And my boy still wanted it. After I told him about the blog post, he was back to whining. “Did you tell them to change me to a girl yet?”

“No, son. It’s wrong and I won’t do it.” Because we have rules in this family, guidelines for living that include “Be kind” and “Learn something new every day.” Also “Don’t sell your soul.”

Some of these rules are easier to explain to young children than others. This is another one they weren’t quite sure about:

I bought this magnet the day the post first appeared and put it on the refrigerator above our family calendar. I hoped the children would see it and somehow the words would leech into their minds, allowing the meaning to steep over the years.

But today I took it off the refrigerator. I made the kids stop their homework and read the words on the magnet out loud. “Do you know what this means yet?”

They shrugged.

“This is what it means.” Then I read this email to them:

“Thanks for getting in touch with us about your son’s LEGO® Club membership. I’ve read your blog post with interest and I really regret that you’ve had this experience. Any of our LEGO themes can be enjoyed by any builder, which is why we offer so many different options from which children can choose based on their interests.

We found the conclusion at the end of your post very compelling. As a result, we’ve updated the way kids can opt into or out of the LEGO Friends insert in their LEGO Club Magazine. We’ve worked across global functions to make this happen as quickly as possible, while also developing a more in-depth strategy for next year.

The quick solution is that from now on, LEGO Service advisors will be able to select the LEGO Club magazine with or without the LEGO Friends insert. This will be based on the LEGO Club member’s preference as you suggested and not as determined by gender. Please call or e-mail us again so we can update your son’s preference to get the magazine with the LEGO Friends insert. We’ll then send the latest issue to him so he can enjoy it.

Our longer term approach to improving the online sign up process will offer parents and the LEGO builders in their family a choice of magazine versions, so that we can be sure that we really meet to our fans’ tastes.

For 80 years, our core values have been Fun, Creativity, Imagination, Learning, Quality and Caring. We take these values very seriously and we really care about our fans, so I’m grateful that you took the time to share your views.

Please let me know if I can do anything else.

Brick on!”

If Lego follows through, my son will get his Friends insert. Someone else’s son won’t even have to ask, or forced to identify as something he doesn’t consider himself to be. And no one’s daughter will be automatically enrolled based on outdated gender stereotyping. And children with a gender identity that isn’t girl or boy, won’t need to identify as something they aren’t just to get the toys they crave.

Thanks to Lego, my kids understand the meaning behind the magnet.

After seeing how far companies can go to allow for greater gender equity in toy marketing, my daughter is composing a letter to Toys ‘R Us: “The Princess and the Pet Peeve: Where You Can Stick Your (Boys-Only) Sword”

Hello Hair Trigger Types Who Read The Title and Immediately RT. DON’T. Read the editors note first. Then read the actual article. Then read the 5 or 6 articles written after that. THEN consider leaving a comment. But you absolutely don’t have to. Enough has been said, really. – KDC (10/12/2014)

by Kristin Bezio

Editor’s Note — Since this post was written in February! 2013!, Kristen has written followup posts about this issue, including “Digital Damsels in Distress: A Simplified Version of a Real Problem in Gaming”

If you want to comment or share this, do so knowing Kristen is a feminist AND a game critic AND an academic, so this is a critical analysis, because The Learned Fangirl’s tagline is “a critical look at pop culture and technology”!

…..

Back in May, the internet exploded both in favor of and against Anita Sarkeesian’s Kickstarter project “Tropes vs. Women in Video Games,” with a huge contingent of trolls attacking her professionally, intellectually, and personally. Another less vocal contingent supported her Kickstarter campaign to the tune of approximately $150,000. Since then, Sarkeesian has been a vocal presence in the online and real world communities, speaking out against online sexual harassment and occasionally tweeting and blogging about the games she’s playing (presumably for the video series).

On the surface, much of this would seem to align itself with my own personal sympathies, and for a long time I was also a supporter of Sarkeesian’s proposal and her efforts to defend herself against the trolls. I continue to think that her proposed project is one that needs to be done, and I also continue to think that the treatment she received at the hands of the under-the-bridge-dwelling internet was unconscionable.

I am, however, getting over her.

I think it’s long since been time to stop talking about what happened to her and how awful it is and high time to start taking a more progressive stance on the whole thing. Okay, there’s bad behavior on the internet. I got it. How do we help change it? How do we raise our kids and talk to our fellow gamers about acting like adults instead of infants? Repeating over and over how immature the gaming community is as a whole doesn’t do much.

Painting a picture of the gaming community as cruel, misogynistic, violence-prone basement dwellers is not helping with viewing gaming through the lens of rationality. It also alienates those gamers who are genuinely nice people. And further alienates feminist gamers as “White Knights” (people who will defend female gamers at all costs, no matter how wrong they are) rather than reasonable human beings with respect for all.

As a female gamer, I’ve been subject to sexist, harassing, and misogynist comments and assumptions whenever I play online. I understand and sympathize with her desire to lash back, and with her desire to see that it stops. I just think it’s time that the conversation move somewhere more productive.

But May was a while ago, and while Sarkeesian has been occasionally tweeting about games, she hasn’t managed to release even one video in the series her backers paid for. I’m actually finding myself agreeing with a lot of voices on the internet wanting to know why they haven’t seen anything. People are starting to wonder whether those who donated have any recourse if they don’t ever see videos. And that isn’t helping people to feel any more sympathetic toward Sarkeesian herself.

Yes, she’s been busy interviewing in NPR and doing a TEDx Women talk, and travelling around to universities and conventions and other places. I get being busy. But there doesn’t seem to have been a concerted effort to actually begin the serious production process for the video series. Perhaps she has – I don’t know, because she hasn’t been sharing that. I know she’s got a lot of work to do – a lot of games to play, a lot of notes to compile, and so on. As an academic, I understand the overwhelming nature of research and production. However, she can create videos in installments the way an academic researcher putting together a long-term study or a book cannot.

Most important to me is that the snippets of feminist criticism that I have seen coming out of Feminist Frequency have not inspired confidence, in either her interpretive skills as a gamer or in her ability to separate “feminist criticism” from “pointing her finger at women in games and saying ‘bad.’” Take her tweet on Dishonored, for instance: “Many truly brilliant elements in the game #Dishonored, sadly representations of women are not among them. #Disappointing.”

Here’s my problem with this. Dishonored doesn’t have many “strong female” characters … except for the Empress, the Empress’s daughter Emily, and Callista Curnow. Yes, the Empress gets killed in the first five minutes of the game and Emily needs rescuing (she is 10, after all), but Callista makes a point of doing several things in the course of the game that tell you she’s quite a capable human being. One of the most powerful figures in the game is female (though insane – Granny Rags), and the nation appears to be a matriarchy. Yes, there are a lot of female victims in the game, but there are just as many if not more male victims. In fact, pretty much everyone is a victim at one point or another. And yes, there are female villains, but there are male villains, too.

Sarkeesian seems to dismiss Dishonored as misogynistic simply because it doesn’t contain the stereotype of the “strong modern female” in a game that is about how everyone is at the mercy of arbitrary fate in the form of rampaging plague rats.

My point isn’t that games aren’t misogynistic – there are far more of them that are than that aren’t, and some of them are really blatant – nor is it that someone doesn’t need to have the serious conversation about representations of gender (especially women) in games. I think both those things are true. But if Sarkeesian is going to dismiss a complex and intelligent game like Dishonored out of hand, then I have my doubts about her overall ability to be that voice, at least to the degree that we as an internet gaming community seem to have accepted.

I don’t want me or other “feminist gamers” to be thought of as those that do nothing but whine and yell about how women are underrepresented and misrepresented in games and the gaming industry. I don’t want to see women and feminist men with valid criticisms and interpretive opinions silenced because “feminist gamers” have gotten a negative reputation because of what Sarkeesian has and has not said and done.

What I want, really, is for Sarkeesian to make her “Tropes vs. Women in Video Games” series. I want to see what kind of critical approaches she actually takes, and I want to judge her ability to speak for female gamers on the merits of what she has to say about games, in detail, with examples, not based on fleeting tweets and TEDx talks on how internet trolls are horrible people. I want her to make something of quality, and to be successful because of what she’s done rather than what has been done to her.

And that’s how I want all women, gamers, academics, critics, and others, to be successful. Because of what we are capable of accomplishing, not because we have been made victims by trolls, by society, or by individual men (or women). Yes, it is important to talk about what has happened to women, historically and currently, but it is also much more important to talk about what women can do. Let’s talk about how to make the industry better, smarter, friendlier, more tolerant, and more accepting, not just how bad it is now. And if we want our games to change, let’s look at what’s really wrong with them, not just the surface checklist of whether it has a female protagonist or not.

And, finally, let’s stop all the arm-waving and finger-pointing. Videogames don’t cause misogyny. They don’t cause violence. They don’t cause any of society’s ills. Like any other form of popular culture, they reflect those ills and seek to make changes to those things they can. Dishonored puts a princess in a tower (literally) not because it thinks she belongs there, but because it knows she doesn’t.

The Learned Fangirl is steeped in the experience of being a fangirl. Unfortunately, there aren’t nearly enough pop culture examples that are from the perspective of fangirls. Fortunately, there is Answer Me 1997 (2012), a Korean drama, half-set in 1997, the starting point for K-pop’s unending hallyu wave of manufactured groups. This is a show for present or former fangirls of music — from Beatlemaniacs through the Metallica/Megadeth fan battles to those with Bieber fever.

What is so delightful about this show — from the first episode to the last — is that it shows fandom as a powerful, distracting, encompassing, and motivating force in the lives of fans, especially female fans. The show starts when the characters are teenagers, so it shows all of the aspect of high drama that only is possible with the heady mix of hormones, groupthink, and innocent obsessiveness of teenage girls. I laughed knowingly during the first episode when the main character Shi Won almost loses her mind dancing along to H.O.T. in the aisles, nearly passing out from pure fandom excitement.

