Whiskey Tango Foxtrot

Advance Sheets No. 55

Woah! First thing I see when looking at the Advance Sheets is King v. American General. I was very pleased with the Court's decision in this case a couple of months back and they have now substituted that decision after reconsideration. Admittedly, I am just as happy with the new opinion to reverse the trial court's decision as I was with the previous reversal. This is a class action that I worked on both during law school and after entering private practice, so there is an obvious bias on my part. I would like to say that this is a must read for anyone practicing real estate law or class action litigation. In reality, I am not sure how far beyond the actual case this decision will actually reach. It is very specific to the errors made by the trial court in this specific case.

Next up is Mikell v. County of Charleston. This was an appeal from a finding that the Charleston County Council properly enacted a zoning ordnance involving a Planned Development on Edisto Island. This is old family property dating back to 1715 and Charleston County allowed certain family members to rezone their property allowing for more dense development of their property contrary to the County's 1999 comprehensive land development plan. Other family members objected and the Master sustained their objection. The Court of Appeals reversed the Master and the Supreme Court reversed the Court of Appeals. The case basically turns upon statutory interpretation of zoning laws which the Supreme Court held to be clear. Judge Cooper was sitting as an acting justice and wrote a dissenting opinion. Worth a read if you deal with land use planning and zoning laws.

State v. Herring is an appeal from a murder conviction. Police entered the Suspect's property and looked into his garage to find his vehicle but not the Suspect himself. They then obtained a search warrant for the residence in which they apprehended the Suspect and found the murder weapon. Suspect claimed the peek into the garage was an unlawful search and the subsequent search of the residence to be fruit of that unlawful search. The trial court found that the peek was an unlawful search but that the subsequent search was unrelated. The Supreme Court found that the peek was a reasonable safety precaution for officers seeking a suspect they know to be armed and agreed that the subsequent residence search was not related to the peek due to the description police received identifying the suspect. Certainly a good read for criminal practitioners. Not sure how the case would work out had the police been searching for an unarmed suspect. One note: this case does involve a search warrant obtained by facsimile. The Court held that the statute regarding search warrants does not, in fact, require the swearing officer to actually appear before the magistrate but to be sworn by the magistrate and, apparently, swearing over the telephone is good enough. Might be a case of bad facts making bad law. Justices Kittredge and Pleicones concurred separately because they disagree with the majority concerning the initial "peek" search being legal. They felt exigent circumstance were not present warranting the peek.

State v. Anderson is an appeal from the Court of Appeals regarding a conviction of 1st-Degree Burglary. The Defendant asserts that the trial court erred in allowing the admission of an unauthenticated ten-print fingerprint card. Prints lifted from the crime scene matched fingerprints on record at SLED. The Defendant asserts that the trial court failed to follow the requirements of State v. Rich to the letter in admitting this evidence. A good read to familiarize yourself with the rules regarding authentication of master fingerprint cards both for the prosecution and defense perspective.

In re Anonymous Member of the Bar is a disciplinary matter involving law practice marketing through the use of discount coupons and use of the terms "expert" and "specialist". Draw a red flag on this one and read it well. The Court dismissed the charges regarding discount coupons but did address the proper method to distribute them.

LaSalle Bank National Association v. Davidson is an appeal from a foreclosure hearing in Dorchester County in which the trial judge did not attend the final hearing. The Court held that failure of the judge to attend the final hearing is a violation of the parties' procedural due process and a nullity. This one steams my blood better than a nuclear reactor heats water. An "empty ritual" is how the bank described court hearings.

Sapp v. Ford Motor Co and Smith v. Ford Motor Company are consolidated appeals regarding the economic loss rule limiting tort claims. The Court affirmed the judgments in favor of Ford Motor and overruled its decision in Colleton Preparatory v. Hoover Universal to the extent that it expands the exception to the economic loss rule beyond that described in Kennedy v. Columbia Lumber & Mfg. So the exception to the economic loss rule is strictly limited to residential property construction only. Justice Beatty filed a separate opinion concurring only in the result, not the reasoning. Justice Waller also limited his concurrence to the result only but did not join Justice Beatty's opinion. This is a confusing concept and you should take a look at the opinions because you may very well need to try to make some sense of it in the future.

