Grimshaw v. Ford Motor Co.

Grimshaw v. Ford Motor Co.
Court Court of Appeals of California, Fourth Appellate District, Division Two
Full case name RICHARD GRIMSHAW, a Minor, etc., Plaintiff and Appellant, v. FORD MOTOR COMPANY, Defendant and Appellant; CARMEN GRAY, a Minor, etc., et al., Plaintiffs and Appellants, v. FORD MOTOR COMPANY, Defendant and Appellant
Decided May 29, 1981 (1981-05-29)
Citation(s) 119 Cal.App.3d 757
Court membership
Judges sitting Tamura (Acting P.J.)
McDaniel · Kaufman
Case opinions
Decision by Tamura, joined by McDaniel
Concurrence Kaufman

Grimshaw v. Ford Motor Company (119 Cal.App.3d 757, 174 Cal.Rptr. 348) was personal injury tort case decided in Orange County California in February 1978 and affirmed by a California appellate court in May 1981. The lawsuit involved the safety of the design of the Ford Pinto automobile, manufactured by the Ford Motor Company. The jury awarded plaintiffs $127.8 million in damages, the largest ever in US product liability and personal injury cases. Grimshaw v. Ford Motor Company was one of the most widely publicized of the more than a hundred lawsuits brought against Ford in connection with rear-end accidents in the Pinto,[1]

On appeal, Ford contested the trial court judgement on the basis of errors, and contested the punitive damages award on the grounds of an absence of malice and that the punitive damages award was not authorized by statute and was unconstitutional. The appellate court affirmed the trial court.[2]

Trial

A 1972 Pinto rear-end impact and fire in Orange County, California resulted in the death of the driver Lily Gray and severe injury to passenger Richard Grimshaw. Lawsuits were combined for trial. The jury awarded $127.8 million in damages; $125 million in punitive damages and $2,841,000 in compensatory damages to Grimshaw and $665,000 in compensatory damages to the family of Gray. The jury award was the largest ever in US product liability and personal injury cases.[3][4][5] The jury award was the largest against an automaker until $150 million in Hardy vs. General Motors in 1996.[6]

The judge reduced the jury's punitive damages award to $3.5 million, which he later said was "still larger than any other punitive damage award in the state by a factor of about five."[5]

Reaction

University of California Los Angeles law professor Gary T. Schwartz, writing in 1990, said that the jury verdict was plausible, and that the "core of the Pinto story" was:

Given this description of the Pinto's design problem, some comments can be offered on the decision-making process within Ford that resulted in the Pinto. As shown above, a famous Ford report cannot be interpreted as showing Ford balancing lives against dollars in designing the Pinto. To state that the report does not itself reveal such a process does not mean, however, that such a process did not take place. Accordingly, I have consulted the Grimshaw record to learn what light it sheds on this question. As far as basic gas tank location is concerned, I am persuaded that the trunk capacity problem, in conjunction with American auto custom, provides the best explanation for Ford's

choice to place the Pinto gas tank behind the axle. As for additional design proposals brought forward by the plaintiffs, several of them-for example, a bladder within the gas tank, and a "tank within the tank"-concerned somewhat innovative technology that had never been utilized in actual auto production. At trial, there was testimony that a bladder would have been feasible in the early 1970's, but also rebuttal testimony that a bladder was at this time beyond the bounds of feasibility. The jury's general verdict does not reveal whether and how the jury resolved such conflicts in the evidence; and I am in no position to resolve them here. Consider now, however, the combination of a stronger bumper, a smooth (bolt-free) differential, and the addition of both hat sections and horizontal cross-members. This combination of design changes clearly would have improved the Pinto's safety to some appreciable extent. According to the evidence, the overall cost of this combination would have been $9; and it makes sense to assume that these items were turned down by Ford in planning the Pinto primarily on account of their monetary costs. It is plausible to believe, then, that because of these costs, Ford decided to not to improve the Pinto's design, knowing that its decision would increase the chances of the loss of consumer life. Once a variety of misconceptions are stripped away, this limited core of the Pinto story remains. And this is a core

that may well be strong enough to support the "myth" of the Ford Pinto case in the second of the meanings described above. What follows is my effort to explicate the elements of that myth.[2]

According to the Los Angeles Times in 2010, the award "signalled to the auto industry that it would be harshly sanctioned for ignoring known defects."[7]

