Arrested For DUI?
The experience of a drunk driving
arrest begins at the point where a cop notices your
vehicle. It may be that you were speeding or weaving,
but cops are actually trained in a dubious
"science" of detecting drunk drivers. The
training includes directions to stop your car for such
mundane activities as gripping the steering wheel too
tightly, making wide turns, and failing to stop exactly
at the limit line for a stop sign or red light. They get
this nonsense from the National Highway Traffic Safety
Administration (N.H.T.S.A), an agency known for its
indiscriminate pursuit of incompetent bureaucracy. It's
all in some videos and brochures for cops called Guide
for Detecting Drunk Drivers at Night ,(a
fairly accurate rendering of the N.H.T.S.A guide), and {NEED LINK} The
Visual Detection of DWI Motorists
and The Detection of DWI Motorcyclists.
Then again, you may have been stopped at a drunk driving
checkpoint roadblock. Did you know that there's no law
that says you had to roll down your window? (For
those who may be reading this in order to prepare for
the possibility of a drunk driving arrest, please note
that if the cop orders it, you do have to roll your
window down. But that gives your lawyer the ability to
argue later that the order was not legal.) Did you
know that the flashlight the cop may have stuck through
your open window may have had the ability to flash him a
red, yellow or green light that indicated whether or not
you had alcohol on your breath? N.H.T.S.A has published
some standards to be used by law enforcement in
conducting drunk driving roadblocks. You can read them
in {NEED LINK}The
Use of Sobriety Checkpoints For Impaired Driving
Enforcement. California case law says
that not everything has to be strictly complied with.
But note the last sentence at the end of the last big
paragraph in Appendix A, which says,:
A motorist who wishes to avoid the checkpoint by
legally turning before entering the checkpoint area
should be allowed to do so unless a traffic
violation(s) is observed or probable cause exists to
take other action. The act of avoiding a sobriety
checkpoint does not constitute grounds for a stop.
Good lawyers use this statement of official policy to strike
down arrests where the cops stopped the driver only
because he or she utilized the required escape route.
Once the cop detected the odor of alcohol on your breath
you became a DUI suspect. That began the process of
gathering evidence to convict you with. He probably
started out with, "Have you had anything to drink
tonight?" He already knew the answer. If you didn't
tell him then how much you drank, that was probably his
next question. If you answered, "I only had two
beers, officer", he made mental note that you could
be lying.
Whatever your answer was, he or she probably then asked
you to step out of the car, and asked to see your
driver's license and registration. He or she observed
your demeanor as you got out of the car and looked
through your wallet, making mental notes of your
coordination and level of comprehension. If you
"fumbled through your wallet looking for your
driver's license" that went into the police report.
Likewise, leaning against the car, stumbling, not
responding to the demand to get out, and anything else
but perfect performance. You can see at this point that
being a person who just doesn't take orders well puts
you at distinct disadvantage.
All this time the cop has also been looking at your eyes
to see if they're "bloodshot and watery".
Amazingly, whether they were bloodshot and watery or
not, this "fact" always gets written in
the police report. As with everything that occurs, it's
your word against him or her, and they know that. But
don't worry, good lawyers can break down the lies into
bits and pieces, and show the jury that the pieces just
don't fit.
Then came more questions like, "When did you last
eat?", and "When did you last sleep?".
The cop will later testify that he asked these questions
to determine of your apparent lack of coordination could
be caused by something other than alcohol. But what he
or she was actually doing was asking you questions to
gather evidence to use against you, and doing it before
you were formally arrested so that Miranda advice
would not be required. (Although on TV and in the
movies, cops recite the Miranda mantra for
everyone they arrest, in real life that's only done when
(1) you've been formally place under arrest, and (2) the
cops want to ask you questions, and (3) they want to use
your answers against you.)
After that the cop had you do some Field Sobriety Tests
(FST's). Now this is where things got decidedly whacko
because there's no objective scoring of these
"tests". Instead they're graded in an entirely
subjective manner - you just can't pass them if the cop
has already made up his mind that you're a drunk driver.
Once again, he or she is just gathering evidence to
convict you with. But believe it or not, this is a good
thing because good lawyers know how to trip up a cop
over the inconsistencies. We know that the cop will
later testify that he or she didn't make his mind about
your state of sobriety until after the last test was
completed.