Dervin v. State is an appeal from a Post Conviction Relief Hearing. The Court reversed and remanded for resentencing. Dervin was convicted of trafficking in more than 10 grams of cocaine, though the amount involved appears to have been more than 200 grams but less than 400 grams. Since the jury convicted her of trafficking in more than 10 grams, Dervin asserts the jury did not definitively find she had trafficked in 200 grams as required by US Supreme Court decisions. The Court agreed that she should have been sentenced for trafficking in more than 10 grams, not more than 200 grams, unless the jury specifically found the amount was more than 200 grams. Good to know for defense lawyers.

Some Appellate Court Rules amendments follow. Specifically, Rule 412, you know, the one involving your IOLTA, and Rule 608, the one involving your appointments to indigent representations. Definitely want to rad those amendments to see how they affect you.

The Court of Appeals had quite a few opinions issued as well.
Jeffrey v. Sunshine Recycling is a Worker's Comp claim and the substantial evidence rule. This one is convoluted. Better read this one if you do any Worker's Comp work. With the economy as it is, this might be very important for successful resolution for your clients.

Plantation A.D. v. Gerald Builders is an appeal from the trial court's grant of summary judgment to the Defendants based on lack of consideration in a purported contract. The trial court held that the purported contract unambiguously lacked consideration and denying parole evidence of consideration. The Court of Appeals reversed finding the contract was not unambiguous and that parole evidence should have been allowed. This one has some procedural issues for those with a healthy motions practice.

In re Walter M is a very sad tale; an appeal from a family court murder conviction of a minor who fatally shot a friend. Of note: this decision found that the recent State v. Belcher decision of the Supreme Court was not controlling, so this one might not be finished for a while.

Normandy Corp v. SCDOT is an appeal of a condemnation case and determination of the value of the condemned land due to the presence of wetlands. Normandy claims that the property is not wetlands and is of higher value. The Court affirmed the lower court ruling.

Some very interesting cases to peruse.

South Carolina Advance Sheets No.54

Just 4 published opinions in the advance sheets for today. One from the Supreme Court and three from the Court of Appeals.

Supreme Court:
Hooper v. Ebenezer Senior Services - An appeal from common pleas court of York County. Petitioner filed suit against respondent regarding the death of petitioner's decedent but was unable to accomplish service on respondent due to an apparent ownership change and inability to locate the registered agent for service of process. Citing the statute of limitations, the trial court dismissed the case and the Court of Appeals affirmed. The Supreme Court reversed and remanded on the grounds of equitable tolling; finding that there is no exhaustive of suitable circumstances to which equitable tolling should be limited and that, while equitable tolling should be used sparingly, it should be applied where the plaintiff fails to prosecute the matter through no fault of their own but that of the defendant. An important case on this procedural rule that everyone ought to read closely.

Court of Appeals:
Ervin v. Richland Memorial Hospital* - An appeal from the common pleas court of Richland County affirming the Appellate Panel of the Workers' Compensation Commission. Claimant alleged exposure to perfumes rendered her disabled. Employer claimed claimant's asthma was a preexisting condition and claimant was not injured on the job. The Commissioner hearing the matter ruled in favor of Claimant while the Appellant Panel reversed and the common pleas court affirmed. Probably very limited applicability unless you practice in the Worker's Comp field at all.

Shirley's Iron Works v. City of Union - An appeal from the common pleas court of Union County affirming in part and reversing in part the trial court's grant of summary judgment to the defendant. Defendant contracted to build a building to a general contractor but did not require a bond. General contractor retained Plaintiff as a subcontractor and Plaintiff claims it was not paid in full for its work. You really need to read this one because it is a bit complicated in its holding. Particularly if you get involved with litigation between municipalities and contractors,

Smith v. Smith - A cross appeal from the family court of Sumter County affirming in part and reversing in part the family court's final order regarding child support, visitation, etc. A very comprehensive decision regarding divorce cases that you should read.

This week's advance sheets also included notice of proposed changes to Civil Procedure Rules 6 and 7 regarding time for filing memorandum supporting or opposing motions before the scheduled hearing. The changes would create a big change in motion's practice and would greatly reflect the local rules in federal court. If the motion is filed more than 30 days before the hearing: 1) a memorandum in support must be filed at least 20 days before the hearing, 2) a memorandum opposing the motion must be filed at least 10 days before the hearing, and 3) a responsive memorandum in support must be filed at least 2 days before the hearing. As always, if you wish to comment on the proposed rule change, the original and 7 copies must be filed with the Supreme Court Clerk. Deadline is December 29 with a public hearing on January 5 at 3:00 PM. I think it is a good change 9 out of 10 times. I am not 100% behind the idea of finalizing legal theory before the hearing, but how often is that the case?