Throughout the show, fandom is respected in a way rarely seen (and even rarer to see sustained through the entire run of a show). Friendships are tested, but never broken, due to being part of different fandoms. The show is based around the real-life Sechskies/H.O.T. fanwars, but also delves into real world issues, such as inclusiveness, especially of gay (& closeted) fans to traditionally female fandoms.

The fandom of the characters is so serious that one of the main characters as an adult is still known as Mrs. Tony — her teenage nickname based on her love of Tony (from H.O.T). And as an adult, a minor character despite her high profile job, still manages to be the head of a fan club. There is also a strong flavor for the idea that being an obsessive fan is passed down from mother to daughter — even if the object of the fandom varies, much in a similar way to the honored tradition of sports fandom being passed from father to son.

To show the recursive aspects of the show, most of the actors on the show have also been the objects of this type of fandom, considering many of them have been idol singers themselves. The writers clearly know how much they are poking at fandom by having the equivalent of a former real-life Backstreet Boy (here: member of Sechskies) portray the boyfriend of an obsessive fan of the Backstreet Boys.

This is a show that believes in fandom so much that a character wins a college scholarship based on her real-person slash-fanfic about her favorite group.

Dramabeans has great recaps of all of the episodes, but to watch the show, try Dramafever (my recommendation), Hulu, or VIKI. Be sure to watch Episode 0 if you want background on H.O.T. or other aspects of mid-90s Korean pop.

This conversation was on the heels of an in-person conversation that Viv and I had earlier this year, there’s much less profanity, but the ideas are the same. – KDC

VO: Is it just me or is this year the year of harassing geek women? There’s been tons of news about people questioning Felicia Day’s geek cred, the harassment of Anita Sarkeesian for the Tropes vs. Women in Video Games web series and the whole line of “what’s a real geek”? What’s even funnier is seeing this happen roughly at the same time as what was going on in the metal scene.

KDC: Definitely not just you, I think it’s happening in a number of fan communities, that “Girls don’t like metal” post from Metal Sucks comes to mind, even though it was last year. And there have definitely been similar sentiments pop up in other blogs. It’s like open season on chicks who dare to enjoy any kind of pop culture that isn’t Twilight or Fifty Shades of Grey. And it’s weird to me because I swear this level of anger towards women in fan communities seems relatively recent, or at least more pronounced as of late.

Cross-gender Justice League at San Diego Comic-Con 2011Image; Roger Chang, FlickrVO: I think that some of this that the conversation is coming to the forefront. The Internet is offering the ability for women to speak up and tell their stories and I suspect that (geek-wise) they’re upset because they’ve always been seen as the outsiders that welcome everyone, and it turns out it’s not quite the case. Plenty of my friends have stories of being talked down to or having people play their characters at conventions or where gaming professionals talk to their boyfriends or husbands even though they asked the question.

The anger to me is reactionary to them finally being called out on their shit. And it’s not every guy, but it’s also food for thought on the culture as a whole.

KDC: I definitely agree with you, it’s not like like girl geeks are anything new. they’re not even new to fandom, or online fan communities (i am thinking of old school Star Trek fandom, or the Beauty and the Beast TV show or X-Files fandom in the 90’s) But I do think social media has brought different subsections and fandom niches together in a way that never happened as much before and allowed (forced?) them to co-exist. There’s not a cross-pollination of fandom in-jokes, tropes and culture and maybe for some fanboys, I think there’s a feeling that their special club has been invaded.

Fandom diversity because “mainstream” with social media because it encourages a higher level of transparency, rather than the total anonymity of the old school Internet (BBS, Usenet, etc.) I’m sure back in the day, people thought I was a guy, with the screenname “Pastor of Muppets,” and the fact that I never made a point to call attention to my gender (or for that matter, my race) I’ve had a couple of different experiences with this because as a metalhead, I feel like I’ve not really been talked down to or condescended to much, but then, I’m not super active in online metal fandom, where I think there’s more of that kind of behavior. Personally, I feel like male-dominated online fan culture tends to be more combative by nature, which I think plays a big role.

VO: I think it’s also seeing a different perspective that may not mesh with what they want — for example the vitriol aimed at DC’s reboot and their portrayal of Starfire (which is really, really awful and I can’t see letting my daughter read that, even though she loves Tiny Titans and Teen Titans). It’s like they fail to realize that there’s other audiences out there and it’s more diverse than what they think.

What I don’t get is that by ridiculing others, they’re alienating a potential audience that was ALWAYS there, but never noticed. To say that we’re not “real geeks” or that our voices don’t matter is incredibly insulting. I mean, being ignored is one thing, but outright dismissed? That’s fucking war in my book. But this also reminds me of the rock scene and how people start slagging off on an indie band when they start playing MTV or getting larger audience notice. They’re not selling out – there’s just a wider audience than what you initially thought.

KDC: I do feel like issues of wanting to maintain the status quo come into play: people want what they want and in many cases, especially with fandom, radical change on any level is usually not welcomed with open arms, but this is different to me, this has way more to do with (here we go…) privilege and entitlement, the belief that these communities were only meant for men and can only speak to men and that women are interlopers. I think about the whole music blogger trend of classifying melodic or (non-brootal) metal as “girlfriend metal” as if a.) only women like melody b.) only melodic bands are “safe” or “appropriate” for women. Which of course is some grade- A bullshit. I really do think it has to do with the idea that women are not only participating in these fan communities, but also carving out spaces where the approval and participation of male fans as so – called “experts” is not needed or even considered as a factor of our own enjoyment.

So what to do? Is there anything we, as fangirls, can do, except continue to speak out and be ourselves?

VO: What I’ve seen from my friends, and what I tend to do is just keep on keeping on. Don’t leave because of some asshats (and really, most of the geek dudes I meet at Gen Con are good players and good guys overall) are being jerks. You call them out on that shit and make them rethink their positions. Also, for me, having a good group of friends who are willing to speak up also helps. My view is that they need to be reminded that we won’t go away. We are here to stay and we will continue doing what we like to do, even if you’re weirded out, feel the need to categorize it or talk down to us. We’re here whether you want us around or not.

We’d like to hear your thoughts. Is sexism in fandom on the rise? Or are we just hearing about it more via social media? Leave your comments!


/*
 * Copyright (c) Facebook, Inc. and its affiliates.
 *
 * This software may be used and distributed according to the terms of the
 * GNU General Public License version 2.
 */

//! Support for converting Mononoke data structures into in-memory blobs.

use anyhow::Result;
use blobstore::BlobstoreBytes;
use bytes::Bytes;

use crate::typed_hash::{
    ChangesetId, ContentChunkId, ContentId, ContentMetadataId, DeletedManifestId, FastlogBatchId,
    FileUnodeId, FsnodeId, ManifestUnodeId, RawBundle2Id,
};

/// A serialized blob in memory.
pub struct Blob<Id> {
    id: Id,
    data: Bytes,
}

impl<Id> Blob<Id> {
    pub fn new(id: Id, data: Bytes) -> Self {
        Self { id, data }
    }

    #[inline]
    pub fn len(&self) -> usize {
        self.data.len()
    }

    pub fn id(&self) -> &Id {
        &self.id
    }

    pub fn data(&self) -> &Bytes {
        &self.data
    }
}

pub type ChangesetBlob = Blob<ChangesetId>;
pub type ContentBlob = Blob<ContentId>;
pub type ContentChunkBlob = Blob<ContentChunkId>;
pub type RawBundle2Blob = Blob<RawBundle2Id>;
pub type FileUnodeBlob = Blob<FileUnodeId>;
pub type ManifestUnodeBlob = Blob<ManifestUnodeId>;
pub type DeletedManifestBlob = Blob<DeletedManifestId>;
pub type FsnodeBlob = Blob<FsnodeId>;
pub type ContentMetadataBlob = Blob<ContentMetadataId>;
pub type FastlogBatchBlob = Blob<FastlogBatchId>;

impl<Id> From<Blob<Id>> for BlobstoreBytes {
    #[inline]
    fn from(blob: Blob<Id>) -> BlobstoreBytes {
        BlobstoreBytes::from_bytes(blob.data)
    }
}

pub trait BlobstoreValue: Sized + Send {
    type Key;
    fn into_blob(self) -> Blob<Self::Key>;
    fn from_blob(blob: Blob<Self::Key>) -> Result<Self>;
}


621 So.2d 240 (1993)
George BOROS
v.
William J. BAXLEY, et al.
1910866.
Supreme Court of Alabama.
February 26, 1993.
Rehearing Denied May 28, 1993.
*241 George Boros, pro se.
Stephen A. Rowe and E. Berton Spence of Lange, Simpson, Robinson & Somerville, Birmingham, for appellees.
MADDOX, Justice.
This is a legal malpractice action. The plaintiff, George Boros, acting pro se, presents five issues: whether the trial judge erred in (1) directing a verdict for the defendants; (2) refusing to recuse himself from the case; (3) denying Boros's request for a continuance; (4) granting the defendants' motion in limine as to punitive damages and damages for mental anguish; and (5) denying Boros's motion to amend his complaint. We affirm.[1]
Boros sued William Baxley, Charles Dauphin, and the law firm of Baxley, Stuart, Ward & Dillard, alleging legal malpractice; specifically, Boros alleged that in an earlier case they had failed to file his complaint within the statutory period of limitations. The underlying case involved Boros's purchase of real estate from Jack Shewmake. Boros had employed Gwen Palmer, an agent of the real estate company of Johnson-Rast & Hays, to help negotiate the purchase from Shewmake. After moving into the house, Boros found numerous problems.
Boros then retained the Baxley firm to sue Shewmake, Palmer, and Johnson-Rast & Hays on the basis of fraudulent misrepresentation. Shortly after filing suit, the Baxley firm terminated its relationship with Boros because of a dispute over attorney fees. The trial court in the underlying case entered a summary judgment for Palmer and Johnson-Rast & Hays, without stating a specific reason. Boros and Shewmake had settled their dispute before the summary judgment was entered. This Court affirmed the summary judgment, concluding that the applicable statute of limitations period had expired before the lawsuit was filed. Boros v. Palmer, 472 So.2d 1020 (Ala.1985). On October 4, 1985, Boros filed the present suit.
In this action, Boros presented his evidence to a jury. On the defendants' motion, the trial court directed a verdict against Boros on the basis that he had failed to show that he would have recovered against Palmer and Johnson-Rast & Hays in the underlying lawsuit alleging fraudulent misrepresentation had that case been timely filed. Boros appeals from the resulting judgment for the defendants. We affirm.

