ interpretation.
“Even though . . . the words used . . . are the primary, and ordinarily the most reliable,
source of interpreting the meaning of any writing, nevertheless it is one of the surest indexes of a
mature and developed jurisprudence not to make a fortress out of the dictionary; but to remember
that statutes always have some purpose or object to accomplish.” Pub. Citizen v. U.S. Dep’t of
Justice, 491 U.S. 440, 454–55 (1989) (internal quotations and citations omitted). The U.S. Fifth
9
Circuit Court of Appeals has explained that “[i]n determining the meaning of [a] statute, [courts]
look not only to the particular statutory language, but to the design of the statute as a whole and
to its object and policy.” CleanCOALition v. TXU Power, 536 F.3d 469, 473 (5th Cir. 2008).
Illinois Central claims that “the legislative history of section 20109(c) . . . confirms that
Congress intended this section of the FRSA to protect workers who seek medical attention for
work-related injuries.” 20 Because Illinois Central does not consider the manifestation of a preexisting condition while an employee is on-duty to be a “work-related injury,” it argues that to
include such injuries within the protection of subsection (c)(1) conflicts with or exceeds the
purpose of the FRSA. 21 Although Illinois Central is generally correct in its view of the purpose
of section 20109(c), it is incorrect that the Court’s interpretation of subsection (c)(1) conflicts
with that purpose. To the contrary, the goals of subsection (c)(1) could not be achieved without
extending protection to injuries like those allegedly suffered by plaintiff.
The Administrative Review Board (“ARB”), the agency to which the U.S. Secretary of
Labor has delegated authority to review appeals of decisions by administrative law judges under
the FRSA, 22 summarized the pertinent legislative history regarding section 20109(c) in Santiago
v. Metro-North Commuter R.R. Co., Inc., ARB Case No. 10-147; 2012 WL 3255136 (July 25,
2012).
In Santiago, the ARB recounted as follows:
A series of hearings in the 110th Congress signaled increasing public and
Congressional concern with rail safety, including chronic under-reporting of rail
injuries, widespread harassment of employees reporting work-related injuries, and
interference with medical treatment of injured employees. In particular, . . .
20
R. Doc. No. 38-3, at 8.
R. Doc. No. 48-1, at 4.
22
The U.S. Secretary of Labor has jurisdiction over an FRSA complaint pursuant to 49 U.S.C. §
20109(d)(1). The Secretary delegated that authority in Secretary's Order No. 1-2010 (Delegation
of Authority and Assignment of Responsibility to the Administrative Review Board), 75 Fed.
Reg. 3924, § 5(c)(15) (Jan. 15, 2010).
21
10
testimony before Congress identified numerous management policies that deterred
employees from reporting on-the-job injuries including subjecting employees who
report injuries to increased monitoring and scrutiny from supervisors, which could
lead to discipline and termination, supervisors accompanying employees on their
medical appointments and attempting to influence employee medical care,
sending employees to company physicians instead of physicians of their own
choosing, and light-duty work programs, which have the injured employee report
to work, but perform no work, to avoid having to report the injury as a lost work
day to the Federal Railroad Administration.
Santiago, 2012 WL 3255136, at *8 (citations omitted).
As a result of these findings, Congress amended the FRSA by enacting the Rail Safety
Improvement Act of 2008 (“RSIA”). Pub. L. No. 110–432, 122 Stat. 4848 (October 16, 2008).
Prior to the amendment, section 20109 “was exclusively an anti-retaliation provision.” PATH v.
DOL, 776 F.3d at 161. Subsections (a) and (b) of section 20109, which have been in effect since
before the amendment, provide “protections to employees who assist in investigations into
railroad safety, refuse to violate laws pertaining to railroad safety, notify a railroad or the
Secretary of Transportation about ‘work-related’ injuries or illnesses, and report and/or refuse to
work in hazardous conditions.” Id. The RSIA added inter alia subsection (c) to section 20109.
Pub. L. No. 110–432.
Subsection (c)(2)—like subsections (a) and (b)—is an “anti-retaliation provision” aimed
at deterring rail carriers from disciplining employees for, among other things, “following orders
or a treatment plan of a treating physician.” 49 U.S.C. § 20109(c)(2). Subsection (c)(1),
however, is a “substantive provision” whose “primary objective is to ensure that railroad
employees are able to obtain medical attention for injuries sustained on-duty.” PATH v. DOL,
776 F.3d at 163. Accordingly, while subsection (c)(1) may have some anti-retaliatory function,
its primary purpose is remedial in nature. Because the U.S. Supreme Court has stated that
“safety legislation is to be liberally construed to effectuate the congressional purpose,” Whirlpool
11
Corp. v. Marshall, 445 U.S. 1, 13 (1980), the remedial purpose of subsection (c)(1) weighs in
favor of a more liberal construction.
