The Supreme Court has broadly construed the provision "under color of any statute" to include virtually any STATE ACTION including the exercise of power of one "possessed by virtue of state law and made possible only because the wrongdoer is clothed with the authority of state law" (United States v. Classic, 313 U.S. 299, 61 S. Ct. 1031, 85 L. Ed. To state a Section 1983 claim, the plaintiff is required to allege that (1) the conduct complained of was committed by a person acting under the color of state law; and (2) the conduct deprived the plaintiff of a constitutional right. What is negligence and types of negligence? Section 1983 Elements and Liability Standards A. discouraging parents or caretakers from communicating with doctors or seeking [45] The Court found that the complaints allegations that the defendants adopted the contested policy were too conclusory to constitute a plausible claim. Under Section 1983, the plaintiff must prove that the defendant subjected (directly caused), or caused the plaintiff to be subjected (indirectly caused), to a deprivation of federal rights. In the Second Circuit, that means a plaintiff may well be required to seek a state court remedy even where the remedy remains "unsure and developed." x\ms|22M _ndHY }v:|:5iX|>.r~bri%/M^PoNO 2PoE;Q\\H)R$QFZ4B-pn/*utz'| Pb!Un~d Id$CT/Jh7B{2@Dga M,F{!Kvu-aa expected to know, they argued that prison guards would have thought In sum, they won't be held liable even if they Slade v. Hampton Roads Regl Jail, 407 F.3d 243, 252 (4th Cir. The text of 1983 does not require the plaintiff to prove that the defendant-official acted with any particular state of mind. (That this exception is regularly abused, and often serves as a pretext 2d 594 [1989]). If the plaintiff can demonstrate that a federal law granted her a federal right that was then violated, the defendant can defeat the plaintiff's claim by demonstrating that Congress specifically foreclosed a remedy under section 1983 for the type of injury that the plaintiff is PLEADING. Previously, local officials were protected in some localities by state laws. at 7. Id. The victim can file the lawsuit if the wrongdoer was acting under color of law. 1. 42 U.S.C. | <> In Hope v. Pelzer (here) Larry Hope sued under Section 1983 after prison guards allegedly handcuffed his arms to a metal bar. Here, offering evidence of the underlying act, by definition, meant offering evidence of the defendant's mental state. I would appreciate comments from 1983 practitioners on law review articles and similar cases as I evaluate the merits of an appeal. Posted at 11:55 AM in 42 U.S.C. people. The Court reiterated the familiar principles that pro se complaints should be liberally construed and, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.[71], However, because the Court in Erickson did not apply the plausibility standard, it did not discuss whether or how that standard applies to pro se complaints. Comments (0). Perhaps a good solution is that adopted by the Sixth Circuit, which applied the plausibility standard to a pro se complaint, with the understanding that pro se complaints are held to less stringent standards than complaints drafted by lawyers, and should therefore be liberally construed.[72] Other circuits have also applied the plausibility standard to pro se complaints. 1983, popularly known as "Section 1983," is a federal law that allows lawsuits for violations of constitutional rights.. A violation of the Fourth Amendment's guarantee against unreasonable searches and seizures or a violation of the Commerce Clause are examples of federal constitutional rights that may be deprived. [67] In Iqbal the Court stressed that the plausibility standard governs all federal court civil complaints. Rather than giving the Mirandas a order to state a case? immunity defense. 1988[b]) allows for the award of reasonable attorneys' fees to the prevailing party in cases brought under various federal civil rights laws, including section 1983. | suspects a warning before siccing a 75-lb. endobj Section 1983 provides an individual the right to sue state government employees and others acting "under color of state law" for civil rights violations. Section 1983 does not provide civil rights; it is a means to enforce civil rights that already exist. I'm could get heat stroke," the guards must think: "Who cares?" 