That knowledge lets us recite all the other symptoms you
exhibited - bad driving, odor of alcohol on the breath,
stumbling, fumbling through your wallet, leaning on the
car, bloodshot and watery eyes, inability to say the
alphabet, inability to walk a straight line - everything
up to the last FST, and get the cop to agree that none
of it is conclusive. None of it means that you're a
drunk driver. None of it really matters!
We can do this because we know that the cops will take
an oath to tell the truth, then testify to lie after
lie, predictably, every time. They do that because
they're trained to do it that way. They're trained to
gather evidence to use against you and trained to claim
that they were really just investigating, trying to
determine if you were too intoxicated to drive. See what
I mean about picking their story apart in bits and
pieces?
Finally, right before your arrest the cop may have asked
you to blow into a handheld breath analyzer, a thing
called a Preliminary Alcohol Screening Device (PAS). If
the cop didn't advise you that you are not required to
blow into it, he committed a crime under California
Vehicle Code section 23612, subdivision (I), and section
40000.1. (Section 23612(I) requires the advice and
section 40000.1 makes it an infraction to not do
anything the Vehicle Code requires.) But more important,
a good lawyer can use the failure to advise of the right
to refuse this test to get the test results thrown out
as a nonconsensual search. This approach is based upon
the simple idea that the cops can't claim you consented
to a search of your breath when they didn't tell you had
the right to refuse that search.
In many counties the PAS result isn't admissible anyway
because the methods used to operate the device usually
lack the technical requirements needed to overcome a scientific
foundation objection. But there is no legal
authority that makes it inadmissible statewide. Several
local appellate courts, most notably Los Angeles
County's, have ruled it inadmissible, but for political
reasons having nothing to do with justice, none of these courts
ordered their decision published. So it's a decision to
be reached by the local judges of each county, based
upon the skills and knowledge of the attorney handling
your case.
You'd be amazed how many times we hear, "I passed
all the tests". If you got arrested, you flunked
them, otherwise you wouldn't have been arrested. But
like it says above, it's more likely that the decision
was made to make an arrest long before you did the
FST's.
Soon after your arrest you may have been advised of the
requirement that you submit to a blood test. (Since January 1, 1999, the urine test has been
offered only when both blood and breath testing are
unavailable. I say "may have" because in
some counties, like Orange County, the routine is to
simply tell the arrestee that he or she needs to give a
blood sample. They deny people he choice because blood
provides more direct evidence of blood alcohol level
than breath does.
In any event, if you decline the offer of a chemical
test you'll be formally advised of the "implied
consent" law. It says that if you refuse to take
the test your license will be suspended or revoked for
anywhere from one to three years, depending on your past
record. Amazingly then, in some counties, they'll strap
you down on a table and take your blood by force, if
necessary. So you get the double whammy - a long
suspension because you refused, and they get their
evidence anyway!
Most people opt for a breath test. As with any chemical test,
the prosecution has three problems:
- First, they have to prove that they tested your
breath sample accurately. Actually, that's not all
that hard to do. unless you were painting that
day, or were otherwise exposed to solvents which
can give a false read. Toluene found in many
paints, is a frequent interferant. The problem is
that most breath machines use nonspecific testing
methods. The Intoxilyzer, for instance, is an
infrared spectrometer that looks for a very
abbreviated infrared signature for alcohol, an
abbreviated signature that many other solvents
share.
- Then they have to relate that breath test result
to the alcohol in your blood at the time you blew
into the machine.
You can imagine how much guesswork is involved in
proving that a certain amount of alcohol on your
breath means you got a certain amount in the
blood. What they do is guess that you have 2100
times as much alcohol in the blood as you do on
your breath, multiply the breath reading by 2100,
and call that blood alcohol. There goes the
pursuit of truth and justice out the window! The
2100 to 1 assumption is called the partition
ratio, and it's very far off if you're still
absorbing alcohol from a recent drink, perhaps
following a large meal.
- Then, they have to prove that the alcohol in your
blood at the time you were driving was above the
legal limit, and they have to do that based upon
the amount of alcohol in your blood. You can
imagine how difficult that would be, since your
body has had a half hour to 45 minutes to burn off
some it, and absorb some more from your stomach
and intestines. Bottom line - it's easy to show
that your blood alcohol level was lower while
driving than it was when you were tested.