The Directed Verdict Issue
Initially, we note that a motion for directed verdict is a procedural device by which one party tests the sufficiency of the other party's evidence. See, Rule 50(a), Ala. R.Civ.P.; Alabama Power Co. v. Williams, 570 So.2d 589 (Ala.1990); John R. Cowley & Bros., Inc. v. Brown, 569 So.2d 375, 376 (Ala.1990); J. Hoffman & S. Guin, Alabama Civil Procedure § 8.37 (1990). The ultimate question presented by the motion, of course, is whether the nonmovant has presented sufficient evidence to allow submission of the case or issue to the jury for a factual resolution. Hoffman & Guin, supra, at § 8.37.
For actions filed on or before June 11, 1987, the applicable standard of review is the "scintilla evidence rule." Section 12-21-12(e), Ala.Code 1975; Maharry v. City of Gadsden, 587 So.2d 966 (Ala.1991). Under the "scintilla evidence rule" the nonmovant could defeat a directed verdict motion by showing "a mere gleam, glimmer, spark, or trace of evidence" supporting each element of his cause of action or defense. See, e.g., Gross v. Republic Steel Corp., 400 So.2d 383 (Ala.1981), and Gadsden Paper & Supply Co. v. Washburn, 554 So.2d 983 (Ala.1989).
Additionally, in reviewing a motion for directed verdict this Court must view all the evidence in a light favorable to the nonmovant and must entertain such reasonable evidentiary inferences as the jury would be free to draw. Williams v. Allstate Ins. Co., 591 So.2d 38 (Ala.1991).
*242 Concerning legal malpractice, this Court has stated:
"[I]n a legal malpractice case a plaintiff must prove, basically, the same [elements] that must be proven in an ordinary negligence suit. Moseley v. Lewis & Brackin, 533 So.2d 513, 515 (Ala.1988); Tyree v. Hendrix, 480 So.2d 1176 (Ala. 1985). Thus, the elements [a plaintiff] must prove in order to support his legal malpractice claim are a duty, a breach of that duty, an injury, that the breach was the proximate cause of the injury, and damages. Moseley; Tyree; and Herston v. Whitesell, 348 So.2d 1054 (Ala.1977). [Additionally,] [i]n a legal malpractice case, the plaintiff must show that but for the defendant's negligence he would have recovered on the underlying cause of action, Johnson v. Horne, 500 So.2d 1024 (Ala.1986), or must offer proof that the outcome of the case would have been different. Hall v. Thomas, 456 So.2d 67 (Ala.1984)."
McDuffie v. Brinkley, Ford, Chestnut & Aldridge, 576 So.2d 198, 199-200 (Ala. 1991).
The tort of fraudulent misrepresentation under § 6-5-101, Ala.Code 1975, requires "(1) a false representation, (2) regarding a material existing fact, (3) which the plaintiff relies upon, and (4) damages proximately caused by the misrepresentation." Smith v. J.H. Berry Realty Co., 528 So.2d 314, 316 (Ala.1988); Ex parte Leo, 480 So.2d 572, 574 (Ala.1985); and see, Country Side Roofing & Sheet Metal, Inc. v. Mutual Ben. Life Ins. Co., 587 So.2d 987, 991 (Ala.1991).
On appeal, the defendants maintain that Boros failed to prove that "but for [their] negligence he would have recovered on the underlying cause of action," because, according to the defendants, Boros failed to prove that he relied on any representations made by Palmer. After carefully reviewing the record, we conclude that the defendants are correct.
Our review of the record reveals not even a scintilla of evidence that Boros relied on Palmer's representations. In fact, Boros's own testimony establishes that he disbelieved Palmer's assertions and relied instead on assertions made by Shewmake. Boros testified[2] as follows:
"But, Monday or Tuesday nightI'm not sure whichshe [Palmer] came over to our hotel, the Mountain Brook Inn, to give us an offer, to have us sign an offer, and I said, `I'd like to talk to the owner-builder.' I said, `because I want to confirm what you say. I know that real estate agents have a habit of huffing and puffing. I want to confirm what you say, and most importantly, I want to make doubly sure there is no flooding.'
". . . .
"We didn't sign it [the offer] until after I had talked with the owner-builder, Jack Shewmake. I told her [Palmer] I wouldn't sign it. I thought it was an offer, not a binding sale agreement, and I told her that.
"I talked with Shewmake on the phone from my room at the Mountain Brook Inn for twenty-some minutes and I said, `I'm concerned because we've had some bad luck with houses. Is there flooding?' [Shewmake's answer]: `Oh, no, no, no, no. That was from construction.' [Boros]: `Is it a well built house?' [Shewmake's answer]: `Indeed, I build only good houses. It's all in here.' [Boros]: `Is it energy efficient?' [Shewmake's answer]: `Oh, yes, yes, yes.'"
(R. at 199-203; emphasis supplied.)
Additionally, this Court has stated:
"To claim reliance upon a misrepresentation, the allegedly deceived party must have believed it to be true. If it appears that he was in fact so skeptical as to its truth that he placed no confidence in it, it cannot be viewed as a substantial cause of his conduct.... The undisputed fact that [the plaintiff] was unwilling to accept the statement of [the defendant] *243 without verification is evidence that he did not rely on it."
Smith v. J.H. Berry Realty Co., 528 So.2d 314, 316 (Ala.1988). (Emphasis supplied).
As in Smith, we conclude that a factfinder could not have found that Boros relied on Palmer's representations, because, according to his testimony, "he was in fact so skeptical as to [their] truth that he placed no confidence in [them]," and because he "was unwilling to accept [Palmer's representations] without verification." Id. Because Boros failed to establish a necessary element of his underlying fraudulent misrepresentation claim, necessarily he failed to establish his legal malpractice claim. The trial court properly directed a verdict for the defendants.

The Recusal Issue
Boros argues that the trial judge erred in refusing to recuse himself from the case. According to Boros, the trial judge exhibited a "hostile, demeaning, and prejudiced or biased attitude" toward him. (Appellant's brief at 27-28.) Boros stresses several remarks made by the trial court and argues that these remarks establish prejudice directly resulting in the judge's entering a directed verdict for the defendants.
Initially, we note that a petition for a writ of mandamus is the proper method for challenging the denial of a motion for recusal. Ex parte Balogun, 516 So.2d 606 (Ala.1987). However, because this is a pro se appeal, we address the issue.
The law in this area is well settled. The Canons of Judicial Ethics apply to all judges in this State and have the force and effect of law. Ex parte Balogun, 516 So.2d at 609. Canon 3 C. states:
"(1) A judge should disqualify himself in a proceeding in which his disqualification is required by law or his impartiality might reasonably be questioned, including but not limited to instances where:
"(a) He has a personal bias or prejudice concerning a party, or personal knowledge of disputed evidentiary facts concerning the proceeding...."
(Emphasis supplied.)
This Court has interpreted Canon 3 C.(1) to impose a "reasonable person in the judge's shoes" standard. In Henderson v. G & G Corp., 582 So.2d 529, 530 (Ala.1991), this Court stated:
"The test for recusal is whether a person of ordinary prudence in the judge's position, knowing all of the facts known to the judge, would conclude that there is a reasonable basis for questioning the judge's impartiality."
However, a judge's recusal is not required by the "mere accusation of bias unsupported by substantial fact." Acromag-Viking v. Blalock, 420 So.2d 60, 61 (Ala.1982). Further, "there is a presumption that a judge is qualified and unbiased, and ... one alleging to the contrary has a substantial burden of proof." Henderson, 582 So.2d at 530. Additionally, "[a]dverse rulings during the course of the proceedings are not by themselves sufficient to establish bias and prejudice" on the part of a judge. Hartman v. Board of Trustees of the Univ. of Alabama, 436 So.2d 837, 841 (Ala.1983); Matter of Sheffield, 465 So.2d 350, 357 (Ala.1984).
We have examined closely each of the remarks made by the trial court. We conclude that Boros has failed to establish that the trial judge should have recused himself.

The Continuance Issue
Boros argues that the trial court improperly refused to grant him a continuance on the day of trial. Boros asserts that he was mentally and physically exhausted from preparing his own case and otherwise acting as his own counsel. He argues that the trial judge abused his discretion in refusing to continue the case.
Generally, parties acting pro se should be treated as parties represented by counsel are treated. See, Cofield v. McDonald's Corp., 514 So.2d 953 (Ala.1987); Hines v. City of Mobile, 480 So.2d 1203 (Ala.1985); Hubbard v. Montgomery, 372 So.2d 315 (Ala.1979); and Lockett v. A.L. Sandlin Lumber Co., 588 So.2d 889 (Ala. *244 Civ.App.1991). In particular, pro se litigants "must comply with legal procedure and court rules." Lockett, 588 So.2d at 890. Furthermore, "continuances are not favored and ... a trial court's denial of a motion for continuance will be upset only when a palpable or gross abuse of discretion has been shown." Scullin v. Cameron, 518 So.2d 695, 698 (Ala.1987).
Here, we note that this case began in October 1985. After every judge in the Tenth Judicial Circuit (Jefferson County) recused himself, this Court appointed Judge Billy C. Burney to handle the case. According to the defendants, Judge Burney attempted three times to have the case tried. Ultimately, Judge Burney retired before the case was tried, and Judge Robert Parker was appointed to handle the matter. Judge Parker granted Boros a continuance on May 28, 1991, and set the case for trial on October 21, 1991. On that trial date, Boros requested the continuance at issue here.
We find no abuse of discretion here. Boros had six years to prepare his case for trial. Further, the trial court was in a better position than is this Court to evaluate Boros's claims of mental and physical exhaustion and to rule on the motion for continuance.