Appeal

In discussing the appellate court findings of fact Schwartz (1990) notes that the appellate court was under strict rules of interpretation. He states:

For reasons quite beyond the court's control, its opinion must be treated cautiously as a source of actual facts. Because the defendant was appealing a jury verdict in favor of the plaintiffs, the court was under an obligation to view all the evidence in a way most favorable to the plaintiffs and essentially to ignore evidence in the record that might be favorable to the defendant. See id. at 773, 820, 174 Cal. Rptr. at 359, 388. In fact, Ford's basic position at trial-which the court's opinion at no point mentions-was that the approaching car (a Ford Galaxie) had not slowed down at all, and had struck the Gray car at a speed in excess of 50 miles per hour. There was an enormous amount of evidence at trial supporting each of the parties' factual claims as to the Galaxie's closing speed. Had the jury accepted Ford's speed estimate, there would not have been much of an issue of crashworthiness: for the plaintiffs' position throughout trial was that even a state-of-the-art fuel system could not maintain integrity in a 50 mile-per hour collision.[2]

Appellate court findings of fact

The trial court's findings of fact regarding the accident, the design of the Pinto, Ford's crash testing, and Ford's cost benefit analysis were not contested on appeal, and were accepted by the appellate court "in accordance with established principles of appellate review."[8]

The accident

A 1972 Ford Pinto hatchback stalled on a freeway, erupting into flames when it was rear-ended by a Ford Galaxie proceeding in the same direction. Lilly Gray, the driver of the Pinto, suffered severe burns to her entire body and resulted in her death by congestive heart failure. 13-year-old Richard Grimshaw, a passenger, suffered severe, permanently disfiguring burns to his entire body. Grimshaw underwent numerous skin grafts and extensive surgeries, but still lost portions of the fingers on his left hand and his left ear in the accident. Doctors estimated that Grimshaw would require many more surgeries within the next 10 years.

The plaintiff's expert testified that the Pinto's gas tank was pushed forward upon impact and punctured by a flange or bolt on the differential housing. Fuel sprayed from the tank and entered the passenger compartment through the gaps between the rear wheel wells and the floor.

Design of the Pinto Fuel System

In 1968, Ford began designing the subcompact car that would eventually become known as the Pinto.

The courts found that Lee Iacocca, at the time a vice president at Ford, conceived the Pinto "project and was its moving force" and said that "Ford's objective was to build a car at or below 2,000 pounds to sell for no more than $2,000."[9] The courts described the Pinto as a "rush project," and said that while standard automotive industry practice was that "engineering studies precede the styling," in the case of the Pinto project "styling preceded engineering and dictated engineering design to a greater degree than usual."[10]

The court found that the Pinto's styling required the gas tank to be placed behind the rear axle, instead of over the rear axle as was "the preferred practice in Europe and Japan" and that the Pinto had "only 9 or 10 inches" of "crush space," "far less than in any other American automobile or Ford overseas subcompact."[11] The court found that the Pinto's bumper "was little more than a chrome strip, less substantial than the bumper of any other American car produced then or later."[12] The court found that the Pinto's rear structure lacked reinforcement "found in all automobiles produced by Ford's overseas operations," rendering the Pinto "less crush resistant than other vehicles."[13] The court found that a flange and a line of bolts on the Pinto's differential housing "were sufficient to puncture a gas tank driven forward upon rear impact."[14]

Crash Tests

Ford tested two production models of the Pinto and prototypes, some of which "were true duplicates of the design car," "to determine, among other things, the integrity of the fuel system in rear-end accidents."[15] Proposed federal regulations required impacts "without significant fuel spillage," up to 20 miles per hour (32 km/h) impacts by 1972 and 30 miles per hour (48 km/h) by 1973.[16]

Crash tests proved that the Pinto could not meet the proposed regulations. A collision from the rear "caused the fuel tank to be driven forward and to be punctured, causing fuel leakage." A collision of a production Pinto "caused the fuel neck to be torn from the gas tank and the tank to be punctured by a bolt head on the differential housing." In at least one test collision "spilled fuel entered the driver's compartment through gaps resulting from the separation of the seams joining the rear wheel wells to the floor pan," separations due in part to "the lack of reinforcement in the rear structure."[17]