*I would note that this opinion was written for the Court by Judge Paul Short, Jr., whom I clerked for while he was a circuit court judge.

The Latest Faux Outrage

Conservatives are currently going batshit insane over what they believe is the Obama Administration's policy to purge the civil service ranks of all Bush political appointees who have burrowed into civil service jobs in the past five years.

It is a bald-faced lie.

First, a little background. There are federal laws regarding political appointees taking civil service positions and those laws are regulated by the OMB.

Well, regulated is a bit generous. OMB currently only regulates political appointees applying for competitive or sensitive civil service jobs. If the civil service job is not deemed competitive or sensitive, OMB does nothing to regulate political appointees taking those jobs even though the law says they should. These regulations are not strict; most political appointees seeking civil service jobs are cleared easily.

John Berry, the director of OMB, has issued a memo stating that that policy will change as of January 1. After that date, political appointees seeking any civil service job will be screened by OMB. Also, any person who left a political appointment within five years of seeking a civil service job will face similar, easy screenings.

Nothing about purging current civil servants who were once political appointees. And you can see where the five year bullshit came from.

Just more conservative bullshit. More lies.

The Tree of Liberty

"The tree of liberty must be refreshed from time to time with the blood of patriots and tyrants."

Thomas Jefferson said those words a long time ago. But does anyone know what he was talking about? Do the tea baggers know what he was talking about when they proudly prance around in their Tree of Liberty t-shirts at their tea bag parties? Probably not.

Jefferson was referencing Shays' Rebellion in Massachusetts. Maybe the full Tree of Liberty Quote would be helpful for context.

"Yet where does this anarchy exist? Where did it ever exist, except in the single instance of Massachusetts? And can history produce an instance of a rebellion so honourably conducted? I say nothing of it's motives. They were founded in ignorance, not wickedness. God forbid we should ever be twenty years without such a rebellion. The people cannot be all, and always, well informed. The part which is wrong will be discontented, in proportion to the importance of the facts they misconceive. If they remain quiet under such misconceptions, it is lethargy, the forerunner of death to the public liberty. And what country can preserve its liberties, if it's rulers are not warned from time to time, that this people preserve the spirit of resistance? Let them take arms. The remedy is to set them right as to the facts, pardon and pacify them. What signify a few lives lost in a century or two? The tree of liberty must be refreshed from time to time, with the blood of patriots and tyrants. It is its natural manure."

Jefferson's words still ring true today. The tea bag parties might not have been "honourably conducted," but they were founded in ignorance rather than wickedness. For the most part. For the record, Jefferson said it was OK to kill a couple of ignorant tea baggers every twenty years or so for the sake of liberty. Luckily, we have moved beyond the need for such violence against ignorant tea baggers these days. Also:

"A government big enough to give you everything you want, is strong enough to take everything you have."

These words in 20th century vernacular are not the words of 18th century Jefferson no matter what you might read on the editorial pages of the Charleston Post and Courier. Gerald Ford said these anti-American words while president.

Open Up Your Arms

This is a campaign by Iraq and Afghanistan Veterans of America and the band O.A.R.

This O.A.R.'s latest video:

War Song

Medical Malpractice

People are making some absurd claims regarding the need for medical practice liability reform.

I have read claims that make the outrageous allegation that medical malpractice costs $500 billion per year. The amount of tangible money spent on medical malpractice insurance is quantifiable and less than 1% of total health care expenditures. Claims are paid out of those premiums so add nothing to the total costs.

So where does the remaining nearly $500 billion come from? Proponents of malpractice reform stoop so low as to allege that physicians in this country are committing a fraud so large as to be preposterous. They allege that physicians defraud this country of nearly $500 billion a year through defensive medical practices that are entirely frivolous in order to prevent malpractice claims.

The idea is ludicrous and defamatory to our great medical professionals, most of whom never come close to committing malpractice. First of all, defensive medicine cannot prevent malpractice. Ever. Tests or either part of the standard of care, in which case they are not defensive, or they are not part of the standard of care, in which case they do not prevent malpractice. Second, there are a myriad of reasons a physician would order a test so it is impossible to label tests as solely to prevent malpractice claims and thus outrageously claim malpractice costs $500 billion.