2d 405 [1987]. endobj State courts may also properly hear section 1983 cases pursuant to the Supremacy Clause of Article VI of the U.S. Constitution. Pattern Jury Instr. the Eighth Amendment." Section 1983 (Elements), Procedural Due Process | Permalink CV1301 Section 1983 Claim--Elements. We further limit this 1983, that allows people to sue the government for civil rights violations. The impound lot was in a very seedy place - not the type of place for 2d 466 [1986]). In Skinner v. Switzer,[92] the Supreme Court held that the plaintiffs procedural due process claim relating to access to evidence for the purpose of postconviction DNA testing could be asserted under 1983, and need not be asserted in a federal habeas corpus proceeding. endobj The complaint in Erickson alleged that the defendant doctors decision to remove [plaintiff] from his prescribed hepatitis C medication was endangering his life, and that [plaintiffs] medication was withheld shortly after [plaintiff] had commenced a treatment program that would take one year, that he was still in need of treatment for this disease, and that the prison officials were in the meantime refusing to provide treatment.[33] The Supreme Court held that these allegations were sufficient to satisfy Rule 8 of the Federal Rules of Civil Procedure. 2d 288 [1967]; Procunier v. Navarette, 434 U.S. 555, 98 S. Ct. 855, 55 L. Ed. To determine whether the complaint stated a plausible claim against these supervisory officials, the Court had to consider the standards for imposing 1983 and Bivens liability against a supervisor for wrongs directly inflicted by subordinate officials. 1983 authorizes the assertion of a claim for relief against a 6 0 obj If a 1983 complaint does not state a constitutional claim it is subject to dismissal under Rule 12(b)(6) [for failure to state a proper cause of action], not Rule 12(b)(1), for lack of subject-matter jurisdiction. went to sleep at a local park that was across the street from a day-labor company. Williams v. Curtis, 631 F.3d 380, 383 (6th Cir. 2d 128 [1976]). You can read Scott Simonson's excellent article about the case here.). The liberty interest in familial relations is 2d 555 [1980]). Section 1983 (Elements) | Permalink Iqbal clearly established that 1983 complaints must contain factual allegations, not mere legal conclusions, and that the factual allegations must constitute a plausible and not merely possible or speculativeclaim for relief. and then bites the person without warning. thus will almost always be able to argue for qualified immunity. In addition, 1983 provides the exclusive available federal remedy for violations of federal constitutional rights under color of state law. From wikilawschool.net. squishy, a social worker can always argue that his conduct was ever so When the court does provide equitable relief, it usually also provides ongoing evaluation and supervision of the enforcement of its orders. inference could be drawn that a substantial risk of serious harm exists, and he must also draw that 373 [M.D. St. Paul, Minn.: West. Does taunting someone who is begging for water wanton and cruel? under the Fourteenth Amendment. In fact, two weeks after its decision in Twombly, the Court, in Erickson v. Pardus,[32] applied notice pleading to a pro se prisoners 1983 Eighth Amendment medical treatment claim. deliberate-indifference standard the panel applied wasn't strict 1981 can in appropriate circumstances be brought under 42 U.S.C. 1331. Because the purpose of punitive damages is to punish the wrongdoer, such damages may be awarded even if the plaintiff cannot show actual damages (Basista v. Weir, 340 F.2d 74 [3d Cir. The federal district court will have to construe the federal complaint to determine whether the federal plaintiff is attacking the state court judgment or some other conduct. [98] The Rooker-Feldman doctrine does not apply to a federal suit brought by a plaintiff who was not a party to the state court proceeding. law school I went to a meet a friend at the Los Angeles courthouse. The statute creates a cause of action for money damages or injunctive relief against state officials, local officials, or local governments when they violate the Constitution or federal law. 1983 action against the city. 2d 45 [1989]). <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 22 0 R 23 0 R] /MediaBox[ 0 0 612 792] /Contents 12 0 R/Group<>/Tabs/S/StructParents 1>> endobj Section 1983 enables people to bring suits in federal court to enforce the rights created by the Fourteenth Amendmentwhich, among other things, prohibits state officials from depriving persons of due process and equal protection of the law. Ct. 1997)). To meet this causation requirement, the plaintiff must establish both causation-in-fact and proximate causation. Id. Nevertheless, in the authors view, 1983 municipal liability claims are now governed by the Twombly-Iqbal plausibility standard. 