Ford tested modified Pinto prototypes, which "proved safe at speeds at which the Pinto failed," including modifications to line the fuel tank with a rubber bladder, to locate the fuel tank above rather than behind the rear axle, and to add reinforcement.[18]

The Cost to Remedy Design Deficiencies

The courts found that, while "the standard of care for engineers in the industry" after a failed safety test was to "redesign and retest," and although fixes were inexpensive, "Ford produced and sold the Pinto to the public without doing anything to remedy the defects."[19]

Design changes that would have enhanced the fuel system at very little cost included:[20]

Equipping the car with a reinforced rear structure, smooth axle, improved bumper and additional crush space at a total cost of $15.30 would have made the fuel tank safe in a 34 to 38-mile-per-hour rear-end collision by a vehicle the size of the Ford Galaxie. If, in addition to the foregoing, a bladder or tank within a tank were used or if the tank were protected with a shield, it would have been safe in a 40 to 45-mile-per-hour rear impact. If the tank had been located over the rear axle, it would have been safe in a rear impact at 50 miles per hour or more.[21]

Management knowledge

The Pinto project team held regular product review meetings chaired and attended by Ford vice presidents. The Pinto was approved by Ford's Product Planning Committee, which included Iacocca and other Ford vice presidents.[22] At an April, 1971 product review meeting, a report prepared by Ford engineers entitled "Fuel System Integrity Program Financial Review" was distributed and discussed, which referred to the crash tests of Ford vehicles and estimated the financial impact of design changes to comply with the proposed federal fuel system integrity standards. The report recommended deferring fixes in order to accrue cost savings.[23] Harley Copp, a former Ford engineer and the executive in charge of the crash testing program, "testified that the highest level of Ford's management made the decision to go forward with the production of the Pinto, knowing that the gas tank was vulnerable to puncture and rupture at low rear impact speeds creating a significant risk of death or injury from fire and knowing that 'fixes' were feasible at nominal cost."[21]

Disposition of appeals

The appellate court affirmed the trial court.

Defendant's Appeals

Ford contested the trial court judgement on the basis of errors, and contested the punitive damages award on the grounds of an absence of malice and that the punitive damages award was not authorized by statute and was unconstitutional.

Errors

The appellate court "concluded that Ford has failed to demonstrate that any errors or irregularities occurred during the trial which resulted in a miscarriage of justice requiring reversal."[21]

Ford contended that the trial court erroneously admitted Ford's "Fuel System Integrity Program Financial Review" report as irrelevant and prejudicial. In the document, Ford engineers recommending deferring the installation of "flak suits" or "bladders," available at a cost of $4 to $8 per car, in all Ford cars to 1976, which allowed the company to realize a savings of $20.9 million.[23] The appellate court ruled that the report was highly relevant in that "A reasonable inference may be drawn from the evidence that despite management's knowledge that the Pinto's fuel system could be made safe at a cost of but $4 to $8 per car, it decided to defer corrective measures to save money and enhance profits."[24]

Punitive damages

Ford contended the punitive damages on two grounds: 1) punitive damages are statutorily and constitutionally impermissible in design defect cases; and 2) there was no evidentiary support for a finding of malice or corporate responsibility for malice.

Punitive damages in design defect cases

The appellate court found no statutory impediments to punitive damages and said that "Ford's contention that the statute is unconstitutional has been repeatedly rejected."[21]

Malice

Ford contended that the "Exemplary damages" section of California's civil code[25] required an "evil motive," or an intent to injure the person harmed, for punitive damages, and argued absence of malice. The appellate court cited precedent that "malice" as used in California's "Exemplary damages" code included "not only a malicious intention to injure the specific person harmed, but conduct evincing 'a conscious disregard of the probability that the actor's conduct will result in injury to others.'"[26] In Taylor v. Superior Court, the California Superior Court held that a conscious disregard of the safety of others is sufficient to meet the animus malus required for punitive damages awards, adding: "In order to justify an award of punitive damages on this basis, the plaintiff must establish that the defendant was aware of the probable dangerous consequences of his conduct, and that he wilfully and deliberately failed to avoid those consequences." In a commercial context, the imposition of punitive damages deters the furtherance of "objectional corporate policies" and encourages the remedy of safety concerns that might otherwise go unchecked.[27][28][29]