All this adds up to the need for a 0.16% or more breath
test in order to prove a Blood Alcohol Concentration of
0.08% at the time of driving. If your breath test result
was 0.14% or less, you have a pretty good case. If it
was below 0.10% the odds of being convicted are slim
indeed, unless your case is in one of the counties or
districts where juries are dominated by white, middle
class, middle management types. You'll find them primarily Marin County courts,
the Walnut Creek courthouse, much of Orange County and
Ventura County courts.
You're actually being prosecuted twice. First, the DMV prosecutes you in an administrative
proceeding presided over by one person who is both judge
and prosecutor. He or she wants to take your driver's license for
somewhere between one month and three years. Secondly,
you're charged with the crime of DUI in the
criminal courts. More about the crime later. This
discussion covers the DMV proceedings.
The DMV's prosecution starts around the time you were
arrested, when your driver's license was probably taken
from you (unless it was from another state) and you were
served with an ADMINISTRATIVE PER SE, ORDER OF
SUSPENSION/REVOCATION, TEMPORARY DRIVER'S LICENSE
ENDORSEMENT (Form DS 367). (The name of the actual
document may vary, depending on how old arresting cop's
forms are.) As this document says in the fine print, you
have just 10 days to ask for a hearing. If you ask for
the hearing within that 10 day limit, the suspension is stayed,
meaning delayed, until the hearing is held and a
decision is reached. Use
this form to ask for the hearing. But only
ask for the hearing yourself if you get to the last day
and no lawyer has asked for a hearing for you. For lots
of reasons it's better to have the lawyer ask for the
hearing. In any event, take a few minutes right now to
read the instructions that accompany the form. They
explain what that process is all about, how long the
suspension or revocation lasts, and what your chances of
winning the hearing are - pretty good actually.
Click
here for more information on the California
DMV, including:
- Objections to hearing delays and continuances.
- Official disciplinary guidelines for use in driver's
license hearings based on actions related to
negligent operator (excessive point count),
commercial, certificates, endorsements, physical and
mental conditions, fraud and lack of insurance
grounds.
- D.M.V.'s official website.
- How long convictions stay on the driver's license
record and how to get a coy of it.
- How to obtain your Federal driver's license
record.
Click here
for information about your driver's license record.
It's important to understand that what the cop arrested
you for is not necessarily the crime you'll be charged
with by the prosecutor, a City Attorney or county
District Attorney.
The Usual Case: Usually you're charged with a
misdemeanor violation of California Vehicle Code section
23152, which reads, in relevant part:
(a) It is unlawful for any person who is under the
influence of any alcoholic beverage or drug, or under
the combined influence of any alcoholic beverage and
drug, to drive a vehicle.
(b) It is unlawful for any person who has 0.08
percent or more, by weight, of alcohol in his or her
blood to drive a vehicle.
For purposes of this article and Section 34501.16,
percent, by weight, of alcohol in a person's blood is
based upon grams of alcohol per 100 milliliters of
blood or grams of alcohol per 210 liters of breath.
In any prosecution under this subdivision, it is a
rebuttal presumption that the person had 0.08 percent
or more, by weight, of alcohol in his or her blood at
the time of driving the vehicle if the person had
0.08 percent or more, by weight, of alcohol in his or
her blood at the time of the performance of a
chemical test within three hours after the driving.
(c) It is unlawful for any person who is addicted to
the use of any drug to drive a vehicle. This
subdivision shall not apply to a person who is
participating in a narcotic treatment program
approved pursuant to Article 3 (commencing with
Section 11875) of Chapter 1 of Part 3 of Division
10.5 of the Health and Safety Code.
(d) It is unlawful for any person who has 0.04
percent or more, by weight, of alcohol in his or her
blood to drive a commercial motor vehicle, as defined
in Section 15210. In any prosecution under this
subdivision, it is a rebuttal presumption that the
person had 0.04 percent or more, by weight, of
alcohol in his or her blood at the time of driving
the vehicle if the person had 0.04 percent or more,
by weight, of alcohol in his or her blood at the time
of the performance of a chemical test within three
hours after the driving.
You might instead be charged with one of three different
felony offenses. Each of these is chargeable as either a
felony or a misdemeanor. A misdemeanor is a crime
punishable by no more than one year in the county jail.
A felony is punishable by 16 months or more in a
state prison.