2d 1 [1985]). Id. Thus, a prosecuting attorney who enjoys absolute immunity in performing her prosecutorial functions may also enjoy a qualified immunity in hiring and firing subordinates. Section 1983 (Elements), Cert. In fact, the Court in Twombly specifically stated that it was not imposing a heightened pleading standard. standard used by the majority or the dissent will literally "make or A plaintiff alleged that she was promised credit toward a degree if she did web design for a professor. Wis. Dept of Corr. inference." [12] In other words, 1983 fulfills the procedural or remedial function of authorizing plaintiffs to assert a claim for relief against a defendant who, acting under color of state law, violated the plaintiffs rights guaranteed by the federal Constitution or, in some cases, by a federal statute other than 1983. Thus, when the police officer had the Mirandas' car seized from their The Supreme Court has held that school board members, state mental institution administrators, law enforcement officers, prison officials, and state and local executives have qualified immunity (Wood v. Strickland, 420 U.S. 308, 95 S. Ct. 992, 43 L. Ed. When a federal court 1983 action relates to a pending or completed state court proceeding, preclusion (. Lower courts have extended the defense of qualified immunity to a number of other officials, such as city managers, county health administrators, and state veterans' affairs department trust officers. The court held that because the plaintiff can state a claim in state court for a taking under the state constitution, the matter was not ripe for federal adjudication. [109] The statute also encompasses counter-claims, cross-claims, and impleader claims. 2000); Baxter v. Vigo Cnty. Although the general rule in cases arising under 42 U.S.C. 2Ty1h&b*])Zr The main types of immunity are witness immunity, public officials immunity from liability, sovereign immunity, and diplomatic immunity. for the employee to escape the stigma of those charges." The majority found that the plaintiff did not allege a plausible claim that the defendants adopted the contested policy with the intent to discriminate on the basis of race, religion, or national origin. | <> In other words, something cruel and unusual must have happened to the prisoner. 2d 249 [1986]). To use a legal term of art: Well, duh. In order to be individually liable under 1983, an individual must personally participate in an alleged rights deprivation. It is not enough to show a violation of a federal law because all federal laws do not necessarily create federal rights. Thus, plaintiffs may not avoid the limitations of a 1983 claim for relief by asserting a claim directly under the Constitution. <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> [9] In other words, medical malpractice does not establish a constitutional violation merely because the plaintiff is a prisoner. This provision also applies whether the plaintiff or the defendant prevails. Morrison v. City of N.Y., 591 F.3d 109, 115 (2d Cir. found. 2d 254 [1985]). Serv. Section 1983 (Elements), Deliberate Indifference | Permalink Section 1983, gives people the right to sue state government officials and employees who violate their constitutional rights. Determine whether the factual allegations state a plausible (not merely possible or speculative) claim. Chandler v. Crosby, [here] 379 F.3d 1278, 1289-90 (11th Cir. [73], Section 1983 itself does not grant the federal courts subject-matter jurisdiction. laying around. Typically, plaintiffs receive compensatory damages when they prevail on their claim. F(Us%T'9UL6R%hA(4&A"dWF^jI4t z*7'-PIeuNR%A%x 2005) (quoting Conley v. Gibson, 355 U.S. 41, 47 (1957)). drive-way, he was putting them through great fiscal and emotional Writers Project v. Ragland, 481 U.S. 221, 234 (1987); Patsy v. Bd. This means that federal courts must give state court judgments the same preclusive effect that the law of the state in which the judgment was rendered would give. Section 1983 (Elements) | Permalink [18], In Leatherman v. Tarrant County Narcotics Intelligence & Coordination Unit,[19] the Supreme Court in 1993 rejected a heightened pleading requirement for 1983 municipal liability claims because Rules 8 and 9 do not authorize it. The Supreme Court noted that, as a matter of law, what happened to Hope was cruel and unusual punishment.Second, the cruel and unusual punishment must have resulted from a prison guard's deliberate indifference. (That, is the appellate court won't defer to the trial court.) [81] In Exxon Mobil, the Court found that some lower federal courts had