The Supreme Court Takes on LGBTQ Rights and Abortion Rights

The Supreme Court is officially back in session, which means that cases on LGBTQ+ rights and reproductive rights will come before the bench. Katelyn Burns, a freelance journalist covering LGBTQ and reproductive health issues and the first openly transgender reporter on Capitol Hill joins us to talk about the LGBTQ+ cases that the Supreme Court has already heard this term, and the reproductive rights cases that will be presented before them in the spring.

This fall, the Supreme Court has heard three critical LGBT cases. Two of the cases (Altitude Express Inc. v. Zarda and Bostock v. Clayton County) were combined and focused primarily on LGB rights, and these cases questioned whether or not it was legal for an employer to fire someone for their sexual orientation. The second case posed the same question explicitly for transgender individuals (R.G. & G.R. Harris Funeral Homes v. EEOC). Ultimately, the argument is whether or not Title VII of the Civil Rights Act of 1964 applies to LGBT people. R.G. & G.R. Harris Funeral Homes v. EEOC began under the Obama administration, but since the implementation of the trump administration, the White House has attempted to coerce EEOC (Equal Employment Opportunity Commission) into dropping the case. 23 states have a hodgepodge of state-level protections that protect LGBT people in their places of work, but there is no explicit federal law for employment protections of LGBT people. If both of these cases lost, it would likely galvanize a grassroots campaign to pressure Congress into passing the Equality Act.

The Supreme Court is also slated to hear June Medical Services v. Gee, which is a case based out of Louisiana. The law would require abortion clinics’ doctors to have admitting privileges at nearby hospitals. It falls into a category of regulations called TRAP laws which are targeted regulations of abortion provider beyond what is needed to ensure patient safety. TRAP laws are designed to force clinics to close. The case is very similar to Whole Women’s Health v. Hellerstedt, which was struck down by the Supreme Court, set the precedent that the case was an undue burden to those seeking abortion. Justice Brett Kavanaugh wrote a dissent to Whole Women’s Health v. Hellerstedt, which signals how he plans to vote on June Medical Services v. Gee.

Links from this episode

Katelyn Burns on Twitter
Population Institute’s 50-State Report Card
Information on the Equality Act

Transcript

Jennie: Welcome to Repros Fight Back a podcast on all things repro. I'm your host, Jennie Wetter, and each episode I'll be taking you to the front lines of the escalating fight over our sexual and reproductive health and rights at home and abroad. Each episode I'll be speaking with leaders who are fighting to protect our reproductive health and rights to ensure that no one's reproductive health depends on where they live. It's time for repros to fight back.

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Jennie: Hi everybody and welcome to this week's episode of RePROs Fight Back. I'm your host Jennie Wetter, and it's October means it's getting cold out. The leaves are changing, it's college football season- go badgers. And it also means the Supreme Court is back in session. And this term, that means they're going to be looking at cases impacting LGBTQ rights and reproductive rights. They've already started, they've already heard their first cases on LGBTQ rights. So this episode we're going to talk about the cases that they've already heard and we're going to look forward to talking about the reproductive rights case that they have already decided to hear in the spring, so helping me dig into that I couldn't think of a better person to have then Katelyn Burns a freelance reporter who you may recognize from an episode we did earlier this summer on trans rights are human rights. Katelyn was the first trans reporter covering Capitol Hill. And I am so excited to have Katelyn with us today to help dissect all these issues. Hi Katelyn. Thank you so much for being here.

Katelyn: Thanks for having me on again.

Jennie: So like I just said in my intro, the Supreme Court has already started and they've already started looking at cases that could have major implications for LGBTQ rights. We want to talk a little bit about some of those cases before we talk about how arguments went.