According to the appellate court decision,

There was ample evidence to support a finding of malice and Ford's responsibility for malice. Through the results of the crash tests Ford knew that the Pinto's fuel tank and rear structure would expose consumers to serious injury or death in a 20- to 30-mile-per-hour collision. There was evidence that Ford could have corrected the hazardous design defects at minimal cost but decided to defer correction of the shortcomings by engaging in a cost-benefit analysis balancing human lives and limbs against corporate profits. Ford's institutional mentality was shown to be one of callous indifference to public safety. There was substantial evidence that Ford's conduct constituted "conscious disregard" of the probability of injury to members of the consuming public...There is substantial evidence that management was aware of the crash tests showing the vulnerability of the Pinto's fuel tank to rupture at low speed rear impacts with consequent significant risk of injury or death of the occupants by fire. There was testimony from several sources that the test results were forwarded up the chain of command;...While much of the evidence was necessarily circumstantial, there was substantial evidence from which the jury could reasonably find that Ford's management decided to proceed with the production of the Pinto with knowledge of test results revealing design defects which rendered the fuel tank extremely vulnerable on rear impact at low speeds and endangered the safety and lives of the occupants. Such conduct constitutes corporate malice.[21]

Ford argued that the amount awarded in punitive damages was excessive. The test for deciding whether the amount was excessive as a matter of law or was so grossly disproportionate as to raise the presumption that it was the product of passion or prejudice is four-prong: 1) the degree of reprehensibility of defendant's conduct; 2) wealth of the defendant; 3) the amount of compensatory damages; and 4) an amount which would serve as a deterrent effect on like conduct by the defendant and others. The appellate court held that

...the conduct of Ford's management was reprehensible in the extreme. It exhibited a conscious and callous disregard of public safety in order to maximize corporate profits...Ford's tortious conduct endangered the lives of thousands of Pinto purchasers. Weighed against the factor of reprehensibility, the punitive damage award as reduced by the trial judge was not excessive."[21]

In light of Ford's 7.7 billion dollar net worth and 983 million dollar income after taxes in 1976, the court found that the punitive award was approximately 0.005% of Ford's net worth and 0.03% of its income. The ratio of punitive damages to compensatory damages was approximately 1.4:1. Significantly, Ford did not argue about the excessiveness of the compensatory damages. Lastly, the punitive award was sufficient to require Ford to take notice, rather than allowing the company to write it off as a mere business expense.

Plaintiff's Appeals

Grimshaw appeals from the order granting a conditional new trial and from the amended judgment entered pursuant to the order. Grimshaw argues that 1) the punitive damages awarded by the jury where not excessive as a matter of law; 2) the specification of reasons was inadequate; and 3) the court abused its discretion in cutting the award so drastically. The appellate court held that the trial court did not err in reducing the jury's award of punitive damages from more than 122 million to 3.5 million or in granting a new trial for excessive damages. There was no evidence showing that the trial judge abused his discretion, nor that he acted in any way that was not fair and reasonable under the circumstances.