But to the extent that subsection (c)(1) does have a secondary objective as an antiretaliation statute, the Court’s interpretation of the subsection supports that objective. The
reporting requirements promulgated by the Federal Railroad Administration (“FRA”) dictate that
rail employers report any new case involving an employee’s “death, injury or occupational
illness . . . if an event or exposure arising from the operation of a railroad is a discernable cause
of the resulting condition or a discernable cause of a significant aggravation to a pre-existing
injury or illness.” 23
49 C.F.R. § 225.19(d) (emphasis added).
Because the reporting
requirements expressly exclude any “injury or illness [that] involves signs or symptoms that
surface at work but result from a non-work related event or exposure that occurs outside the
work environment,” 49 C.F.R. § 225.15(c)(1) (emphasis added), Illinois Central argues that the
Court’s view of subsection (c)(1) will require employers to react to injuries that occur at work
but are not reportable to the FRA. 24 In Illinois Central’s view, such a requirement does not
advance subsection (c)(1)’s purpose of combating the “various actions taken by railroad carriers
to discourage employees from reporting work-related-injuries [sic].” 25
To the extent Illinois Central is correct that the goal of subsection (c)(1) is to prevent
railroad carriers from retaliating against employees who sustain injuries that might be
reportable, 26 Congress must have recognized that the incentive for an employer to discourage
treatment is present any time an employee is injured while at work. After all, the cause of an on23
R. Doc. No. 48-1, at 3.
R. Doc. No. 48-1, at 3.
25
R. Doc. No. 48-1, at 3.
26
As the Court previously noted, deterrence is not the primary objective of subsection (c)(1).
Rather, as a substantive provision, the goal of subsection (c)(1) is chiefly remedial. PATH v.
DOL, 776 F.3d at 163.
24
12
duty injury is often unclear. An employee can have a heart attack, for example, and it may not
become evident until much later whether the attack was brought on by work-related stress or a
pre-existing condition. Because the employer often will not immediately know whether a given
injury will ultimately be reportable, prohibiting interference with medical care for all injuries
would promote the deterrent effect.
Illinois Central also argues that interpreting subsection (c)(1) to apply to injuries during,
but not caused by, work trespasses on the domain of the FELA, which the Fifth Circuit has
explained “provides the exclusive remedy for a railroad employee engaged in interstate
commerce whose injury resulted from the negligence of the railroad.” 27 Rivera v. Union Pac. R.
Co., 378 F.3d 502, 507 (5th Cir. 2004) (emphasis added). But this is a problem for Illinois
Central’s proposed interpretation as well, because to the extent overlap occurs, it cannot be
avoided by either interpretation of the statute. Both Illinois Central’s and Jones’ interpretations
of subsection (c)(1) render a rail carrier potentially liable under FELA and the FRSA for
delaying or discouraging treatment of at least some on-the-job injuries. See Santiago, 2012 WL
3255136, at *12 (recognizing that “there can be overlapping remedies common to both [FELA
and FRSA claims]” such that “an employee who files a whistleblower complaint under the FRSA
can also file a negligence claim under the FELA”).
Furthermore, unlike in a FELA action, a violation of section 20109 of the FRSA is
punishable by punitive damages of up to $250,000 dollars.
49 U.S.C. § 20109(e)(3).
Accordingly, limiting those in Jones’ position to a FELA claim insulates employers from the
deterrent effect of punitive damages in circumstances where, as the Court has already explained,
employers may be equally incentivized to discourage employees from receiving treatment. Such
27
R. Doc. No. 38-3, at 2.
13
an interpretation of subsection (c)(1) cannot be what Congress intended. Accordingly, the
regulatory purpose of subsection (c)(1) provides an alternative basis for the Court’s holding.
CONCLUSION
The Court concludes that Jones’ injury, which admittedly was initially brought on as the
result of the manifestation of a pre-existing condition during the course of his employment, does
entitle Jones to the protection of subsection 20109(c)(1) of the FRSA. This interpretation is
compelled not only by the plain meaning of the statute, but also by the legislative history and
regulatory purpose behind subsection 20109(c)(1). Accordingly,
IT IS ORDERED that Illinois Central’s motion for summary judgment with respect to
Count II of Jones’ amended complaint is DENIED.
New Orleans, Louisiana, October 7, 2015.
_______________________________________
LANCE M. AFRICK
UNITED STATES DISTRICT JUDGE
14
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