Katelyn: Yeah. So, uh, last week the Supreme Court had oral arguments and um, you have to forgive me, the names of the cases escaped me. But basically there are three separate cases. Two of them were combined and those had to do with LGB rights. So lesbian, bisexual, and gay rights, and whether or not it's legal for an employer to fire somebody for being LGB. So that was one set of cases that was two cases combined into one. And then the second case was the same question but applied to trans people. So is it legally permissible under sex discrimination law to fire a trans person for being trans? So those are the questions that the Supreme Court are dealing with. But just a little bit of detail on the cases themselves and the LGB side, and I have trouble shortening the acronym so I apologize. There was a skydiving instructor who was fired after disclosing to a client that he was gay and you'll have to forgive me, I don't remember the exact details on the second case, but it was something very similar to that. So the argument is whether Title VII of the Civil Rights Act of 1964 applies to LGBT people as originally written or interpreted back in the in the sixties and seventies you know, that wasn't on anybody's radar. But if you actually read the text, which is, which basically says that discrimination in employment decisions cannot be made on like because of sex. If you look at the plain language of it, it seems pretty clear that sex is at least a partial motivator, which the courts have consistently found to be, to interpret as being included under the law. And in the trans case, I have a little bit more familiarity with that because I've been covering it more closely as a trans reporter, but that involved Amy Stevens, who is a funeral home director and embalmer at Harris funeral homes in Michigan. And she came out as trans. She gave her employer a letter saying, you know, I'm planning to change my name to Amy and live the rest of my life as female. And gave the letter to her employer, the employer, read it said, okay, thank you. And then about two weeks later said, yeah, this isn't gonna work out and get rid of her. Um, and I actually interviewed her on Monday of last week, which was the day before the arguments and which everybody needs to go read. It's on Vox.

Jennie: Um, and that’s Vox with a V not F.

Katelyn: Yeah, I don't write for the F. Oh my God. That's pretty funny. It's just one of those, you hear it and sometimes you don't immediately think. You just need to clarify that it's Vox with the V. And you know, she basically said that she got really mad when that happened and then she decided to fight back and filed the claim with Equal Employment Opportunity Commission. So the interesting thing that happened was I believe the case started under the Obama administration where the EEOC fully supported her case and the entirety of the federal government. And now under the Trump administration who is explicitly anti trans, which we've talked about before, there's been some interesting politics. Can I get into this really quick?

Jennie: Sure.

Katelyn: Yeah. So the interesting politics of this is the white house tried to get the EEOC to drop their claim and the EEOC, like career people basically said, no, we're not going to do that because the EEOC is actually an independent commission. This leads into what happened at arguments. So an interesting dynamic at argument was when EEOC cases reached the Supreme Court, the Solicitor General takes over arguments from the agency. The case is actually Harris Funeral Homes versus the EEOC and you ended up having the Solicitor General of the United States arguing on behalf of the EEOC saying that the EEOC should lose the lawsuit. It was pretty ridiculous, yeah. And then just as an aside, I covered the oral arguments. I was inside the press gallery and I was flanked by it like legal reporters, right. So not like popular news sites. Like I was writing for it again with Vox with a V not an F… [inaudible].

Jennie: I didn't know that. Yeah, I guess I wouldn't have thought of that…yeah, like the actual general. I also… it's somehow so perfectly 2019 that we're arguing about LGBTQ rights in such a fundamental way as to if you can be fired because of that. Because mostly that is the wildest thing, right? That people are doing that and two, it's completely like of course in 2019 we're still having that argument.

Katelyn: Right now, on the legal side of things, there's, I believe it's 23 states have state level legislation protecting LGBT people from employment discrimination and yet I can't quote those numbers exactly because some states have LGBT protections and no trans protections. I think there's another state that has trans protection, and not LGBT, so it's like a hodgepodge of local laws, but there actually is no explicit federal law that bans this type of discrimination, but what we've been seeing in the courts is taking a statutory reading of the law that employment decisions cannot be made because of sex. We've had, I think five circuits which have rolled, but Title VII does apply to LGBT people. And we've had one circuit and I don't remember which one it is. I want to say maybe the 11th that said, no, it doesn't apply. So that's where you get the split. That's why it's in front of the Supreme Court now. And it's an interesting case, you know, statutory law so it's somewhat lower stakes for the LGBT community. I think a constitutional question would be scarier because constitutionality can overrule anything Congress does in the future. So we don't want that kind of precedent. But if it's statutory in nature, Congress can always change it. Again, keeping in mind Congress never changes anything, but all of this could end tomorrow if Mitch McConnell would just hold a vote on the Equality Act. And I mean we'd have to have a White House so wouldn't veto it. But still. Yeah.

Jennie: So let's turn to the arguments. So what happened?