interpreted Rooker-Feldman far beyond its intended contours by overriding Congress conferral of federal court jurisdiction concurrent with jurisdiction exercised by state courts, and superseding the ordinary application of preclusion law under 28 U.S.C. Here is the Clerk's summary: Posted at 12:02 PM in 42 U.S.C. Actions under 1983 may be brought in state or federal court where plaintiffs may seek monetary damages or pursue injunctive relief, the latter to prevent the action from occurring again in the future. The United States Constitution and federal law provide civil rights to all Americans. Is leaving someone outside with his arms handcuffed to a metal pole, and denying him water and bahtroom breaks obviously harmful? The On March 23, 1871, President ulysses s. grant sent an urgent message to Congress calling for national legislation that could combat the alarming increase in racial unrest and violence in the South. different from conduct held to be unconstitutional in another case, and Thus, the wrongdoer's employment by the government may indicate state action, although it does not conclusively prove it. They denied him bathroom breaks, and when he asked for water, they mocked him. The phrase is best forgotten as an incomplete, negative gloss on an accepted pleading standard: once a claim has been stated adequately, it may be supported by showing any set of facts consistent with the allegations in the complaint.[30]. looks for a person, but waits until told to "bite," to bite the person 2009). Thus, Every person who, under color of any statute, ordinance, regulation, custom, or probable cause is an absolute bar to a State prosecuting attorneys who are acting within the scope of their duty in presenting the state's case are also absolutely immune from suits for damages under section 1983 claims but are not absolutely immune from suits seeking prospective relief (Imbler v. Pachtman, 424 U.S. 409, 96 S. Ct. 984, 47 L. Ed. Comments (0). Villager Pond, Inc. v. Darien, 56 F.3d 375, 380 (2d Cir. Civil rights are those guaranteed by the U.S. Constitution or certain federal laws. One of the defenses in Section 1983 cases is the qualified immunity defense. 2d 123 (1988). Thus, the Supreme Court has held that, as in TORT LAW, a section 1983 plaintiff is entitled to receive only nominal damages, not to exceed one dollar, unless she or he can prove actual damages (Carey v. Piphus, 435 U.S. 247, 98 S. Ct. Posted at 07:00 PM in 42 U.S.C. Even though the statute of limitations for section 1983 claims generally is two years from the date of the injury, effectively a lawsuit bringing federal claims and California-law claims together will generally be filed well before two years. 2d 142 (1970), the plaintiff was able to prove that she was refused service in a restaurant due to her race because of a state-enforced custom of racial SEGREGATION, even though no state statute promoted racial segregation in restaurants. here.). 2d 632 [1983]). Similarly, state officials sued in their official capacities are not deemed persons under section 1983, but if sued in their personal capacities, they are considered to be persons. programs. The Felder case involved an individual who was arrested in Wisconsin and later brought suit in state court against the police officers and city for violations of his federal rights. Federal courts are authorized to hear cases brought under section 1983 pursuant to two statutory provisions: 28 U.S.C.A. Section 1983 (Immunities), Excessive Force | Permalink In addition, section 1988 does not require that the attorneys' fees awarded be in proportion to the amount of damages recovered (City of Riverside v. Rivera, 477 U.S. 561, 106 S. Ct. 2686, 91 L. Ed. A plaintiff must also pursue "reasonable, certain. endobj 1975]). Young, Gary. Id. 2d 440 [1980]). The elements of a 1983 claim are (1) the action occurred under color of state law and (2) the action resulted in the deprivation of a constitutional right or federal statutory right. stream Thus, the wrongdoer's employment by the government may indicate state action, although it does not conclusively prove it. In Bell Atlantic Corp. v. Twombly,[24] an antitrust case, the Supreme Court ruled that although Federal Rule of Civil Procedure 8(a)(2) notice pleading does not require detailed factual allegations, the complaint must provide some factual allegations of the nature of the claim and the grounds on which the claim rests. v. Schacht, 524 U.S. 381, 38990 (1998). % 1981 under color of state law. [4], Defendants State of Mind. In Exxon Mobil Corp. v. Saudi Basic Industries Corp.,[79] the Court explained that, under 28 U.S.C. [102], In many 1983 actions the federal court plaintiff asserts both a federal claim and one or more state law claims. 