See also

References

  1. ↑ Sherefkin 2003: Ford customers filed 117 lawsuits, according to Peter Wyden in The Unknown Iacocca.
  2. 1 2 3 Schwartz, Gary T (1990). "The Myth of the Ford Pinto Case". Rutgers Law Review. 43: 1013.
  3. ↑ "Teen wins $127.8 million in car-fire suit". Chicago Tribune. Santa Ana, California. Associated Press. February 7, 1978. p. 6. Retrieved March 4, 2016.
  4. ↑ "Award in injury suit is over $127 million". The Globe and Mail. Toronto, Ontario. February 7, 1978. p. 10.
  5. 1 2 McLellan, Dennis (April 19, 2008). "Retired O.C. judge handled major cases". Los Angeles Times. Retrieved March 4, 2016.
  6. ↑ Christian, Nichole M; Henderson, Angelo B; Nomani, Asra Q (October 9, 1997). "Chrysler is Told to Pay $262.5 Million by Jurors in Minivan-Accident Trial". The Wall Street Journal. p. 1. Retrieved March 4, 2016.
  7. ↑ Williams, Carol J. (March 14, 2010). "Toyota is just the latest automaker to face auto safety litigation". Los Angeles Times. Retrieved March 4, 2016.
  8. ↑ Grimshaw v. Ford Motor Co. 1981: Since sufficiency of the evidence is in issue only regarding the punitive damage award, we make no attempt to review the evidence bearing on all of the litigated issues. Subject to amplification when we deal with specific issues, we shall set out the basic facts pertinent to these appeals in accordance with established principles of appellate review
  9. ↑ Grimshaw v. Ford Motor Co. 1981: In 1968, Ford began designing a new subcompact automobile which ultimately became the Pinto. Mr. Iacocca, then a Ford vice president, conceived the project and was its moving force. Ford's objective was to build a car at or below 2,000 pounds to sell for no more than $2,000.
  10. ↑ Grimshaw v. Ford Motor Co. 1981: Ordinarily marketing surveys and preliminary engineering studies precede the styling of a new automobile line. Pinto, however, was a rush project, so that styling preceded engineering and dictated engineering design to a greater degree than usual.
  11. ↑ Grimshaw v. Ford Motor Co. 1981: Among the engineering decisions dictated by styling was the placement of the fuel tank. It was then the preferred practice in Europe and Japan to locate the gas tank over the rear axle in subcompacts because a small vehicle has less "crush space" between the rear axle and the bumper than larger cars. The Pinto's styling, however, required the tank to be placed behind the rear axle leaving only 9 or 10 inches of "crush space"--far less than in any other American automobile or Ford overseas subcompact.
  12. ↑ Grimshaw v. Ford Motor Co. 1981: In addition, the Pinto was designed so that its bumper was little more than a chrome strip, less substantial than the bumper of any other American car produced then or later.
  13. ↑ Grimshaw v. Ford Motor Co. 1981: Pinto's rear structure also lacked reinforcing members known as "hat sections" (two longitudinal side members) and horizontal cross-members running between them such as were found in cars of larger unitized construction and in all automobiles produced by Ford's overseas operations. The absence of the reinforcing members rendered the Pinto less crush resistant than other vehicles.
  14. ↑ Grimshaw v. Ford Motor Co. 1981: Finally, the differential housing selected for the Pinto had an exposed flange and a line of exposed bolt heads. These protrusions were sufficient to puncture a gas tank driven forward against the differential upon rear impact.
  15. ↑ Grimshaw v. Ford Motor Co. 1981: During the development of the Pinto, prototypes were built and tested. Some were "mechanical prototypes" which duplicated mechanical features of the design but not its appearance while others, referred [119 Cal. App. 3d 775] to as "engineering prototypes," were true duplicates of the design car. These prototypes as well as two production Pintos were crash tested by Ford to determine, among other things, the integrity of the fuel system in rear-end accidents.
  16. ↑ Grimshaw v. Ford Motor Co. 1981: Ford also conducted the tests to see if the Pinto as designed would meet a proposed federal regulation requiring all automobiles manufactured in 1972 to be able to withstand a 20-mile-per-hour fixed barrier impact without significant fuel spillage and all automobiles manufactured after January 1, 1973, to withstand a 30-mile-per-hour fixed barrier impact without significant fuel spillage.
  17. ↑ Grimshaw v. Ford Motor Co. 1981: The crash tests revealed that the Pinto's fuel system as designed could not meet the 20-mile-per-hour proposed standard. Mechanical prototypes struck from the rear with a moving barrier at 21 miles per hour caused the fuel tank to be driven forward and to be punctured, causing fuel leakage in excess of the standard prescribed by the proposed regulation. A production Pinto crash tested at 21 miles per hour into a fixed barrier caused the fuel neck to be torn from the gas tank and the tank to be punctured by a bolt head on the differential housing. In at least one test, spilled fuel entered the driver's compartment through gaps resulting from the separation of the seams joining the rear wheel wells to the floor pan. The seam separation was occasioned by the lack of reinforcement in the rear structure and insufficient welds of the wheel wells to the floor pan.