Felony
Injury to Another: But if you caused injury to
another the crime is chargeable as a felony under
Vehicle Code section 23153. It reads, in relevant part:
(a) It is unlawful for any person, while under the
influence of any alcoholic beverage or drug, or under
the combined influence of any alcoholic beverage and
drug, to drive a vehicle and concurrently do any act
forbidden by law or neglect any duty imposed by law
in driving the vehicle, which act or neglect
proximately causes bodily injury to any person other
than the driver.
(b) It is unlawful for any person, while having 0.08
percent or more, by weight, of alcohol in his or her
blood to drive a vehicle and concurrently do any act
forbidden by law or neglect any duty imposed by law
in driving the vehicle, which act or neglect
proximately causes bodily injury to any person other
than the driver.
In any prosecution under this subdivision, it is a
rebuttal presumption that the person had 0.08 percent
or more, by weight, of alcohol in his or her blood at
the time of driving the vehicle if the person had
0.08 percent or more, by weight, of alcohol in his or
her blood at the time of the performance of a
chemical text within three hours after driving.
(c) In proving the person neglected any duty imposed
by law in driving the vehicle, it is not necessary to
prove that any specific section of this code was
violated.
Felony With Three or More Priors: And it's also
chargeable as a felony under Vehicle Code section 23550
if you had three or more prior drunk driving or alcohol
related reckless driving (wet reckless
convictions within the past 7 years. Section 23550
reads:
(a) If any person is convicted of a violation of
Section 23152 and the offense occurred within seven
years of three or more separate violations of Section
23103, as specified in Section 23103.5, or Section
23152 or 23153, or any combination thereof, which
resulted in convictions, that person shall be
punished by imprisonment in the state prison, or in a
county jail for not less than 180 days nor more than
one year, and by a fine of not less than three
hundred ninety dollars ($390) nor more than one
thousand dollars ($1,000). The person's privilege to
operate a motor vehicle shall be revoked by the
Department of Motor Vehicles pursuant to paragraph
(7) of subdivision (a) of Section 13352.
(b) Any person convicted of a violation of Section
23152 punishable under this section shall be
designated as an habitual traffic offender for a
period of three years, subsequent to the conviction.
The person shall be advised of this designation
pursuant to subdivision (b) of Section 13350.
Felony With a Felony Prior: In addition, it's
chargeable as a felony under Vehicle Code section
23550.5 if you had any prior conviction of felony drunk
driving within the past 10 years which was punished
as a felony. Section 23550.5 reads:
(a) A person is guilty of a public offense,
punishable by imprisonment in the state prison or in
a county jail for not more than one year and by a
fine of not less than three hundred ninety dollars
($390) nor more than one thousand dollars ($1,000) if
that person is convicted of a violation of Section
23152 or 23153, and the offense occurred within 10
years of any of the following:
(1) A prior violation of Section 23152 that was
punished as a felony under Section 23550 or this
section, or both, or under former Section 23175 or
former Section 23175.5, or both.
(2) A prior violation of Section 23153 that was
punished as a felony.
(3) A prior violation that was punished as a felony
under Section 191.5 of, or paragraph (1) or (3) of
subdivision (c) of Section 192 of, the Penal Code.
The person's privilege to operate a motor vehicle
shall be revoked by the Department of Motor Vehicles
under paragraph (7) of subdivision (a) of Section
13352.
(b) Any person convicted of a violation of Section
23152 that is punishable under this section shall be
designated an habitual traffic offender for a period
of three years, subsequent to the conviction. The
person shall be advised of this designation under
subdivision (b) of Section 13350.
DUI Drugs: Click
here for an article on Drug-Related
Driving Offenses - Rolling Stoned.
Your first court appearance is typically scheduled about
one month after the day you were arrested, except in San
Francisco where they get you into court within just a
few days. This first court date is for arraignment,
an occasion to enter a plea (not guilty if you plan on
fighting) and set a date for a pretrial conference. But
if you do plan on fighting you can instead ask the judge
to continue the case for a week or two so you can
hire a lawyer.
There will be a tremendous amount of coercion from the
judge and prosecutor to convince you of the wisdom of
pleading guilty right away. Often this coercion will
take the form of nasty threats and outright falsehoods
about the law and the punishments possible. Even the
judge, especially the judge, will engage in such
tactics. Remember that both the judge and the prosecutor
benefit greatly from a guilty plea. The judge clears his
extremely crowded calendar, and the prosecutor gets rid
of a case. Do not trust these people to be either
fair or honest with you. Under no circumstances should
you plead guilty until your case has been reviewed by an
attorney with your interests foremost in his mind.