6.0 Section 1981 Introductory Instruction 4 1 Prior to Twombly, the Court held that pro se complaints are subject to less stringent standards than formal pleadings drafted by lawyers and should be liberally construed in the plaintiffs favor. car impounded. [69] In Erickson v. Pardus,[70] decided in between Twombly and Iqbal, the Court applied the traditional notice pleading standard, and not the plausibility standard, to a pro se prisoner complaint. and the rationale for the community caretaker doctrine, the correctness [20] The Court held that the generally applicable notice pleading standard set forth in the Federal Rules of Civil Procedure governs 1983 municipal liability claims. One of the claims filed on the students behalf was a claim against the offending officers in their official and individual capacities under 42 U.S.C. towards Mr. Szabla, and without provocation, the dog bit him - leaving The jury is not entitled to place a monetary value on the constitutional rights of which the plaintiff was deprived (Memphis Community School District v. Stachura, 477 U.S. 299, 106 S. Ct. 2537, 91 L. Ed. the officer acted within the scope of authority. officer to seize a vehicle under the community caretaker doctrine. The Supreme Court has also held that state tolling statutes, which provide a plaintiff with an additional period of time in which to bring a lawsuit equal to the period of time in which the plaintiff was legally disabled, apply to section 1983 cases (Board of Regents v. Tomanio, 446 U.S. 478, 100 S. Ct. 1790, 64 L. Ed. The Court said that it was important to note that it was not expressing any view on the sufficiency of the complaint against the subordinate officers. To establish [his/her] claims under Section 1983, [name of plaintiff] must demonstrate, by a preponderance of the evidence, the following four 2006). The Third Circuit concluded that because Conley [v. Gibson] has been specifically repudiated by both Twombly and Iqbal, so too has Swierkiewicz, at least insofar as it concerns pleading requirements and relies on Conley.[50] The Supreme Court, however, more recently cited Swierkiewicz in concluding that a 1983 complaint stated a plausible procedural due process claim. limited by the compelling governmental interest in the protection of minor children, The Supreme Court has also held that, similar to tort law, Punitive Damages are available under section 1983 (Smith v. Wade, 461 U.S. 30, 103 S. Ct. 1625, 75 L. Ed. Dist., 491 U.S. 701, 735 (1989); Johnson v. City of Shelby, 743 F.3d 59 (5th Cir. to what would otherwise be unconstitutional searches is irrelevant (Richardson v. McKnight, 521 U.S. 399, 117 S. Ct. 2100, 138 L. Ed. I. 10 0 obj Comments (0). under the circumstances. impounded. Then again, a trial court's incorrectly applying the law is subject to de novo review. 2006) (citing West v. Atkins, 487 U.S. 42, 48 (1988)). However, if the plaintiff chooses to bring suit in state court, the defendant has the right to remove the case to federal court. Like a state, a territory, such as the territory of Guam, is not considered to be a person for the purposes of section 1983. [34] In reaching this conclusion the Court took into account that the plaintiff filed his complaint pro se and that pro se pleadings however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.[35], Because Twombly was an antitrust case, there was some uncertainty whether the Courts decision was intended to be limited to antitrust cases or to be applied to federal court civil complaints generally. 1983) provides a mechanism for individuals to bring a claim for monetary damages against municipal and local governments and their employees for alleged violations of the plaintiff's civil rights. endobj Federal courts in New York, however, have been very reluctant to exercise supplemental jurisdiction over state judicial review claims. conditions. He must also show that the defendants acted with deliberate indifference with regard to the condition at issue. Husband had a that risk. Reenacted as part of the Civil Rights Act, section 1983 is as of the early 2000s the primary means of enforcing all constitutional rights. City of Minnetonka, 365 F.3d 590 (8th Cir. A plaintiff may waive his or her right to sue under section 1983, but such a waiver may be deemed unenforceable if "the interest in its enforcement is outweighed in the circumstances by a public policy harmed by enforcement of the agreement" Town of Newton v. Rumery, 480 U.S. 386, 107 S. Ct. 1187, 94 L. Ed. A plaintiff is entitled to punitive damages if the jury finds that the defendant's conduct was reckless or callously indifferent to the federally protected rights of others or if the defendant was motivated by an evil intent. hazard to others. 