Even if you assume that defensive practices exist, the CBO estimates that eliminating malpractice would save Medicare approximately $54 billion over 10 years. That is $5.4 billion a year in a system that spends about $1.5 trillion. $15 billion is 1% of $1.5 trillion and $5 billion is just one-third of that 1%. That is not real cost savings.

But here is the kicker. Medical expenses account for the largest element of medical malpractice damages. Single payer universal Medicare eliminates the need for medical expenses as a part of malpractice damages. It would also carry over to almost all other personal injury lawsuits. Universal Medicare would be the single most effective way to "reform" personal injury lawsuits.

Concierge Medicine

Or whatever you prefer to call it. There isn't really a good name for it because, really, it is what every general medical practice should be about.

Basically, you pay a retainer to a general practicioner . . . maybe $1500 per year. In return, the physician limits the number of patients in their practice, say to 300. That guarantees the physician revenue of $450,000 to cover their annual "fixed" expenses, assuming a maximum of 300 patients is actually achieved. Other than getting your foot in the office door, that annual fee includes a complete annual physical examination. But hopefully you won't need additional visits.

If you do get sick, you pay for office visits and tests and such as normal. The key thing is to focus on that annual physical and prevent illnesses before they occur. By reducing the patient load, physicians are better able to focus on prevention rather than cure. By guaranteeing a certain level of revenue, you can hopefully encourage people to become general practice physicians focused on preventive medicine.

If you were to add in the benefits of an active health club membership with a professional trainer, a health lifestyle for this country becomes an obtainable goal. It would be a good start.

I would like to see a health care reform bill that expands Medicare coverage to every legal resident of this country. It should include provisions for the above, concierge medical fees and health club membership with monthly monitoring by a professional trainer. This would rein in costs by helping people to be healthy and prevent illness. Anything less, in my opinion, would be a failure. And it would be a lot cheaper than many would imagine.

Liberal

An adjective.
Favorable to or in accord with concepts of maximum individual freedom possibly, especially as guaranteed by law and secured by government.

What Their Words Reveal

I've been hearing a lot of noise from a very small minority of physicians who are just tore up with some kind of superior stupid. Take for instance this excerpt from a letter to the editors:

"Private health insurance pays about half of what physicians bill, Medicare pays about 20 percent and Medicaid pays even less."

So basically all of the payers in health care think physicians charge too much and refuse to pay those charges. That is what this statement means. And we know physicians charge too much because no one pays them what they charge yet they remain viable businesses.

And the always dubious claims regarding tort reform are just plain outrageous. Physicians paid around $10 billion in malpractice premiums last year. And payouts on malpractice claims were around $5 billion. Neither of these figures is a significant portion of U.S. health care costs. Yet, tort reform is once again being presented as a must-be-addressed issue by those who otherwise oppose all health care reform. Ande since $10 billion isn't enough to control health care costs, the tort reformers are relying mainly on an intangible boogeyman named Defensive Medicine.

The kindest thing that can be said about Defensive Medicine is that it is a strawman. It is not only intangible, but almost completely hypothetical in nature. Tort reform advocates claim that this bogeyman accounts for 10% of health care costs, $300 billion. Malpractice payouts accounts for $5 billion, but tort reformers want you to think that physicians spent 60 times that amount to prevent having to pay $5 billion. Really?

Now, I said the kindest thing that could be said about Defensive Medicine is that it is a strawman. But I am not feeling particularly kind toward tort reformers. If a physician orders a test merely to prevent a lawsuit . . . I cannot even complete that thought it is so outrageous. The physician hasn't prevented anything.

A malpractice claim is preciated upon a violation of the standard of care. If the standard of care does not call for a certain test, then ordering that test is not defensive. It is frivolous and unethical. If the standard of care does call for a test to be performed, then ordering that test is not defensive. It is the standard of care.

So if a physician claims to practice Defensive Medicine, remember that that physician is admitting to engage in Frivolous Medicine and confessing to unethical practices.

What Is Property?

With recent "purchase" of AIG by the U. S. government, the word "socialism" has been receiving a lot of unwarranted attention.