At the pretrial conference your attorney will plead you
guilty if he or she is a dump
truck, or there is some other very good
reason to do so, like two or more prior convictions that
are not charged. But if you've hired a good lawyer he or
she will most likely not accept the prosecutor's initial
offer. Instead, the case will be set for pretrial
motions and/or a jury trial. Most cases don't actually
go to trial, but setting a trial date begins to get the
prosecution's attention, and convinces him or her that
you're serious about fighting. The more additional court
appearances there are, the more opportunities there are
for further plea bargaining.
But there's nothing like showing up for a jury trial to
really convince the prosecutor, and the judge, that
maybe now is the time to offer a better deal. Judges
particularly want to clear cases on the trial calendar.
For this reason they'll often switch hats and start
coercing the prosecutor to offer a deal that will settle
the case. Better late than never. (This is particularly
true if your case is only a 0.13% BAC and they have
others on the calendar awaiting trial with much higher
BAC's.) What you want is a deal that is better than what
you could reasonably expect most attorneys to obtain for
you. That's why you hired the best. If you don't get it,
you should go to trial, even though the cost - $1000 to
$2000 per day - may be quite a burden. By this point
you've probably already paid for at least the first day
anyway. Of course, the final choice is always yours.
REMEMBERING:
The most important thing in evaluating your case is to
preserve your memory of what happened.
What kind of case do you have, what's your chances?
There are five primary factors involved in evaluating
any drunk driving case. Here they are, accompanied by
some comments that assume you've hired one of the best,
a "Recognized Leader" in DUI
DefenseTM©:
- The Blood Alcohol Concentration (BAC) - Anything
0.14% or below is a low range reading with a
reasonable chance of acquittal. If it's 0.10% or
less it's likely in most courts that you'll be
found not guilt. If it's 0.08%, the prosecution's
own expert will admit that the testing error alone
is sufficient to put you below the legal
limit. But if it's 0.18% or more you've got about
a one in twenty chance for your attorney to pull a
rabbit out the hat and get you off.
- How likable you are - The jury has to like you
and the attorney who represents you in order to
put them in the frame of mind to accept the fact
that you may be innocent. If you're not the
outgoing likable type, don't worry, we'll either
teach you to fake it for a few days or do the best
we can to at least make you polite and acceptable
by others.
- How you were driving - This one isn't really that
serious since the cop himself will usually admit
it wasn't decisive, but driving of the type that
only someone really drunk could manage can be a
real hindrance to acquittal.
- What you said to the cop - This one is important,
like everything else. But even "I'm real
drunk" can be explained away. And once again,
the cop is likely to say that it didn't convince
him he had even as little evidence as probable
cause to arrest you.
- Physical symptoms - Not really all that
important. Again, the cop will say that he had
trouble making up his mind till the end.
Gastroesophageal Reflux Causes Many Breath Alcohol
Testing Errors: This Zantac
ad shows how gastroesophageal reflux occurs.
Such reflux is a primary source of error in breath
alcohol testing.
Calculate
Your BAC: It's possible to calculate what your BAC
may have been at various relevant times on the day of
your arrest. (click
here to download the program). Version 2.0 of
EZ-ALC remains the world's state of the art in BAC
calculations. It's just a simple DOS program, but so far
no one has produced a better product. And it's
shareware, so you can download it for free.
In addition, in 1990 Mr. Kuwatch first published Fast
Eddie's 8/10 Method of Hand Calculating BAC
which revealed a new and simple method for hand
calculating BAC's. It's so simple that most calculations
can be done in your head.
Court-Imposed Punishment: Click
here for a chart detailing the punishment for
a drunk driving conviction.
Click
here for information about the consequences
for a California resident of a drunk driving conviction
in another state, and the consequences for a resident of
another state with a drunk driving conviction in
California. Includes a form for an out of state resident
to use to have the California suspension removed without
completing a DUI Program. Click here for information about Colorado's
liberal reinstatement program.
Any traffic violation, accident, failure to appear,
suspension or revocation stays on your driver's license
record permanently. But Vehicle Code section 1808 sets
limits on how long these events and actions are
reportable to persons requesting a copy of your record.