  18. ↑ Grimshaw v. Ford Motor Co. 1981: Tests conducted by Ford on other vehicles, including modified or reinforced mechanical Pinto prototypes, proved safe at speeds at which the Pinto failed. Where rubber bladders had been installed in the tank, crash tests into fixed barriers at 21 miles per hour withstood leakage from punctures in the gas tank. Vehicles with fuel tanks installed above rather than behind the rear axle passed the fuel system integrity test at 31-miles-per-hour fixed barrier. A Pinto with two longitudinal hat sections added to firm up the rear structure passed a 20-mile-per-hour rear impact fixed barrier test with no fuel leakage.
  19. ↑ Grimshaw v. Ford Motor Co. 1981: When a prototype failed the fuel system integrity test, the standard of care for engineers in the industry was to redesign and retest it. The vulnerability of the production Pinto's fuel tank at speeds of 20 and 30-miles-per-hour fixed barrier tests could have been remedied by inexpensive "fixes," but Ford produced and sold the Pinto to the public without doing anything to remedy the defects.
  20. ↑ Grimshaw v. Ford Motor Co. 1981: Design changes that would have enhanced the integrity of the fuel tank system at relatively little cost per car included the following: Longitudinal side members and cross members at $2.40 and $1.80, respectively; a single shock absorbent "flak suit" to protect the tank at $4; a tank within a tank and placement of the tank over the axle at $5.08 to $5.79; a nylon bladder within the tank at $5.25 to $8; placement of the tank over the axle surrounded with a protective barrier at a cost of $9.95 per car; substitution of a rear axle with a smooth differential housing at a cost of $2.10; imposition of a protective shield between the differential housing and the tank at $2.35; improvement and reenforcement of the bumper at $2.60; addition of eight inches of crush space a cost of $6.40.
  21. 1 2 3 4 5 6 Grimshaw v. Ford Motor Co. 1981
  22. ↑ Grimshaw v. Ford Motor Co. 1981: The feasibility study was conducted under the supervision of Mr. Robert Alexander, vice president of car engineering. Ford's Product Planning Committee, whose members included Mr. Iacocca, Mr. Robert Alexander, and Mr. Harold MacDonald, Ford's group vice president of car engineering, approved the Pinto's concept and made the decision to go forward with the project. During the course of the project, regular product review meetings were held which were chaired by Mr. MacDonald and attended by Mr. Alexander.
  23. 1 2 Grimshaw v. Ford Motor Co. 1981:At an April 1971 product review meeting chaired by Mr. MacDonald, those present received and discussed a report (exhibit 125) prepared by Ford engineers pertaining to the financial impact of a proposed federal standard on fuel system integrity and the cost savings which would accrue from deferring even minimal "fixes." The report refers to crash tests of the integrity of the fuel system of Ford vehicles and design changes needed to meet anticipated federal standards...Exhibit No. 125 was a report presented at a Ford production review meeting in April 1971, recommending action to be taken in anticipation of the promulgation of federal standards on fuel system integrity. The report recommended, inter alia, deferral from 1974 to 1976 of the adoption of "flak suits" or "bladders" in all Ford cars, including the Pinto, in order to realize a savings of $20.9 million.
  24. ↑ Grimshaw v. Ford Motor Co. 1981: A reasonable inference may be drawn from the evidence that despite management's knowledge that the Pinto's fuel system could be made safe at a cost of but $4 to $8 per car, it decided to defer corrective measures to save money and enhance profits. The evidence was thus highly relevant and properly received.
  25. ↑ "California's Civil Code § 3294". Retrieved March 4, 2016.
  26. ↑ Grimshaw v. Ford Motor Co. 1981: As this court recently noted, numerous California cases after Davis v. Hearst, supra, have interpreted the term "malice" as used in section 3294 to include, not only a malicious intention to injure the specific person harmed, but conduct evincing "a conscious disregard of the probability that the actor's conduct will result in injury to others."
  27. ↑ Taylor v. Superior Court, 24 CA3d 890 (Cal. August 21, 1979).
  28. ↑ 598 P.2d 854
  29. ↑ Grimshaw v. Ford Motor Co. 1981: In Taylor v. Superior Court, supra, 24 Cal. 3d 890, our high court's most recent pronouncement on the subject of punitive damages, the court observed that the availability of punitive damages has not been limited to cases in which there is an actual intent to harm plaintiff or others. (Id, at p. 895.) The court concurred with the Searle (G.D. Searle & Co. v. Superior Court, supra, 49 Cal.App.3d 22) court's suggestion that conscious disregard of the safety of others is an appropriate description of the animus malus required by Civil Code section 3294, adding: "In order to justify an award of punitive damages on this basis, the plaintiff must establish that the defendant was aware of the probable dangerous consequences of his conduct, and that he wilfully and deliberately failed to avoid those consequences."

Bibliography

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