We have long thought about and played with various economic systems. There are all manner of theories out there, but they mainly are based upon the different views of the ownership of property. We can argue about capitalism versus socialism versus fascism versus communism until the cows come home but it is meaningless if we do not understand what we are arguing about. And to begin to understand economic theories, we have to understand what property is. Because that is the dividing line of economic theories.

We can dismiss personal property and intellectual property from consideration because both of those items are determined by the economic system; they do not define the economic system but are defined by it. So basically we are talking about real property. Land and the resources within the land. We can also include improvements made to the land, such as a factory and equipment permanently installed within it. The means of production, thus, are the land, resources and improvements thereto.

There are essentially two theories about the ownership of property, now that we have defined it. First, is the theory that rejects the idea that property, nature, can be owned by individuals. The second obviously accepts the idea that property can be owned by individuals. That's it, folks. Nothing more complicated than that. And they cannot be reconciled with each other. There is no combination of the two. You cannot accept the idea of private ownership of property and reject the idea at the same time.

The theory accepting private ownership is obviously capitalism. The other theory is basically ever other economic model ever created. For simplicity's sake, we can divide the theory rejecting private ownership into two camps. The first would be those who believe nature cannot be owned and is available to all; this would be communism. The second would be those who believe that the government owns nature on behalf of the . . . whatever (whatever being the separation in the remaining economic models; generally some type of aristocracy); this would be socialism.

Socialism is the predominate economic system for most of mankind's recorded history. Fascism, feudalism, you name it, are variations of socialism. Communism being the predominate economic system for much of mankind's unrecorded history.

That may be debatable because we never consciously created capitalism; it just sort of snuck up on us and we didn't even see it until Adam Smith pointed it out to us. It arose from feudalism, when monarchs started giving land to subordinates. At some point, that gift of the monarch became less of a noble's "duty" and more of a noble's "right." When the nobility further began giving land away to commoners, the concept of private ownership became entrenched.

We have pretty much done away with any valid concept of socialism or communism and they are relatively useless terms to be casting about in a capitalist society. At best we have concepts of capitalism that may resemble some loose concept of socialism or communism in a general sense. But they are based on an entirely different view of the world and cannot be mixed with capitalism.

Why I Am A Liberal

Because I am an American and believe in our Constitution and Declaration of Independence.

Because I am a Capitalist.

Because I am a Christian.

I cannot think of three more liberal institutions than those.

This has been another episode of simple answers to simple questions.

McCain Chooses A Running Mate!

Heh. Indeed.

A Day Which Will Live In Infamy

Seven short years ago today the President of the United States was briefed on a summary of intelligence related to terrorists activities in the United States. As the then National Security Advisor to the President was fully aware, that summary briefing was titled "Bin Ladin Determined To Strike Inside The U.S."

The President responded to be being briefed about 70 full field investigations into possible terrorist attacks inside the United States by telling the briefer: "You've covered your ass."

He wasn't covering his ass, Mr. President; he was providing you with information so that you direct the Administration on their efforts to protect this country. You failed.

And more than 3,000 Americans died as a result of your failure.

As bad as that was, you continued to make poor decisions that led to the deaths of thousands of other Americans and hundreds of thousands of people in other countries.

In honor of my friend Todd's birthday, I offer this birthday song in remembrance.

It's you're birthday.
Oh, happy birthday.
Misery, grief, and despair
People dying everywhere
On your birthday.
Oh, happy birthday.

Beating Irony To Death

A headline on the last page of the front section of today's Post & Courier caught my eye. The headline claimed that 2 former CIA officials denied telling Ron Suskind that they had been told to fabricate intelligence linking Iraq to the 9/11 Hijackers. So naturally I read the article.

It was an AP article under Brett J. Blackledge's byline. I couldn't find a link to the article on charleston.net but here is a link to it at Newsweek with a headline similar to the Post & Courier headline.

One of the first things I read in the article was not that two former CIA officials deny Suskind's claims, but that the White House issued a statement on their behalf. Then I read further that itself wasn't really true. The White House issued a statement on behalf of one of the former CIA officials who himself was claiming to speak on behalf of the other.

But the entirety of the story revolves around accusations that the White House is fabricating communications for people.

So, you know, maybe it might be better to not use the White House as a source for communications it claims were made by others!

Update: To be clear, the former CIA officials in question are named Robert Richer and John Maquire. The White House allegedly issued a statement on behalf of them both. It actually was only Richer allegedly making the statement. In the statement Richer alleges that he spoke with Maquire who authorized Richer to say that Richer never order him, Maquire, to fabricate evidence. It is all very self-serving from beginning to end.