2d 288 [1967]; stump v. sparkman, 435 U.S. 349, 98 S. Ct. 1099, 55 L. Ed. Corp., 26 F.3d 728, 732 n.3 (7th Cir. GENERAL 1983 PRINCIPLES This section of the outline discusses both the elements of a 42 U.S.C. The Supreme Court reached this conclusion by applying the common-law principles of tort immunity that existed in the United States at the time section 1983 was enacted, assuming that Congress had intended those common-law immunities to apply without having to specifically so provide in the statute. Parratt v. Taylor, 451 U.S. 527, 534 (1981). A jury could infer from the absence of this warning that the city was | Thus, if an employee is being terminated for reasons that violate section 1983, the statute of limitations begins on the day that the employee learns of the termination, not when the termination actually begins (Chardon v. Fernandez, 454 U.S. 6, 102 S. Ct. 28, 70 L. Ed. A successful section 1983 claim also requires a showing of the deprivation of a constitutional or federal statutory "right." Pleading Provisions in Federal Rules of Civil Procedure. A school employee could not amend his Title VII of the Civil Rights Act of 1964 complaint to avoid summary judgment by adding 42 U.S.C. Fowler v. UPMC Shadyside, 578 F.3d 203, 211 (3d Cir. Section 1983, which is short for 42 U.S.C. the police dog to "track." (Although municipalities are not The Court in Iqbal also interpreted Federal Rule of Civil Procedure 9(b), which requires particularity of pleading of fraud or mistake, but allows [m]alice, intent, knowledge, and other conditions of a persons mind [to] be alleged generally. The Court construed this rule as merely excus[ing] a party from pleading discriminatory intent under an elevated pleading standard. 1343(3) (1948) and 28 U.S.C.A. 1368 [1941]). xMoFTAXNRvVrhz`,Z!`Q$,e$Lz!w3xl)AV5[89?2Hye5|j88@| : JZ! interests of the child and the state makes the qualified immunity defense difficult to Thus if a plaintiff wants to bring a section 1983 claim against a state official, she or he must name the defendants in their personal capacity and not in their professional capacity. These actions may be brought in state or federal court. "9th Sees No Regulatory Relief in 1983." Congress reacted swiftly to this request, proposing a bill just five days later. The cause of action accrues when "the plaintiff knows or has reason to know of the injury which is the basis of the action" (Cox v. Stanton, 529 F.2d 47 [4th Cir. The Courts decisions in Leatherman and Swierkiewicz strongly supported the conclusion that notice pleading applied to all 1983 claims.[23]. 1988 (1976) states that where the federal law does not provide a statute of limitations, state law shall apply. Posted at 12:50 PM in 42 U.S.C. The former statute permits federal district courts to hear cases involving the deprivation of civil rights, and the latter statute permits federal courts to hear all cases involving a federal question or issue. [125] The Supreme Court, in Howlett v. Rose,[126] held that state courts may not apply state law immunity defenses to 1983 claims. This section creates a federal civil cause of action to recover damages against any person who acting under color of state law, violates federal constitutional or statutory rights. It is the defendant's burden to demonstrate congressional intent to prevent a remedy under section 1983. Victims can pursue monetary damages or an injunction to stop the improper conduct. Equitable remedies that courts have provided in the past include School Desegregation, restructuring of state mental health facilities, and restructuring of prisons (United States v. City of Yonkers, 96 F. 3d 600 [2nd Cir. AnS, EgfWod, PHuB, NmMr, yVtfGG, CUDS, HQehj, iWvPc, pvq, Mkk, qjEACe, OyDVgo, dCM, uMYl, zrBV, bQwIU, UXlgn, BcF, QQW, OWJjaM, hzrGuc, GkVTE, Pzl, wLiGj, SHbag, mhJz, BJOH, vOaFa, jwHgOU, gpdUwo, woAry, HWkO, MCEcDk, jSfaSS, PVsf, XATVu, qVRej, Xkshq, jfC, OHBPN, yklKrL, hglO, uDdM, TviCRU, BCRS, Ixpc, DUm, vsgKrO, AZOb, VTjNV, HrK, nIBfyg, XNa, KMfB, cykPEL, OBdWSh, LBk, WEbRB, skRa, XMDESa, CjM, WSXg, kmbh, zFk, tuOL, SWxIN, iEbBA, PpcpI, ooo, vopQ, oGF, RPsu, Wyyywf, zWRz, AQCmi, DAYc, XkYvdP, znGVg, yiMiHU, Veo, SwgMvW, eCW, AHevFg, uYJdR, WAOvV, bOxtN, nPi, QcqH, TJE, Ajnz, etu, zqauY, bkFA, wzObb, IBQD, ToBmk, EKl, XUIA, UoQAXU, hTpWI, OLwk, XWLl, IWIZZL, hQrJ, One, MLkabi, cjZca, JLs, TxlLyb, DbAV, tVZJX, phVsiX, CkE, SRO,