Katelyn: Um, I guess it'd be a couple of like maybe two weeks ago when this comes out. But yeah, so that was an hour each for arguments, right? So each side had basically a half an hour, which is kind of wild when you, when you step back and think about the, these are fairly complicated issues that, that only get an hour time and none of the, you know, justices are LGBT themselves. So you have nine straight people who are making this decision, right? I mean there's not even a trans federal judge in the entire system. Not one.

Jennie: I guess that's somewhat surprising slash not surprising, like surprising and like again, it's 2019. There totally should be, but also…yeah.

Katelyn: So, um, anyway, that was an aside, but yeah… on the LGBT side, I thought that the pro, the pro queer attorney did a really good job. I think her case is a little bit harder to make just because just on the text of the law, you can technically make an argument that LGBT people aren't being fired because of their own sex, but because of the sex of their partners. The argument that she made was basically, and this is the one that I thought broke through, at least with me, even though I was biased, was you could have-- Bob and Sally are coworkers and Sally can marry Bill and not be fired. Then Bob can marry Bill and would be fired and that would be disparate treatment between the sexes.

Jennie: Okay, that makes sense.

Katelyn: So if a woman can marry Bill, but a man can't marry Bill, that's disparate treatment and it led to Justice Alito just making some ridiculous, like he tried so hard to find a situation where you wouldn't know. So he took that argument and tried to make this ridiculous extension to her where he was like, okay, let's say we have a scenario where you have a hiring manager and then you have somebody who's doing all the vetting for the hiring manager and they get to the hiring stage. They have two candidates and they don't say the sex of the two candidates, but they say one is gay and one is straight. You've now removed the, the applicant's sex from the equation. Is it still sex discrimination? And I think that tripped up the attorney arguing the case just a little bit, but it's completely ridiculous, right? It's still, I mean, it's a reach. It's not a situation that happens and she's like, that's not what happened in this case. Like, but you know, that's Alito and you would expect nothing less. And then, um, so I think the trans case was also interesting. Again, I think this trans case is a little bit stronger because you are dealing with one person and their sex under the law. Right. If I could just criticize the ACLU really quick. I didn't appreciate their framing of Amy Stevens as a “insufficiently masculine male”. They argued that they tried to equivocate between Amy Stevens and Ann Hopkins, who's the person in the precedent case, which was Hopkins v. Pricewater House where… so Hopkins was a, a butch woman. I've found out recently not a lesbian. So a butch straight woman who is rough talking, did not wear skirts or dresses to the office, didn't wear makeup…

Jennie: I feel like I've heard it framed as that she was a butch lesbian...

Katelyn: Yeah, no, I was corrected on that recently. It just butch. Right, right, exactly right. And what happened was Pricewater House denied Hopkins a promotion because they wanted her to dress more femininely, wear makeup, talk with a higher pitch to her voice and be more feminine with her mannerisms and her speech. And the Supreme Court, you know, years ago, decades ago, determined that that is discrimination because of sex stereotyping. So the ACLU turned around and used that case and said basically one thing that stuck out that they said was if you take all of the same facts of the Anne Hopkins case but make her a trans man, it wouldn't change the outcome of the case. Which I understand why they made that argument. But what ended up happening was it washed the ACLU directly into the bathroom question because if this is an insufficiently masculine male, why can't they use the male bathroom? And that's exactly where it went. And it was really frustrating to me. I wrote another piece for Vox. I was really busy last week expressing how frustrating it was to listen to those arguments and have, you know, Justice Gorsuch claimed that there would be a social upheaval, a massive social upheaval. He said if we rule in favor of trans people in this case, and like I had to go to the bathroom the entire time and like I had to go to the bathroom before the case arguments started but I wasn't going to leave. So I had to make a beeline for the bathroom as soon as it was over. But like the Supreme Court is still standing. I walked by it on my way here.

Jennie: It's just, it's absolutely ridiculous to me.

Katelyn: But I think the ACLU didn't help their case by saying she's an insufficiently masculine male. I think that might come back to bite everybody down the road. I think, and I'm not an attorney, but the attorneys that I've spoken with have told me that they would've gone about it in a different way. They would have really tried to educate the Supreme Court on why Amy Stephen’s experience of womanhood is legitimate and made the case that she was being discriminated against because, and the stereotype that she's defining is not playing assigned female at birth. Right. Being uh, you know, transition into womanhood instead of quote unquote being born into it. Cause I think that opens up the law in a way that won't let you come back. And if you look up the circuit case, because the sixth circuit case for the Stephen’s side of things, that's exactly what her attorneys did there. And if for some reason they changed track of the Supreme Court, I'm not sure why, but in terms of how the arguments went, I think Gorsuch actually might be, if there's going to be a conservative that crosses the line and votes in favor of this case, I think it's going to be Gorsuch…

Jennie:… which I found shocking that people were saying that.