The Punitive Damages-Mental Anguish Issue
Boros argues that the trial court erred in granting the defendants' motion in limine regarding punitive damages and damages for mental anguish arising from the defendants' alleged legal malpractice. The defendants argue that Boros failed to preserve the error alleged in this regard. Because we conclude that the motion in limine here was of the "prohibitive-absolute" type, we disagree.[3]
However, the defendants argue that any discussion of damages for mental anguish was properly disallowed because Boros alleged only professional negligence and breach of contract in his complaint. Also, the defendants argue that the facts of this case do not support any claim for punitive damages, and, therefore, that the trial court correctly excluded any discussion of punitive damages.
We agree with the following statement by the Court of Civil Appeals:
"There can be no recovery for emotional distress, where [the legal malpractice] does not involve any affirmative wrongdoing but merely neglect of duty, and the client may not recover for mental anguish where the contract which was breached, was not predominately personal in nature."
Dorsey v. Purvis, 543 So.2d 703, 704 (Ala. Civ.App.1989) (quoting 7A C.J.S. Attorney and Client § 273 (1980)).
Here, Boros presented no evidence that the alleged malpractice involved *245 "affirmative wrongdoing" and no evidence that his contract with the defendants was "predominately personal in nature." Further, we agree with the defendants that the facts of this case did not warrant any mention of punitive damages. "Ordinarily, punitive damages are not recoverable for breach of contract." Corson v. Universal Door Systems, Inc., 596 So.2d 565, 572 (Ala.1991). Also, some showing of fraudulent, malicious, willful, wanton, or reckless behavior or inaction must be made to support a claim for punitive damages in a legal malpractice case. Allowance of Punitive Damages in Actions Against Attorney for Malpractice, 13 A.L.R.4th 95 (1982 & Supp. 1992).

The Amendment Issue
Boros argues that the trial court erred in refusing him leave to amend his complaint on the day of trial to add counts alleging involuntary servitude and consumer fraud. The defendants argue that Boros had had five years to amend his complaint, and that he failed to explain to the trial court the pertinence and applicability of the additional counts.
The applicable version of Rule 15(a), Ala. R.Civ.P.[4], reads:
"A party may amend his pleading once as a matter of course at any time before a responsive pleading is served, or, if the pleading is one to which no responsive pleading is permitted and the action has not been placed upon the trial calendar, he may so amend it at any time within 30 days after it is served. Otherwise a party may amend his pleading without leave of court but subject to disallowance on the court's own motion or motion to strike of an adverse party; but such amendments shall be freely allowed when justice so requires. A party shall plead in response to an amended pleading within the time remaining for response to the original pleading or within 10 days after service of the amended pleading, whichever period may be longer, unless the court otherwise orders."
Although Rule 15(a) itself calls for liberal amendment, this Court has held consistently that "the grant or denial of leave to amend is a matter that is within the discretion of the trial court and is subject to reversal on appeal only for an abuse of discretion." Schoen v. Styron, 480 So.2d 1187, 1189-90 (Ala.1985); Ex parte Reynolds, 436 So.2d 873 (Ala.1983). Further, this Court has stated:
"Rule 15, [Ala.R.Civ.P.], is not carte blanche authority to amend a complaint at any time. Discretion rests in the trial judge to deny amendments for good cause. `[I]f the court determines ... that a party has had sufficient opportunity to state a claim or revise his answer to a complaint but has failed to do so, leave to amend may properly be denied.'"
Ex parte Tidmore, 418 So.2d 866 (Ala. 1982) (quoting Stallings v. Angelica Uniform Co., 388 So.2d 942, 946-47 (Ala.1980)). (Citations omitted.)
We conclude that Boros had had ample opportunity to amend his complaint before the day of trial. Clearly, the trial judge did not abuse his discretion in disallowing Boros's requested amendment here.
We pretermit any discussion of Boros's new trial issue because it is merely repetitive of the directed verdict issue. Also, we pretermit discussion of the expert witness issue because we find it meritless factually.
Based on the foregoing, we affirm the trial court's judgment entered on the directed verdict for the defendants.
AFFIRMED.
HORNSBY, C.J., and SHORES, HOUSTON and KENNEDY, JJ., concur.
NOTES
[1]  Although our holding on the directed verdict issue is dispositive of this case, we discuss the remaining issues because the plaintiff is acting pro se.
[2]  Because Boros was a pro se plaintiff, the trial court allowed him to testify in a narrative fashion.
[3]  The defendants cite State v. Askew, 455 So.2d 36, 37 (Ala.Civ.App.1984), quoting Charles Gamble, The Motion in Limine: A Pretrial Procedure That Has Come of Age, 33 Ala.L.Rev. 1, 16 (1981), for this proposition:

"[I]t is generally held that the granting of a motion in limine can never be reversible error. The non-moving party may repeat at trial, preferably out of the hearing of the jury, his request for permission to prove the contested matter. This offer of proof is required in order to isolate the error for appeal."
(Emphasis in original.)
The defendants neglect Dean Gamble's next sentence and his earlier distinction between "prohibitive-absolute" and "prohibitive-preliminary" motions in limine.
In the sentence following the above quote, Dean Gamble states, "Of course, this ability to bring up the matter a second time would not be available if counsel had requested and the judge had granted a prohibitive-absolute motion in limine." Gamble, supra, at 16.
Earlier in his article Dean Gamble distinguishes between "prohibitive-absolute" and "prohibitive-preliminary" motions in limine. Gamble describes the "prohibitive-absolute" motion in limine: "This motion and the order issued upon it being granted absolutely prohibit the opponent from questioning about or mentioning the evidence at trial in any form." Id. at 12. (Emphasis supplied.) Gamble says of the "prohibitive-preliminary" motion, "This motion and the accompanying order merely prohibit the opponent from offering, questioning about, or mentioning the evidence without first obtaining the permission of the judge outside the hearing of the jury." Id. (Emphasis supplied.)
We conclude that the motion in limine here was of the "prohibitive-absolute" type. Thus, Boros was not required to raise the issue again to preserve it for appellate review.
[4]  Rule 15(a) was amended effective August 1, 1992. The pre-amendment version would apply to this case.


Now that’s a vanity plate.

New York State is redesigning its official license plate — and residents are being asked to vote on the new look, Gov. Cuomo announced Monday.

And among the potential plates is one featuring the new Tappan Zee bridge — now officially named for Cuomo’s father, Gov. Mario M. Cuomo.

Three other designs prominently featuring the Statue of Liberty, while the fifth option includes the New York City skyline — Lady Liberty included — on one side and upstate wilderness on the other.

All choices but the bridge design also include the state’s motto, “Excelsior” — Latin for “Ever upward” and a favorite maxim of the governor’s.

Conspiracy theorists quickly took to Twitter to suggest the cards are stacked in favor of the design featuring Cuomo’s dad’s titular bridge.

“This indeed seems kind of rigged,” political polling wizard Nate Silver tweeted. “A bunch of near-identical Statue of Liberty designs will split the SoL vote.”

Another tongue-in-cheek tweeter demanded “ranked choice voting” for the plates.

A Cuomo spokesperson scoffed at the suggestion that the contest was skewed.

“At the end of this public process we anticipate that the design with the most votes will be accepted, and all the insane conspiracy theories will be rejected,” said spokesman Patrick Muncie.

Voters will be able to pick their favorite online or at the New York State Fair in Syracuse beginning Wednesday. Polls close Sept. 2.

The winner will hit the market in April 2020, the governor’s office said.

It will replace the state’s “Empire Gold” plates, which have been in circulation for almost a decade.

The new plate design is part of the state’s push to switch drivers over to reflective, easier-to-read plates, according to the governor’s office.

Starting in April, drivers with license plates that are 10 years or older will have to get new plates for $25 a pop — plus another $20 on top of that if they want to keep their old plate number.

Votes are being tallied online and at the New York State Fair beginning Wednesday. Polls close Sept. 2.

The winner will hit the market in April 2020, replacing the state’s “Empire Gold” plates, which have been in circulation for almost a decade.