Update II: Suskind is standing by his book and says it is all on record in his notes and recordings. Suskind also claims that Maquire was pressured to make a statement based on misleading information.

To the South Carolina Democratic Party

You suck.

No. Seriously. The state party is a joke. Its candidate for U. S. Senate was a member of the Horry County GOP Executive Committee when he filed to run as a Democrat. Apparently, the Horry County GOP did not kick him out until June, so for much of the primary campaign he was still a member of the Horry County GOP Executive Committee. Every time he was asked about it, he was lying when he failed to acknowledge his realtionship with the GOP.

I know. I never mentioned any of this either. Guess what? I suck too. I knew the guy was a Republican and I hardly ever said anything about it. I made shadowed references to it. At the Galivants Ferry Stump Meeting, I said that I didn't join the Democratic Party to run in this election. That was as close as I ever came to attacking my former opponent to a large group of people. I made the conscious decision not to attack him. I made a conscious decision to tell people about myself, not my opponent. I tried to be a nice guy.

Nice guys finish last.

Yeah, the news media sucks too. Jim Davenport at the Columbia Bureau of the Associated Press seems to be the only news reporter interested in finding out anything about Bob Conley's relationship to the GOP. His colleague Seanna Adcox was thorough in finding out about my background. So I certainly want to say that the Associated Press did a good job of trying to find out about the candidates. The Big Picture, a show produced by SCETV, and its host Mark Gwinn did a good job interviewing the candidates (I am including all of the staff of The Big Picture in this). It isn't their fault that Bob Conley elected to lie to them about his affliation to the GOP. But the rest of y'all, y'all suck. I know y'all thought it was supremely arrogant of me to presume to run for United States Senate. It seemed to be the only thing y'all were really interested in covering. Really, there is no ranking of aristocracy in this country. Anyone who wants to run for the U. S. Senate is entitled to do so.

Oh, and Bob Conley is a liar and that is beyond suck.

But all of that fails to relieve the state party of sucking. The state party did nothing to find out anything about the unknown people who filed to run for the party nomination. And I do mean nothing. There are many good people staffing the offices of the state party and I am not saying any of them suck. They are great people eager and determined to work hard for our state. No, I mean the "highly placed Democratic Party leaders." Not one of them ever tried to contact me to find out anything about me. On the county level, yes. County chairs were constantly seeking to contact the campaigns. But not the state level leaders.

Although those state level leaders were all to happy to tell reporters they had never heard me, even though they may have actually worked with me previously. To his credit, Joe Erwin has expressed his regret at having told reporters he had never heard of the candidates. However, when I spoke with him, he didn't seem the least bit interested in speaking with me. But he is certainly not the only state level leader in the South Carolina Democratic Party. He isn't even the state party chair any longer. So, it really wasn't his responsibility and certainly not his alone.

After the June 10 primary, I told a reporter that the Democrats had just nominated a Republican. In the article in which that quote appeared, Don Fowler was also quoted seemingly discounting my quote and saying that the Democratic Party welcomes everyone, even those with conservative beliefs or former Republicans. I did not say Bob Conley was a former Republican; I said he was a Republican. The following week, after the automatic and mandatory recount (not anything I requested, Minuteman assholes), an Horry County GOP official broke the news that Conley had been a member of their Executive Committee up until shortly before the June 10 primary. That is what I meant, Mr Fowler. Maybe I should have said "he is not a Democrat" to more precisely get my meaning across, but as I said, I suck too.

But Don Fowler is not the only Democratic leader in this state. He isn't even a DNC Committeeman any longer. His only leadership role really is as the husband of the State Party Chair, Carol Fowler. And she has only been Chair for a year. I look forward to seeing great things with her as our Chair.

No, the people I am really referring to are our elected officials. Not one of whom reached out to me. Not one of those whom I attempted to reach out to bothered to return my calls or respond to my emails. It is sort of a "I got mine" attitude. I saw nothing resembling an appearance that separate campaigns were preparing to work together in a coordinated effort. How are we ever going to win back this state if campaigns don't work together? How are we ever going to do what is best for our state if elected officials, or candidates, seem more interested in protecting their own territories rather than helping others get elected?

And that was the most disappointing thing I learned during my brief campaign.