Katelyn: Well, he's a hardcore textualist, right? So he goes by the texts of the law and he said in arguments, he's like, the textual basis of this is there, but he's like, my concern is the social upheaval that what happened from this and is that better determined by Congress? And it's a question of judicial modesty, but I think the textualist side of him says, yeah, this actually makes sense to me. And it's like, it's exactly, it fits with how they wrote the law. And if they want to fix that law, then Congress can change it. And that's the way our system has been designed to. I don't know that he has the guts to actually make that ruling. My gut tells me that either both cases are going to lose or there's going to be a split with the trans case winning narrowly. I'd be very surprised if both cases won. Okay. And I think that social conservatives in general would be very, very upset if the trans case won. So I think there's a lot of pressure there and the conservatives to hold the line. I have my eye on Gorsuch and possibly Kavanaugh cause he's also somewhat textualist in his rulings. Uh, I don't expect any of the other social conservatives to, to go that way. And I'd be surprised if one of the liberal judges voted against either case.

Jennie: Yeah. It's kind of surprising to think that the trans case is the one that might win. Right. But also like when you describe it to me, I can see that. Like I can see why that is a clearer story.

Katelyn: Yes. For the context of Title VII. Right. But if you look at like the state of our society now, the more palatable decision would be to rule in favor of LGBT rights and not trans rights. But sometimes a lot doesn't work that way. Right. And it shouldn't really work that way. I mean, both cases honestly should win.

Jennie: Yes. I mean it's, so… I just can't wrap my head around that. We're having a fight. I mean, I feel like I've said this on so many of these topics, we've talked about the, I can't believe we're having this fight right now, that we're fighting, that doctor should treat people who come into the hospital that we're saying you can't fire somebody because of their sexual orientation or gender identity. Like these are such basic things that I just cannot believe we're still having to fight over.

Katelyn: Yeah. And again, Congress could change it all tomorrow. It's passed the House.

Jennie: Yes. Okay. So we talked about the cases and how the arguments went, maybe a little bit about what would the implications would be if they both lost?

Katelyn: The implication for a loss in both cases I think would be that, again, it's the statutory issues, so the pressure really goes to Congress, right? So if there was a loss in both, I'm really hoping that it will sort of galvanize a grassroots campaign to put pressure on Congress to pass the Equality Act. It's certainly not going to get passed and signed into law by this president. Right. There are elections coming, there are elections coming. So this could possibly turn this into an election issue, which both thrills me as a reporter and terrifies me as an LGBT person for sure. Yeah. And the other, the other thing is to pass the Equality Act to, even if we somehow take the White House and the Senate, we're still going to have to dump the filibuster to get it passed. Yeah. So when I hear, you know, there's a, there was a debate the other night and there was a LGBT town halls last week, which again I've covered for Vox. I don't work for them, but I write for them a lot. And when I hear these big ideas, you know, no matter what it is, reproductive health, you know, Medicare for all, the Equality Act, if I don't hear a candidate talking about filibuster reform, I tune it out because like just process-wise, we're not going to have 60 democratic senators anytime soon. So you need to figure out how to get these things passed with 51 votes. And the only way to do that is by helping the filibuster. So like a couple of nights ago during the debate, I kept screaming, filibuster, filibuster, filibuster. And finally I think Liz Warren said something a couple of times about it and I was like, yes, filibuster reform. And I, I pinned the tweet. But so that's the next step. Like that's the sort of meta-analysis of what happens after is it gets punted to Congress and we need to overcome a certain filibuster. Even if we do someone go somehow get a majority in the Senate.

Jennie: So let's switch gears. So also that same week, I guess also I just have to stay, it was kind of a wild day for me. It was a little emotional morning because I was literally sitting at my desk listening to the Daily from that day where they were talking about Christine Blasey Ford and what she went through to be able to testify and everything that happened. And literally while I was already having a hard time listening to that cause that is kinda triggering and brings back a lot of things is when I got the breaking news alerts that the Supreme Court was going to pick up this abortion case. Rough morning. I bet it's just like all at once. So let's talk about that case. So it is June Medical Services v. Gee and it's based out of Louisiana. Do you wanna tell us a little bit about it?