Q:

Add an Accept and Decline Button on every Row

I'm trying to add a button on every row which I already did. When I click update which updates a certain field on the database it doesn't work. When the button is clicked it's redirected to the approve.php file.
<?php
$con=mysqli_connect("localhost","root","","rabco");// Check connection
if (mysqli_connect_errno())
{
echo "Failed to connect to MySQL: " . mysqli_connect_error();
}
$result = mysqli_query($con,"SELECT * FROM service_request");

                    echo "

                    Service ID
                    Service Type
                    Schuduled Date
                    Scheduled Time
                    Client Reference
                    Client ID
                    Admin ID
                    Special Instructions
                    Status
                    Approve
                    Decline

";

                    while($row = mysqli_fetch_array($result))
                    {
                    echo "
";
                    echo "" . $row['Service_ID'] . "	";
                    echo "" . $row['Service_type'] . "	";
                    echo "" . $row['Sched_date'] . "	";
                    echo "" . $row['Sched_time'] . "	";
                    echo "" . $row['Client_reference'] . "	";
                    echo "" . $row['Client_IDN'] . "	";
                    echo "" . $row['Admin_IDN'] . "	";
                    echo "" . $row['Special_instructions'] . "	";
                    echo "" . $row['Request_status'] . "	";
                    echo "<form action='approve.php' method='POST'>        <input type='hidden' name='accept' value='".$row["Service_ID"]."'/><input type='submit' name='submit' value='Approve'/></form>	";
                    echo "<form action='decline.php' method='POST'><input type='hidden' name='decline' value='".$row["Service_ID"]."'/><input type='submit' name='submit' value='Decline'/></form>	";
                    }
                    echo "
";
                    echo "
";

                    mysqli_close($con);
                ?>

approve.php
<?php
$link = mysqli_connect("localhost", "root", "", "rabco");
if(isset($_GET["Service_ID"]))
{
$row_sr=$_GET["Service_ID"];
$sql="UPDATE service_request SET Request_status = 'Approved', Admin_IDN =     '$_SESSION[Admin_ID]', Paid = 'Php 17,500', Balance = 'Php 32,500', Total_price     = 'Php 50,000' WHERE Service_ID = '$row_sr'";
$result=mysqli_query($sql);
mysqli_query($link,$result);
if($result==1)
{
header('location: adminpage-sr.php');
}
}
?>

A:

You are using method POST on your main file but in approve php you use $_GET ??
according to your approve.php file, you can change your button to :
"Approve	"


                              ‘.*
                               -:::
                                 .                            .2; 4.,?2
I                             OFFICE        OF      .~
               l"ms mT?RTL'EY e..' ~GEm=
                         ...,.i.,                                      .   ._.
                       AUSTIX.TEXAS

    Honorable .Jim.D; Bomeri : .: -..Opinioa     V-278 ~.
    County Attorae y, .           ‘. :
    Bell county,      .’       ,.:’ ._. Rer YU’glblllty of Per-
    Belton, Texas, .:      i ‘~.             430~18
                                                  ~005vioted.or
                                           .:Febrral.felony to-
                                          ’ qualify a8 tmatm
                                             or oommoa rohool
    Dear Sir: “ ’                            dlrtrlot. ‘A..’
                -          .,.
                             ~.
                we refer to Job setter         or reoeat -date 801
    knowledged by the Attorney      General oa June 16, 1947,
    ihere%a ydu~repueet.sn     oplaloa.of    this offlae ooaoer-
    ing the allglblllty .df a :perroa to be a frwtee       of a
    oomoa ~ohool distriof who hae been oomloted of a.,,,Feb-
    era1 felony. ..:...     ::                                     i

               -In your letter uad aroelleat brief thereoa,
    you pretreat,la substaaoe, the tollowlng
                                        ~. iaots:
                                                .,
                  A perBoa was eleoted truat6e’of a
            oomda aohool dlstrlot who was oonvloted
            aad e85tenoeU by .a Federal Dlstrlot Court
            oa thaw oouatty,eaoh of whloh lr’made a
            felony by Title 86; Beotloa 8003, 8820
            aad 8856, U.S.&A.,   the Federal UQuor
            Taxlag Aot, served four month@ la a Fed-
            eral prison and who paid (600.00 la ilaea
            pureuaat to mob seateaoe. On twb of the
            aouats he oould h&w been ooaflaed & max-
            lmm OS two yeam; oa the t+lrd oouat , a ‘.
            maximum of five yeare.
                   Title 18;Seotioa 541, U.S.U.A.,   de-       :
            flaee Veloayn au aa ,oSfeaeewhloh may be
              ualehed by death or Lmprlronmeat for .a
     -~..   term exoeeUlag  oae year.        .‘. ._~
                Artiole 8745; Se6tlon 1, V. C:S;, ~p*oviU-
    lng for the eleotloa of trusteee of oonmoa rohoal’bin-
    trlots and Sor their auallfloatlo~s reads, la part:
            * . . , ~Provlclhg 50 pereoa rhall ‘be quail-       1.
            ,Metl as truatee ualosrrhe 1s a property
                                        .
‘422
       HoaorablOJim D. Bawmc - Page S

             taxpayer la the dlrrtrlot-towbloh he 10
             elootod a~~3othorwlw a qualltied totsr
             la 8Uoh.dlrtrlot. . .Allw1oaaale88hall
             be rlllea by the ooanty board of trusteoa
             for the remalader              6r.tho term in rhloh
             the r a     o a a ooyo o ur 9.
                                          .-
                                           l”

                    Artlole =,~8eotiO5             1, 0oa8tltutloa pi Texa8,
       prorldes:'
                   "The Sollowlag ola8868 of pemoae
             8ball.aot be allowed to vote la thl8
             State, to-wit;
                       (1.'..                     -'-

                  *FoUrth: .&l per8oacleoavibtod of
            aay rolonjr,8ubjeot to 8Uoh loeptloar a8
          . the bglslattarc8hall ra$e." _            .,... .'
                   .Artlo&~ 8954, V. C; S..,pq?ride8,la part:
                   "The roiiarriagola89e8 of per8oa8
             ;ha&5ot    be 9atltled to roto,la thi8
                     . . .
                    1)
                         .-..   .   .

                   %. ' @I' er8oa9 oen@ited ofuty
             feloay oroept e base restored to foil olt-             -          :
             .;;zt8hjpand .rlght ~f,.8$fmge,'.or pardOa-
                           .
                   . Ia aoddrdaaoe 'dth thk prwl8loae~ of'.&tl-
       01s g745,.Seotloa 1, tie88 the perebn'lsa quallfl6d
       voter in the dl8trlot, he 18 sot ellglbl6or quallrled
       a8.a trU8tee Of a oommoa 8OhoOl dl8triOt; alldIrtiOle    '
       VI, 6eotioa 1 oi the Uoastltutloa prorlde$,'la 8Ub8tWiOe,
       that all perrroalr ooavloted of akq'tolow 8bell not-be-al-
       lowed to rote in thi8 State 8Ub,jeotto 8uoh eroeptloa8
       a8 the ti ielature ehall make. The Logialature ha8 kade
       a5 exooptfoa $a Art1010 8954 'rbiohproYlde8, la BUb8taaO0,
        that those person8 oowloted or emy felonyIho.have been
       ,reirtoredto full oltleeaabip aad right 6r Wfrage,'or
       pardoned d0 not tall within the prohlbltlo~e of hrtlo~o
       VI, &+otion* oi,the Ooarrt$tU~~~a.
                * 'Should th6 abow &ed T&a; #lawr~laoor&-
       atlng the.$angtmge, *ooavloted~of say $elonJ", bo ooa-
                           ,.

                                                                           \
                                                                               i
Honorable JimD.   ?naner-Page   3       ;'
                                         :

.8tr~ed to dS8franohlee also those persona who havb been
 ooavlcted 0s a Federal felony a8 well a8 thoee persons
who have been ooavloted of an offea8e defined a8 a rel-
 oay la the Texae lawe?:We think they 8hoUld be 86 ooa-
 8trueq. We oannot tibeorlbe to the~propositloa that
 the ftiIWr8 or our Oonstltutloa lateaded a tblng 80 an-
 omalous, lllogloal and unjuet a8 to say that%hose gullpy
 of oertala orlmes against.the lane-of the United State8
 and Bleter State8 are eligible or qualiiied to Vote la
 Texa8, while those guilty oftcertain orlmer agalaet the
 lane 0s thla etate are ineligible.
                                  ..
             In Harweil v8i Morrli, 143 5. W. (2d)‘tiOQ,
 an election ooqtest oaae deolded by the rlrmarilloCourt
 of Civil Appeals, wherein it was proven that a person
was ooavloted in a Federal oourt for vlolatlo'iYofthe
Harrleon Narootlo Aot, and hle pUti8hmeat was a88e8md
 at 81x months in jail whloh wa8 8USpeaded for two year8,
 it nae.hela.that 8uoh pereoa was aot qualiflea~to vote'
 in the primaryeleotloa beoauae under the provieloae of
 the applloablq Federal law he could have been oo&fined
 la the Federal pe@.teatlary by the Federal oourt. The
punlebment actually aesesrred by the oourt'opoa a trial
doe8 tit control the olaes 0s the otfease. R. Y. [zor-
den ~8. State, 135 Tex. Grim. Rep.., 438; Attoraey  Oea-
eral'e Opinion No.:~0-4121.
            In several other State8 iihlohhave ooaetl-
tUtional and~.utafUtoryprovl8loae similar to the Texas
laws herela quoted under Article VI, Seotloa'l'of the
Coaetltutloa, and Article 2954, it ha8 beea~held'that
a ooavlotloa of a felony in.a Federal ooU.rt,or a'oourt
of another State or country, reader8 that pereoa ooa-
vlotea lnellglble or 618qUali?$68 hlm~to vote .la sled-
pk$   held la the State.  See oltatloae la ,I49 A.L.B.
    .
            .Aooordingly; it 18 imr opinion, that a p&-
8oa who ha8 been oonviot,edot a Federal felony whereby
he is deprived of hla right to vote under LLrtlOleVI,
Seotloa 1, Con8titutloa of Texa8, and llrtlale.2954,    '
v. c. s., i8 laellglble or ai9q~liriea to 89X70 a8
truetee of a oommoa eohool 618trlOt by rea8Oa of the
provleloas of Article 2743, Seotloa 1, V. 0. S., uale88
and until he ha8 been reetored~to full oltlzenehlp and
'right 0s suffrage, or pardoned.
4         ~~~lrtuw or:fhe provlrloa8~of Artl-
    ole MU,     6eotlon1, Artlola 08543. 0. 8.,
    ~-4 brtlole VT. Seotloa 1, Con6titatlonar
    yaxacr, a-per8oa who ha8 been oonvlotea nf
    Q telory, FedOr8lQr &ate, l.8laellglble
     or not   ~wiri0a   to 8orw a8 trmteo of I
    0olpo5 #Ohooidi8triOt  Unle88 UU3 U&ii hd
    -8 bOO5 XV8tOXVd to 'fall OltiSOMhip urd
    tight 0r ourtrage, or pr(L0004.