Those time limits are described in a DMV memo sent to
the courts in 1998 (D.M.V. COURT INFORMATIONAL MEMO 98-4
(May 15, 1998) - Reportability of Driving Record
Information) The relevant portion of the memo states:
Overview of Procedures
Suspensions and revocations shall appear on the
record for three years following termination of the
action or reinstatement of the driving privilege,
except non-driving convictions taken pursuant to
Sections 13202.6 and 13202.7 of the Vehicle Code or
Section 256 and 11350.6 of the Welfare and
Institutions Code which are shown only when the
action is in effect.
- Violations designated as two points pursuant
to VC §12810 will be reported for seven years
from the date of violation.
- All other violations shall be reported for
three years from the date of violation.
- Accidents shall be reported for three years.
- Failure to Appear (FTA) violations shall be
reported for five years from the date of
violation. (No changes from existing policy.)
DMV will disclose suspension and/or revocation
actions that have not been reinstated or terminated
until the action has been reinstated, terminated (see
above), or there has been 10 years of inactivity -
whichever occurs first.
Exception: An FTA reported under VC §40509.5(c)
shall be reported for ten years from the date of
violation.
Effective January 1, 1998, a felony DUI conviction or
a felony manslaughter conviction shall be reported to
the courts and law enforcement for ten years from the
violation date (AB 130).
Note: Current fifty-five and ten-year reporting
requirements for specified violations involving
commercial vehicles remain unchanged.
Click here for additional details.
Check your national driving record at the {NEED LINK} National
Driver Register (N.H.T.S.A).
Your attorney can use this
letter from the Office of Legislative Counsel
to convince judges that drunk driving arrest billings
aren't for routine arrest situations.
Click
here for a list of California licensed DUI
Program providers. These are licensed Drinking Driver
Treatment Programs, usually required for license
reinstatement after a drunk driving conviction. No law
requires a court referral for enrollment, but some
providers require it. Shop around.
Can't afford the program fees? California law (Title
9, California Code of Regulations, section 9878)
requires these programs to admit persons who cannot
afford the fees. As you might expect, most of these
programs ignore this law, and tell you that if you
cannot afford the fees, you cannot enroll. When this
happens you should report it to California Department of
Alcohol and Drug Programs, 916 445 0834 (1700 K St.,
Sacramento CA, 95814).
Expedited DUI programs are offered by Driver
Benefits, Inc. in Torrance.
You can expect to pay $1500 to $2200, per year for three
years, over what you are now paying for auto insurance
as the result of a DUI conviction.
Basic
West makes it a specialty to offer
insurance to persons convicted of drunk driving. Click
here for some inside information about auto insurance.
A simple first offense drunk driving can have serious
consequences for an alien, but deportation is not one of
them. However, any drunk driving conviction which
results in a sentence of one year or more in custody
qualifies the defendant for automatic deportation. Click
here for additional information.
Pilots must report drunk driving suspensions and
convictions to the FAA. Click
here for details of the reporting
requirements. Click
here for additional information.
As many as three misdemeanor drunk driving convictions
may not result in state bar discipline, however
discipline might be imposed for just one conviction for
drunk driving with injury. Click
here for additional information.
Commercial vehicle drivers and their employers have
limited DUI reporting requirements. They told you in
truck driving school to report DUI arrests immediately,
but that's not required! Click
here for more information.
Click
here for information about consequences for
doctors and nurses. Nurses: Also see the Greater
Sacramento Area Chapter of the American Association of
Legal Nurse Consultants. Particularly note
the link to Dixie
O. Ten Broeck, RN.
Click here to find a lawyer in your area
There's a lot of talented salesmen out there, eager to
take your money with fast talk, and lots of promises of
talent, but beware - lawyers are highly skilled in the
arts of persuasion and hype. That's fine if it's put to
good use in front of a jury, but not if it's used to
simply collect a retainer then hang you out to dry.
Unfortunately, that practice is all too common.
DUI Lawyer Bar Associations: The links below
connect to websites of bar associations whose members
have indicated by their membership an interest in the
defense of persons accused of drunk driving. DISCLAIMER:
No recommendation is made or implied by the fact that of
the link being on this website. Evaluate each attorney
independently, without relying on the fact that he or
she was found by way of a link from this site.