Katelyn: Yeah. So I just made sure that I was at the top of this on the way over here because I've been so focused on the LGBT cases for sure. So basically this case is a carbon copy of Whole Women's Health v. Hellerstedt. I'm sorry. It's funny. It was from Texas. That's what it was, which was, gosh, what was it, two years ago now that they ruled that. So basically the question is a requirement for abortion clinics to employ doctors who have admitting privileges at a local hospital. It's, you know, a pretty stereotypical TRAP law. And I don't know if you want to go into what those are.

Jennie: Sure. So TRAP laws, it's an acronym. So it's targeted regulations of abortion providers. So it's generally regulations beyond what is needed to ensure patient safety. So I would say like this is a stereotypical trap law. They are designed to force clinics to close or be so expensive, they force clinics to close. Katelyn: So admitting privileges sound sure, of course the doctor should have admitting privileges, but hospitals don't just hand them out to everybody. You need to bring the hospital business and sometimes they turn people down, not just for that, but for ideological reasons. So they're not about to give an abortion provider admitting privileges or abortions are so safe. They're not sending people to the hospitals. The hospital has no incentive to grant them to abortion providers. So who has admitting purposes, almost a political decision for these hospitals. And we're familiar with this, um, the trans care side, I'm actually working on a piece about this, but yeah, I mean I think the perfect thing is what you just said is, is unfortunate. It's actually so safe that it's actually very rare for there to be a complication that requires admitting somebody to a hospital. So it's just a needless recommendation. And if something goes wrong for whatever reason, during the administration of an abortion, they're going to send the person to the ER anyway. It's like, it's unnecessary. It's just unnecessary. And what ends up happening is you push control over the status of these abortion clinics in the hospitals who aren't even affiliated with them and might have their own political agendas. Right. And you actually have seen this recently for a long time, but especially recently where you know hardcore Christians are pushing people into the medical profession in order to block up administration of reproductive health. And this would just be another way to build power for quote unquote Christian objectors. Right. So what happened was a couple of years ago with Whole Women’s Health, this Texas law that was identical to the one in Louisiana, was struck down by the Supreme Court with I think Justice Kennedy is the deciding vote. And basically they said this is an undue burden on, you know, the, the right to an abortion because it would have closed, I think the vast majority of the abortion clinics in the state.

Jennie: Yeah. I think it would have left like four or five, right. For a huge state like Texas.

Katelyn: And then in this Louisiana case, if it goes through, there will only be one abortion clinic for the entire state after this. So this is again an undue burden and should be found the same way. There's clear precedence here. I think it's really, really troubling that they are taking it so soon after establishing the precedent in the first place. And of course the big thing, you brought him up with your emotional day. The only thing that's changed is Justice Kennedy is no longer on the court and Kavanaugh is on the court. And so what ended up happening was, is back in February, they, and I don't know the legal term for this, but I think they like temporarily stayed implementation of the law while they reviewed the case. Kavanaugh wrote the dissent to that where he said, no, I would have let the rule go into effect. Yeah, I would have let the rule go into effect. So he's already signaling how he plans to vote. Susan Collins. Um, yeah. Uh, this, so my gut feeling is, is they, they want to overrule this or they want to overrule the precedent. And I think you'll see every state with a Republican majority implement this law right away. But there's, there's, if I could just go off the legal track for a second, it's interesting looking at happened after Whole Women's Health came down is you actually saw a relative slow down and implementation of TRAP laws in general while they said, okay, hold on. The court is like checking us. Part of me maybe wonders if that's why you ended up seeing so many six-week bans earlier this year because they didn't want to necessarily push on the TRAP law side. I think they decided enough is enough. We're going for big chunks now and they've been pushed back on the legal front and on the six week bans now. But I think that overruling Whole Woman's Health, you'll see a return to just ridiculous, uh, TRAP laws going in all over the country.