                              sr
                                   dhe8tor1..Olll .1on.
@80tTB                             A881 8tant


NEXT UP FOR WAN-BISSAKA

After resting his legs and recharging the body during the international break, Aaron is almost certain to start on Sunday when the Reds face Sheffield United in the Premier League at 16:30 GMT.

His defensive prowess may be needed against a Blades side that is fifth in the table – one point above us - following an excellent start to the campaign.

MUTV’s live coverage of the game will begin at 15:00 GMT and you can also following unrivalled updates in the Official App throughout the course of the day.

Reading this in our app? If not, you might miss some exclusive features not found on ManUtd.com. Download the Official App here.


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The Delaware House last week voted 24-14 to approve a ban on “conversion therapy,” a widely discredited practice that purports to change sexual orientation from gay to straight.

Senate Bill 65, which prohibits the use of “conversion therapy” on LGBTQ youth in Delaware is sponsored by State Sen. Harris McDowell and State Rep. Debra Heffernan (D-Bellefonte). The measure was approved by the Senate last year and is expected to be signed into law by Gov. John Carney.

Delaware would join 12 other jurisdictions that ban the practice, including New Jersey, Nevada, California, Connecticut, Vermont, Illinois, Oregon, Hawaii, Maryland, Rhode Island, New York and the District of Columbia. New Hampshire is in a similar situation as Delaware, with its General Assembly passing legislation preventing the use of “conversion therapy” awaiting signature from its governor.

The Human Rights Campaign said in a statement that research has shown “conversion therapy” can result in numerous harmful risks, including decreased self-esteem, depression, substance abuse, homelessness and suicidal behavior. The practice has been condemned by the American Psychiatric Association, American Psychological Association and American Medical Association.

“For young people across Delaware, this legislation provides vital and potentially lifesaving protections from the damaging, dangerous and discredited practice known as ‘conversion therapy,’” said HRC National Press Secretary, Sarah McBride, in a statement. “While Delaware has made historic progress on LGBTQ equality, we can and must do more to protect LGBTQ youth from rejection, stigma and harm. SB 65 is a critical and significant step in the right direction.”

McBride is a native Delawarean, born in Wilmington. She worked as a campaign staffer for Delaware Attorney General Beau Biden’s 2010 campaign and Gov. Jack Markell’s 2008 campaign.

“We thank those members of the General Assembly who voted to protect LGBTQ children against the dangerous and harmful practice of conversion therapy, and especially prime sponsors Sen. Harris McDowell and Rep. Debra Heffernan and their legislative aides for their leadership,” said Equality Delaware’s Mark Purpura in a statement. “We look forward to Gov. Carney signing the bill into law promptly.”

Under the measure, a licensed medical practitioner who performs the practice could be fined or have their license revoked.


Electrical wiring is used to conduct electrical current in a variety of applications. For example, electrical wiring is used to conduct electrical energy for the purposes of power delivery. Electrical wiring is also used in data transmissions between electronics devices. Exceptionally important applications include the various power and data delivery uses in human related services, such as transportation (e.g., plane, automobile, etc.) and medical care.
Over time, wiring can deteriorate due to environmental conditions and ultimately degrade wire integrity. For example, excessive flex, chafing between adjacent wires, lack of strain relief, altitude, temperature, humidity, and/or acceleration can jeopardize the integrity of the wire. When a wire breaks, open circuit conditions are created that contribute to a loss of signal integrity, component failures, or even catastrophic fires. Due to the intermittent nature of most of cable failures, these problems are often difficult to detect and more difficult to repair.
Hard faults (i.e., those fault where a wire has completely failed) are quickly detected using common circuit testing equipment. Intermittent faults, however, are much more difficult to detect because the faults are generally only detectable when the wire is live (e.g., operational). Time domain reflectometry can detect intermittent events in live wires by monitoring the wire over a period of time. For example, a time domain reflectometer (TDR) may transmit a relatively short rise time pulse along a conductor. If the conductor is of a uniform impedance and properly terminated, the entire transmitted pulse is absorbed in the far-end termination. Thus, no signal is reflected towards the time domain reflectometer. Impedance discontinuities in the wire, however, cause a portion of the incident signal to be reflected back towards the source. The intermittent fault and even the location of the fault may be determined from the reflected signal. Accordingly, if the faulty wire is monitored over some period of time with the time domain reflectometer, a fault in the wire is likely to be detected by the time domain reflectometer.
Detection of wire faults is possible after the fault occurs. However, detection after the fact may be too late. For example, an aircraft with aging deteriorating wires may begin to experience intermittent faults in the wiring. TDR testing of the wires may be performed as part of maintenance on the aircraft while the aircraft is not in-flight to repair/replace faulty wires. But, intermittent faults are likely to occur while the aircraft is in flight, jeopardizing the safety of the people on board.


David Sax

Coming off four years in New York and my fifth cross-country move in the books, I’d yet to wipe the pizza sauce from my chin when I stumbled into the halls of public service -- Phoenix City Hall, to be exact.

It was November 2014 and to some fanfare, the city was hosting its Plan PHX Summit, the formal unveiling and public review of its General Plan Update, a wide-ranging document intended to shape various sectors of urban and economic development in the decade to come. It would be approved by more than 75 percent of voters in a general election held the following August.

The summit gave members of the public the opportunity to engage with elected officials, city managers, community leaders, observe panel discussions and give input. A far cry from my experience in New York as researcher and speechwriter to the director of a public policy institute on Manhattan’s Upper East Side.

In NYC, you're limited to your title

There I rubbed shoulders with foreign and civic leaders, Supreme Court justices, renowned academics, former New York City mayors and one legendary songwriter. But my encounters were just that -- encounters. Nice people, many of them, but New York is a place where, to borrow the phraseology of historian Marvin Meyers, the “basic principles and institutions [are] firmly settled.” In such an unforgiving climate, most can only dream of advancing in New York beyond the limits of that title underneath their name on their LinkedIn profile.

My first brushes with Phoenix’s civic leadership at the Plan PHX Summit told a different story, violating my preconceptions like a close encounter with an alien kind. You’re telling me I can actually approach these people? Now we’re chatting about urban policy? Now you’re asking me questions? I came with no fixer. No ace up my sleeve, nothing profound or immediate to draw the ear of Phoenix’s power brokers.

Over the past two years, I’ve gotten to know many of these influencers and decision-makers, and have found in the city’s leadership affirmation of my first impressions. There I stood at the Plan PHX Summit, and now I stand, a beneficiary of the supportive culture that has shaped our history and will elevate our future.

Phoenix has accomplished great feats

To some degree, Phoenix and Arizona have always been this way. Our modern state was shaped by intrepid statesmen and women whose creativity and entrepreneurship in their unlikely desert setting set the foundation for our current, thriving metropolis. Consider monumental feats of statecraft such as the Central Arizona Project and, in more recent years, the creation of the Translational Genomics Research Institute (TGen) alongside the transformation of Arizona State University into the New American University.

These are remarkable products of our uniquely open climate, part of a culture of connectivity that continues to inspire leaders today.

This week, PBS NewsHour is featuring the story of one such result with their national broadcast of a two-part series celebrating the work and impact of the Southwest Autism Research & Resource Center (SARRC) and First Place AZ. These sister nonprofit organizations owe much of their success to the supportive community that grew up around them and that they cultivated through public-private-charitable collaborations.

Thanks to Phoenix’s connective, pioneering spirit, First Place, SARRC and a host of partnering organizations are turning the dream of jobs, friends, continuing education and new housing options into reality for adults on the autism spectrum and others with special abilities.

We enable problem-solvers

This spirit is enabling, within the wider community, the incubation of generations of dreamers, problem-solvers and entrepreneurs and must be recognized as a valuable asset to be embraced and nurtured as we endeavor to raise the profile of Phoenix, both regionally and on a global scale. At the same time, it is imperative we confront pervasive structural inequalities that persist along socio-economic fault lines.

Gaps in education, employment, criminal justice, housing and health care sadly exist and prevent many individuals living in our state’s marginalized communities from engaging in this open exchange of ideas.

Take my inside/out perspective of our beloved city as an offer of encouragement against the backdrop of recent events, the contentious tone of the presidential cycle and every other expression of unrest sowing seeds of uncertainty in America today. Progress is being made and the momentum to act is in our favor.

Our ability to look at our city in the mirror and say, we’re not perfect, but the possibilities are endless -- that is an uncommon gift.

David E. Sax is an account manager with the public relations and marketing group, DRA Collective. He previously worked in New York City as researcher and speechwriter to the director of the Roosevelt House Public Policy Institute.


When director Assia Boundaoui begins investigating the FBI surveillance of her family’s Arab American neighborhood, one of her mother’s friend’s lovingly calls her a “troublemaker.” But with the digging that leads to the startling and effective documentary “The Feeling of Being Watched,” the journalist catches the eye of some powerful people and finds herself enmeshed in that trouble.

Boundaoui brings her skills as a reporter for the BBC, NPR, Al Jazeera, VICE and CNN back to her hometown of Bridgeview, Ill., to examine why the Muslim community in the Chicago suburb was a target of the FBI’s suspicion in the 1980s and 1990s, and if their mosques, homes and schools are still under watch today.

Fear and shock waft off “The Feeling of Being Watched,” and it evokes a few genuine gasps at the audacity of its villains. You feel like you’re watching a ’70s conspiracy thriller, but this is today and it’s nonfiction. Boundaoui uses home videos, archival footage and contemporary interviews to tell her story. Twitchy editing and surveillance videos work well to increase the tension.

“The Feeling of Being Watched” is focused and thorough, but it takes the time to place its events in a larger context. Expanding its scope beyond Bridgeview and Islamophobia, it looks at the larger question of how the United States government has targeted minority groups throughout its history.

