Jurisdiction, p. 101ffJurisdiction, p. 101ff

The power of a state to exercise jurisdiction is not unlimited. The power of a state to exercise jurisdiction is not unlimited. National jurisdiction is divided into legislative jurisdiction, National jurisdiction is divided into legislative jurisdiction,

also called prescriptive; adjudicative; or executive (the latter also called prescriptive; adjudicative; or executive (the latter two are sometimes called enforcement jurisdiction).two are sometimes called enforcement jurisdiction).

U.S. law students have already been introduced to the U.S. law students have already been introduced to the principles of jurisdictional limitation at the internal national principles of jurisdictional limitation at the internal national level in Civil Procedure classes when students study the level in Civil Procedure classes when students study the limits of state (such as California or New Hampshire) limits of state (such as California or New Hampshire) jurisdiction. In order to demonstrate a basis for jurisdiction jurisdiction. In order to demonstrate a basis for jurisdiction in a US state, what needs to be shown? What U.S. law in a US state, what needs to be shown? What U.S. law requires such limitations?requires such limitations?

At the international level, for example, do you think the At the international level, for example, do you think the French legislature could pass a law making it illegal for and French legislature could pass a law making it illegal for and Italian to kill another Italian in Rome? Why? Italian to kill another Italian in Rome? Why?

Bases for State JurisdictionBases for State Jurisdiction

In order for a State to exercise jurisdiction, In order for a State to exercise jurisdiction, there must be one, or more of the following there must be one, or more of the following jurisdictional bases: Territorial; Nationality; jurisdictional bases: Territorial; Nationality; Passive Personality (victim nationality) in Passive Personality (victim nationality) in limited circumstances; Protective; or limited circumstances; Protective; or Universal. Universal.

We shall study each of these bases.We shall study each of these bases.

The Territorial PrincipleThe Territorial Principle

When persons, organizations or activities are When persons, organizations or activities are within a state’s territory then that state can within a state’s territory then that state can legislate, adjudicate and enforce its regulations legislate, adjudicate and enforce its regulations with respect to those persons, organizations or with respect to those persons, organizations or activities. The difficult cases arise when a state activities. The difficult cases arise when a state tries to regulate persons, organizations or tries to regulate persons, organizations or activities located outside the state when the state activities located outside the state when the state determines that those entities or activities have an determines that those entities or activities have an effect within the state. For example, when OPEC effect within the state. For example, when OPEC sets the price of oil, the price set for oil has a world sets the price of oil, the price set for oil has a world wide effect. Does that mean that every nation can wide effect. Does that mean that every nation can regulate the activities of OPEC? regulate the activities of OPEC?

U.S. v. Aluminum Co. of America Limited U.S. v. Aluminum Co. of America Limited (a Canadian corporation) (a Canadian corporation) U.S. Ct of Appeals 1945U.S. Ct of Appeals 1945

What acts, in general does the U.S. Sherman Act prohibit? What acts, in general does the U.S. Sherman Act prohibit? Describe the “Alliance” that the Canadian Aluminum Describe the “Alliance” that the Canadian Aluminum

Company had formed.Company had formed. What was the 1936 agreement designed to do? What was the 1936 agreement designed to do? Why did the court decide that the activities of the Alliance Why did the court decide that the activities of the Alliance

were in violation of the Sherman Act?were in violation of the Sherman Act? Do you think that the Canadian, French, German, Swiss Do you think that the Canadian, French, German, Swiss

and British companies, who had formed a company in and British companies, who had formed a company in Switzerland, and who met in Europe to decide upon their Switzerland, and who met in Europe to decide upon their trading policies should be subject to US law, in light of the trading policies should be subject to US law, in light of the fact that the laws of their own countries did not prohibit fact that the laws of their own countries did not prohibit what they were doing? what they were doing?

The Nationality PrincipleThe Nationality Principle

The state may assert jurisdiction over a The state may assert jurisdiction over a person or entity on the basis of nationality, person or entity on the basis of nationality, even if the person or entity happens to be even if the person or entity happens to be outside the state of citizenship. outside the state of citizenship.

If you are a US citizen, which US laws apply If you are a US citizen, which US laws apply to you, because you are a US citizen, even to you, because you are a US citizen, even when you are outside the US? If you are when you are outside the US? If you are citizen of another country, which laws of citizen of another country, which laws of your country apply to you even when you your country apply to you even when you are outside your own country? are outside your own country?