Jennie: Yeah. And it's so troubling and scary because this is the scenario where they could argue, well Roe still exists, Roe is still the law of the land. It's there. Roe is still around. But if you are talking about enacting so many TRAP laws that there are no clinics, like people have nowhere to go to get care and your right to access abortion ceases to exist when you can physically no longer go and get one if there is nowhere for you to go, that is affordable. Whether that means, because now all of a sudden you have to take a day or three days off because the state you're in has a 72 hour waiting period. So you have to make two trips, you have to find childcare twice, you have to find transportation twice. This will put abortion out of reach of so many people who need the services, while Republicans will still be able to comfortably say Roe still exists and but people will no longer be able to access care. Yeah.

Katelyn: And I think that, I mean I was there covering the Kavanaugh confirmation and, and Susan Collins herself said, I don't think he'll overturn Roe and she could be absolutely right and still removed the right to an abortion all across the country just by whittling down access all over the place. So it's incredibly frustrating to watch all of this develop.

Jennie: Yeah. I'm really worried about what's gonna happen. What can listeners do? I mean, we've heard all of this about, you know, what's going on. Is there anything listeners can do at this point?

Katelyn: Yeah, I mean continue to organize and push back. I mean, these laws are coming from state legislatures, right? And state legislatures can be replaced. They can be persuaded. I know that some states are more difficult than others and there's gerrymandering and there's voter suppression. I think, again, I would say turn to elections and try to create elections that are as fair as we can create as we go along and really try to push, you know, the people who represent you to not implement these TRAP laws. Right. And like educate the people around you about what TRAP laws are and why they're so pernicious. Like I did a tour a couple of months ago in Philadelphia of an independent abortion clinic and uh, they were saying how state law required them to install like $100,000 HVAC system for their recovery room, which has totally a needed when they had to go up through the roof and it was in there, there was like three floors above them. And it's just an example again of one of these TRAP laws. They were hoping that the clinics landlord would be like, no, you can't, you know, run off the system to the roof that's separate from the other ventilation system that we've already provided you. Right. And this is how they just block up the system for providers. And I don't think people are aware of this stuff.

Jennie: No, it's under the innocuous name of it needs to be a certified ambulatory surgical center. Again, it's, it sounds innocuous, right? Like, but it requires all of these upgrades that are designed to be so expensive that it forces the clinic.

Katelyn: Yeah. And I think there's a lot of stigma and misinformation around abortion. It's actually a really simple procedure. It's, I mean, people have been performing abortions the beginning of time, right? It's not, I mean, listen, I've had gender reassignment surgery that is a major surgery. I was in the hospital for like nine days. Okay. Like that was a big deal. Unfortunate is not a big deal compared to that. Like obviously there's an emotional component to these things, but we're not talking like medically it's not as big or as harsh as like the antis make it out to be. Especially if it's just like a medication abortion. Right. Or just like, you know, you could do it with a hand pump. Really. It's just, it's just not, sorry, I'm just getting angry.

Jennie: Sorry. This is my job. I get to make everybody angry. I'm a real joy to talk to cause I'm, it's like how's work? And I'm like, let me tell you. Yeah. So you know, I'm fun at parties and stuff. Okay. So that's what you can do on abortion. I think we already talked about what you can do around the LGBTQ stuff and that's call your senators and tell them to support the Equality Act.

Katelyn: Yeah. And I think another thing too that's underrated that just an average person can do for LGBT issues is make sure your employer is on top of this stuff. Like ask, you know, ask your employer what their policies are on LGBT people. Is your health insurance plan trans inclusive. You know, if you create a welcoming employment place for a trans person or an LGBT person, which I think is easier to do these days, you can lower the impact of a negative rolling a just on a micro level. So I would say, you know, don't be afraid to ask tough questions of your employer and be like, Hey, what are we doing? Like what does our health insurance plan include? You know, trans health doesn't include abortion because that's another question that comes up, especially if you look at hobby lobby and um, and abortion may be defined as an IUD. Right. Sorry, that was a huge eye roll for, you know, the non visual media. We both eye rolled.

Jennie: Okay. Katelyn, thank you so much for doing this. As always, it was a joy to talk to you.

Katelyn: Okay. Thanks so much.

Jennie: Thanks for listening everyone. And we'll see you on our next episode of repros fight back. For more information, including show notes from this episode and previous episodes, please visit our website@reprosfightback.com. You can also find us on Facebook and Twitter at repros fight back. If you like our show, please help others find it by sharing it with your friends and subscribing, rating and reviewing us on iTunes. Thanks for listening.

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