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‘The Feeling of Being Watched’

Not rated

Running time: 1 hour, 27 minutes

Playing: Starts June 21, Laemmle Music Hall, Beverly Hills

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calendar@latimes.com

@LATimesMovies


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465 N.W.2d 680 (1991)
Claudia McCLAIN, as Trustee for the heirs and next of kin of Michelle Elizabeth McClain, decedent, petitioner, Appellant,
v.
Bridget J. BEGLEY, petitioner, Appellant,
Christine S. Meyers, Defendant,
Altra Auto Rental, Inc., a division of Agency Rent-A-Car, Inc., Respondent. and
ALTRA AUTO RENTAL, INC., A DIVISION OF AGENCY RENT-A-CAR, INC., Respondent,
v.
FIREMEN'S FUND INSURANCE COMPANY, Defendant,
Allstate Insurance Company, petitioner, Appellant.
No. C1-89-2206.
Supreme Court of Minnesota.
February 15, 1991.
Eric Magnuson, Andrew M. Walsh, Rider, Bennett, Egan & Arundel, William M. Hart, R. Gregory Stephens, Meagher & Geer, Minneapolis, for appellants.
Scott W. Johnson, James A. O'Neal, Paul W. Heirling, Faegre & Benson, Bonita J. Girard, Bassford, Hecht, Lochhart & Mullia, Minneapolis, for respondents.
Heard, considered and decided by the court en banc.
*681 YETKA, Justice.
This case is here on appeal from the court of appeals, which reversed summary judgment awarded by the trial court on motion of plaintiff McClain. We reverse the court of appeals and reinstate the judgment of the trial court.
Petitioner McClain brought an action against Altra Auto Rental, Inc., Bridget Begley, and Christine Meyers for the wrongful death of her daughter, Michelle McClain. The death resulted from a car accident involving a car rented by Michelle McClain, Begley and Meyers from Altra. Altra insured the rental car through a plan of self-insurance under the no-fault act. Allstate insured Begley, the driver of the rental car at the time of the accident, through her parents' liability policy. After McClain commenced suit, Altra brought a declaratory judgment action against Allstate to determine priority of coverage.
In January 1988, McClain moved for partial summary judgment, claiming that Altra's self-insurance plan provided primary coverage to the extent of the $500,000 liability limits stated on the certificate of insurance. The motion was granted on April 7, 1988. Altra's petition for discretionary review was denied by the court of appeals. Thereafter, the parties stipulated to damages and the entry of judgment with the express understanding that Altra would appeal the summary judgment decision.[1]
The court of appeals reversed the trial court, holding that, in the absence of express liability coverage limits in a self-insurance plan, a self-insurer is liable only for the statutory minimum amount of coverage. McClain v. Begley, 457 N.W.2d 230 (Minn.App.1990). Respondents McClain and Begley appealed. This court granted respondents' petition for review.
This case arises from an automobile accident on March 30, 1986, in Missouri. Michelle McClain, Bridget Begley, Christine Meyers, and Shannon Murphy, all college students, planned a spring-break trip to Padre Island, Texas. Prior to the trip, Murphy contacted Altra about renting a car. An agent of Altra told Murphy that, to qualify for the least expensive rate, she must rent the car as a replacement for an insured, but out-of-service car. Murphy told the agent that McClain had an out-of-service car insured through Firemen's Fund Insurance.
On March 21, 1986, the Altra agent delivered the car to Murphy and Meyers. Meyers signed the rental contract which stated that Altra did not provide liability coverage on the car and that the car was to be insured by the lessee. A few days after the rental contract was signed, the agent filled in the rental form with a fictitious policy number, agent, and agency phone number. On March 30, 1986, as the women were returning from the trip, Begley fell asleep at the wheel and collided with a car parked on the shoulder of an interstate in Missouri. McClain was killed in the collision.
Altra insures its cars through a plan of self-insurance. As a self-insured entity, Altra completed and filed the forms developed by the Department of Commerce. One of the forms included a question and an answer which we repeat as follows:
12. List all excess insurance applicable to motor vehicle accidents, with name(s) of insurer(s), policy number(s) and limits of liability.
    Lexington Insurance Company
    Policy No. 552 8742
    Effective: 12-31-86/87
    Amount of Insurance: $2,500,000 in
    excess of $500,000 S.I.R.
    [Self-insured Retention]
The above question and answer was part of a form entitled "REQUEST FOR EXEMPTION FROM INSURING LIABILITIES UNDER THE MINNESOTA NO-FAULT AUTOMOBILE INSURANCE ACT."
The parties to the lawsuit entered into a stipulation which, in substance, provided the following: Altra owned the car in *682 which McClain was killed. The negligence of Begley, the driver, was the sole cause of McClain's death. The total damages for the death are $155,000. If the trial court orders are upheld on final appeal, Altra will pay $155,000 to plaintiff. If Altra's obligation is limited to the statutory minimum, Altra will pay $30,000 and Allstate will pay $100,000.
As a result of all this pre-appeal maneuvering, the parties agree and have submitted to the court the following:
1. The question of the applicability of Minnesota's car owner's responsibility act is not raised and is thus not before this court.
2. Altra sought protection of its fleet under the Minnesota no-fault act.
3. Altra, through its rental agreements, had attempted to shift responsibility for all liability coverage to the lessees of its cars and absolve itself of any liability. This has been held illegal by the Minnesota Department of Commerce.
4. Thus, the sole issue for this court to decide involves the interpretation of the no-fault insurance act, Minn.Stat. §§ 65B.41-65B.71 (1990), and its applicability to self-insurers. Interpretation of statutes is a question of law. Hibbing Educ. Ass'n v. Public Employment Relations Bd., 369 N.W.2d 527, 529 (Minn.1985). The parties have stipulated to the facts and to the amount of damages. This court thus must determine whether the court of appeals erred in its application of the law to the facts of this case. This court is not bound by the decision of the court of appeals. A.J. Chromy Constr. Co. v. Commercial Mechanical Serv., Inc., 260 N.W.2d 579 (Minn.1977).
The Minnesota no-fault act imposes a duty on the owner of a motor vehicle to maintain "a plan of reparation security * * * insuring against loss resulting from liability imposed by law for injury and property damage by any person arising out of the ownership * * * of the vehicle." Minn.Stat. § 65B.48, subd. 1. The owner has the choice of self-insuring or buying an insurance policy. The act states five purposes: to relieve the "severe economic distress of uncompensated victims," to prevent overcompensation, to provide prompt payment, to reduce litigation, and to correct abuses of the tort liability system. Minn.Stat. § 65B.42. The obligations imposed on self-insurers should reflect those goals.
Self-insurance is the functional equivalent of a commercial insurance policy. The law of workers' compensation treats self-insurers no differently than those who insure by commercial policy. The purpose of either form of insurance is to compensate victims appropriately. The certificate filed with the commissioner is the functional equivalent of an insurance policy.
While under the Minnesota no-fault statutes, Minn.Stat. § 65B.49, subd. 3(1), any insurer is required to have liability coverage of $30,000 as a minimum, Altra made a deliberate representation to the Department of Commerce to provide coverage in excess of that amount, namely, $500,000. Based on that representation and other data supplied to the Department of Commerce, Altra was accepted as a self-insured. It should thus be held to the representations that it made.
The cases and precedent cited in the briefs are simply not applicable to the unique facts of this case, for the decision in this case is based more on equitable estoppel principles than on any other.
The court of appeals is thus reversed and judgment of the trial court reinstated.
COYNE and GARDEBRING, JJ., took no part in the consideration or decision of this matter.
SIMONETT, Justice (concurring).
I join in the majority opinion but my reasoning, only sketched out here, is different.
A Minnesota car owner can satisfy the requirements of our No-Fault Act by purchasing a liability policy with limits of $30,000 for bodily injury to any one person, $60,000 for any one accident, and $10,000 *683 property damage. Minn.Stat. § 65B.49, subd. 3(1). These limits, of course, do not limit the car owner's tort liability; a car owner remains liable for any tort exposure over the policy limits. By purchasing minimum coverage, a car owner in this state keeps his car registered, keeps his driver's license, and avoids criminal penalties. Minn.Stat. § 65B.67. Policy limits measure the amount of protection afforded the insured. Also, policy limits, whether the statutory minimum or higher, are significant in determining when other auto liability policies covering the driver (if such is the case) will come into play.
A self-insurer must approach these risk management problems a little differently than a regular policyholder. The self-insurer's exposure is its tort liability exposure, which the self-insurer may limit by purchasing an excess policy for claims against it over and above a certain amount. In relation to this excess policy, the self-insurer's underlying personal exposure is its self-insured retention. This self-insurance, by statutory definition, is a plan of reparation. Minn.Stat. § 65B.43, subd. 15. Consequently, there is no need for a self-insurer to file any detailed plan. See Anderson v. Northwestern Bell Tel. Co., 443 N.W.2d 546, 549 (Minn.App.1989) ("[S]elf-insureds are not required to have the carefully worded, highly specific policy provisions, declarations and coverage limits required of insurance companies.").
Ordinarily, a self-insured retention operates much the same as stated limits in a regular insurance policy. But not necessarily. Arguably, a self-insurer may, with respect to certain persons, place limits on its self-insured retention which are lower than the self-insured retention. The self-insurer will try to do this so that if there are other auto insurance policies also covering the driver of the car, such other insurance will no longer be excess but will then apply. In this case, for example, the driver of the rented car, Bridget Begley, had her parents' auto policy affording her coverage, and the question arises as to when this other insurance takes over.[1]
In this case Altra, Inc. (the Rental Agency) purchased an excess policy with coverage of "$2,500,000 in excess of $500,000 S.I.R." (the initials refer to Self-Insured Retention). This excess policy, however, contained a "Renter's Exclusion" endorsement which appears to exclude claims such as McClain's arising from accidents while the automobile is being operated by a lessee under a rental agreement.[2]
I understand the Rental Agency's position to be that it is self-insured for claims arising when its own employees are driving its cars up to $500,000, after which the excess policy takes over for the next $2.5 million; but that as to claims arising where a lessee is operating the rented vehicle, while the personal exposure, if any, of the Rental Agency as owner of the rented car is limitless, the Rental Agency's self-insurance exposure for the lessee-operator is the minimum statutory limits under the Minnesota No-Fault Act.
The issue then becomes: To what extent, if any, does the grant of self-insurance authority to the Rental Agency provide protection to persons operating the Rental Agency's automobiles as lessee-operators?
*684 It seems to me there are two possible ways in which the Rental Agency, as a self-insurer, might possibly provide coverage to its lessee-operators.
One possibility is that the self-insurer contracts with the lessee to protect the lessee the same as if the lessee had purchased a standard auto liability insurance policy for the rented car. Presumably the Rental Agency could place limits on this contractual coverage by so stating in the rental contract. The problem with this arrangement, however, is that the Rental Agency is a self-insurer, not an insurer. I doubt if a self-insurer is authorized to issue contracts of insurance.[3]
The second possibility is to treat the self-insurer as if it had purchased a policy of auto liability insurance for each of its vehicles with itself as the named insured. Such a policy, if purchased, would contain an omnibus clause extending coverage to permissive drivers as additional unnamed insureds.[4] This seems to me the better approach and more in keeping with the concept of self-insurance. This brings up, however, another question: Can omnibus coverage limits ever be less than the coverage limits for the named insured?
Courts in other states appear to differ on this. For example, in Balboa Ins. Co. v. State Farm Mut. Auto. Ins. Co., 17 Ariz. App. 157, 496 P.2d 147 (1972), a rental car agency had purchased a liability policy with $100,000/300,000 coverage but with an endorsement limiting coverage for lessee-operators to $10,000/20,000, the statutory minimum. The court held these differing limits were permissible, relying on Rocky Mountain Fire & Cas. Co. v. Allstate Ins. Co., 107 Ariz. 227, 485 P.2d 552 (1971). Compare Southern Home Ins. Co. v. Burdette's Leasing Service, Inc., 268 S.C. 472, 234 S.E.2d 870 (1977), where the South Carolina Supreme Court held that an auto rental agency's self-insurance covered permissive users including lessee-customers, and that the self-insurance "substitutes for an insurance policy to the extent of the statutory policy requirements." Id., 234 S.E.2d at 872 (emphasis added).
Wisconsin has a so-called "omnibus statute" which provides that coverage applicable to the named insured is to be extended to any person using the motor vehicle. Wis.Stat. § 632.32(3), successor to Wis. Stat. § 204.30(3) (1967). In Smith v. National Indemnity Co., 57 Wis.2d 706, 205 N.W.2d 365 (1973), the car rental agency had liability insurance with coverage for itself, as the named owner insured, of $100,000/300,000; an endorsement to the policy, however, limited coverage for renters to $10,000/20,000. The Wisconsin Supreme Court held, applying its omnibus coverage statute, that the car rental agency could not have less coverage for its lessee-customers than for itself.
In National Indemnity Co. v. Manley, 53 Cal.App.3d 126, 125 Cal.Rptr. 513 (1975), the rental agency's liability policy contained *685 an endorsement that it was excess over other insurance. The intermediate appellate court held that under the California Insurance Code an insurer could provide in its policy for only minimum statutory coverage for permissive users, but that in this instance the policy clause attempted to exclude permissive users from any coverage whatsoever and, hence, was void. 53 Cal. App.3d at 133, 125 Cal.Rptr. at 513. The court, therefore, ruled that permissive users would be entitled to coverage in the same amount as that specified by the policy for the named insured. See also Globe Indemnity Co. v. Universal Underwriters Ins. Co., 201 Cal.App.2d 9, 17-18, 20 Cal. Rptr. 73, 78-79 (1962).
I think arguments can be made both for and against restricting omnibus coverage to minimum statutory limits in cases where a self-insurer is engaged in the business of short-term car rentals.[5] One would need, however, a better record than the one we have here to resolve this question. The record does indicate that the Minnesota Department of Commerce expects a self-insured rental agency to provide liability protection for its lessee-operators, and there is some indication that this coverage can be limited to the statutory minimum.[6]
On this record and for this case, I take the following position. The Rental Agency affords protection to its lessee-operators as if it had omnibus coverage. Car rental companies are a special case of self-insurance. The Rental Agency may limit its omnibus coverage  at least for lessee-operators  to the statutory minimum and it may do this in the rental contract. In this case, however, the Rental Agency went further and attempted to deny all omnibus coverage. This attempt was void.[7] Therefore, left in place for omnibus coverage are the same "limits" for residual liability coverage as for the named insured, see Manley, supra, which in this case is either unlimited or $500,000, depending on how the renter's exclusion is construed. In any event, for the purposes of this case, the Rental Agency is responsible under the stipulation of the parties to pay $155,000.
I think the $500,000 self-insured retention refers to residual tort liability, not to first party no-fault benefits, and, therefore, no-fault economic loss benefits are the statutory minimum.
KEITH, Chief Justice (concurring).
I join in the concurrence of Justice Simonett.
*686 TOMLJANOVICH, Justice (concurring).
I join in the concurrence of Justice Simonett.
NOTES
[1]  The parties stipulated to damages of $155,000, noting that if the summary judgment decision is reversed, then Altra will pay the statutorily mandated amount, $30,000, and Allstate will pay the limit of its secondary liability, $100,000. Thus, were the summary judgment decision reversed, McClain's estate would be uncompensated for $25,000.
[1]  The trial court ruled that Altra's self-insurance was primary vis-a-vis Allstate's policy issued to Bridget Begley's parents and affording coverage to Bridget Begley as driver of the rented car. This ruling was not appealed. Altra appeals only the issue of how much of its self-insured retention must be paid on the wrongful death claim before Allstate's policy must pay.

This case has another twist. Altra, Inc., is a special division of Rent-A-Car and rents to persons whose own cars are disabled. Altra assumed that the customer's own policy would protect the customer under his or her temporary substitute coverage. Under this arrangement, Altra figured it could rent at a more competitive rate, and, indeed, the four women in this case found Altra's rental rate to be the cheapest. Unfortunately for Altra, the Commerce Department struck down this arrangement. See footnotes 6 and 7, infra.
[2]  Thus, while a car is out on rental, the excess policy does not provide coverage to either the Rental Agency or the lessee-operator, and the $500,000 retention figure is irrelevant. Hence the Rental Agency's self-insurance for this rental risk is unlimited except as tort law limits tort liability and as perhaps auto liability insurance policies issued to others may come into play.
[3]  Compare Nathanson v. Hertz Corp., 183 Cal. App.3d 78, 227 Cal.Rptr. 799 (1986), where Hertz, as a self-insurer, had a provision in its rental contract stating, "Lessor provides liability coverage for customer * * * in accordance with the standard provisions of a Basic Automobile Liability Insurance Policy, as required in the jurisdiction in which the Vehicle is operated * * *." The contract then went on to specify limits of $100,000/300,000, which were more than the statutory minimums of $15,000/30,000. 183 Cal.App.3d at 80 n. 2, 227 Cal.Rptr. at 800 n. 2. The appellate court pointed out that Hertz, by contract, was "agreeing to protect its rental customer against his or her negligence that causes damage to a third person." 183 Cal. App.3d at 82, 227 Cal.Rptr. at 802 (emphasis in original). The court held, for purposes of a bad faith claim against Hertz for the manner in which it settled a claim, that the higher contractually declared limits governed. The court noted that Hertz was not authorized to act as an insurer, but this did not prohibit plaintiff's bad faith claim under California's Unfair Claims Practices Act.
[4]  Minn.Stat. § 65B.43, subd. 5, lists persons who are deemed an insured under a reparation plan even though not identified by name, and permissive users are not included. Apparently, however, the Minnesota Department of Commerce will not approve an auto insurance policy for sale in this state unless it contains a "permissive user" provision which extends coverage under the policy to anyone using the car with the permission of an insured. See affidavit of Assistant Commissioner O'Malley. Whatever the value of this affidavit, I take judicial notice that auto policies issued in this state contain an omnibus clause.
[5]  No Minnesota case deals with this issue. Unlike Wisconsin, our state has no "omnibus statute." On the omnibus clause generally, see Dairyland Ins. Co. v. Munson, 292 Minn. 141, 193 N.W.2d 476 (1972); Milbank Mut. Ins. Co. v. U.S. Fidelity, 332 N.W.2d 160 (Minn.1983).
[6]  In its brief the Rental Agency says it now provides the statutory minimum coverage for residual tort liability to its lessee-customers and that this action has been approved by the Attorney General. This information is not in the record and cannot be considered by us.

Nevertheless, we do know that in the summer of 1987 (after the McClain accident), the Department of Commerce conducted an administrative hearing on the legality of the clause in Altra's rental contract purporting to place sole responsibility for liability insurance coverage on the lessee customer. In September of that year the Commerce Commissioner ruled that the Rental Agency was in violation of the No-Fault Act because "it has not provided residual liability coverage * * *" and because it attempted to "eliminate by contract the above coverages required by Minnesota law."
The Rental Agency was given 45 days to change the wording in its rental contracts to comply with the Commissioner's decision. The record indicates that the Rental Agency did not appeal this decision but not whether it chose to comply. While the reasoning of the Commissioner is obscure, nothing in the Commissioner's decision suggests that compliance would require more than the minimum limits mandated by the No-Fault Act.
[7]  Altra's rental contract, it will be recalled, said, "If customer's insurance fails for any reason to afford coverage, customer shall be solely responsible." The administrative law judge ruled that this contract clause flatly contradicts Minnesota law which requires a car owner (except one who leases its car for 6 months or more) to be legally responsible for the car. See Minn.Stat. § 65B.43, subd. 4 (dealing with leased cars), and Minn.Stat. § 170.54 (the Safety Responsibility Act). Implicit in this decision, it seems to me, is that the self-insurer must provide omnibus coverage in at least the minimum statutory amounts for residual tort liability.