Passive Personality Passive Personality (Victim Nationality) Jurisdiction(Victim Nationality) Jurisdiction

This basis of jurisdiction permits the state to assert jurisdiction based This basis of jurisdiction permits the state to assert jurisdiction based on the nationality of the victim of the acts prohibited but it is only on the nationality of the victim of the acts prohibited but it is only permitted in limited circumstances. For example, the U.S. could not permitted in limited circumstances. For example, the U.S. could not assert jurisdiction over the usual type of criminal murder of a US citizen assert jurisdiction over the usual type of criminal murder of a US citizen that took place outside the U.S. Nor could China assert jurisdiction that took place outside the U.S. Nor could China assert jurisdiction over the murder of a Chinese citizen that occurred in Paris or New over the murder of a Chinese citizen that occurred in Paris or New York. If, however, a plane with U.S. passengers was hijacked, the US York. If, however, a plane with U.S. passengers was hijacked, the US could make the hijacking illegal under its law, even though the criminal could make the hijacking illegal under its law, even though the criminal was not a U.S. citizen and the hijacking had not occurred in the US. was not a U.S. citizen and the hijacking had not occurred in the US. Similarly, China could prohibit and prosecute such activities where Similarly, China could prohibit and prosecute such activities where some of the passengers were Chinese even though all of the activities some of the passengers were Chinese even though all of the activities occurred outside China and the perpetrator was not Chinese. The occurred outside China and the perpetrator was not Chinese. The question of getting hold of the perpetrator is a different issue. Merely question of getting hold of the perpetrator is a different issue. Merely because a state has a good basis for the assertion of jurisdiction, that because a state has a good basis for the assertion of jurisdiction, that does not give the state the right to enter another country and capture does not give the state the right to enter another country and capture the alleged perpetrator. the alleged perpetrator.

U.S. v. Fawaz Yunis, a/k/a Nazeeh U.S. v. Fawaz Yunis, a/k/a Nazeeh U.S. Ct. of Appeals 1991U.S. Ct. of Appeals 1991

What was it alleged that Yunis had done?What was it alleged that Yunis had done? How did Yunis end up in the US? Why didn’t How did Yunis end up in the US? Why didn’t

the method of Yunis’ capture defeat the the method of Yunis’ capture defeat the court’s jurisdiction?court’s jurisdiction?

What was the basis for US jurisdiction?What was the basis for US jurisdiction? Which other nations could have tried Yunis?Which other nations could have tried Yunis? How broad is passive personality How broad is passive personality

jurisdiction?jurisdiction?

The Protective PrincipleThe Protective Principle

Certain activities may be perceived as threatening the Certain activities may be perceived as threatening the security of the state and thus the state may prohibit such security of the state and thus the state may prohibit such activities even if they are carried on outside the state by activities even if they are carried on outside the state by non-nationals of that state. For example, using the non-nationals of that state. For example, using the protective principle, Sweden could pass laws prohibiting protective principle, Sweden could pass laws prohibiting counterfeiting of the krona by anyone, anywhere in the counterfeiting of the krona by anyone, anywhere in the world. (Note: the mere fact that a state has legislative world. (Note: the mere fact that a state has legislative jurisdiction to prohibit an activity outside the state DOES jurisdiction to prohibit an activity outside the state DOES NOT permit that state to capture the alleged criminal NOT permit that state to capture the alleged criminal unless the criminal is within the state or unless the state unless the criminal is within the state or unless the state can otherwise get personal jurisdiction over the person, can otherwise get personal jurisdiction over the person, such as through an extradition treaty. ) such as through an extradition treaty. )

US v. Bin Laden U.S. District Ct 2000

What had the defendants allegedly done? Why did the court determine that the acts

and persons were within the permissible scope of US jurisdiction? (and that the legislation prohibiting such acts was intended to reach foreign persons carrying out activities in foreign states?)

The Universality PrincipleThe Universality Principle

All the other bases of state jurisdiction require some sort of All the other bases of state jurisdiction require some sort of connection with the state asserting jurisdiction. Some connection with the state asserting jurisdiction. Some activities are considered so evil that the international activities are considered so evil that the international community has waived the usual requirement of a community has waived the usual requirement of a connection with the forum state and has permitted any connection with the forum state and has permitted any state that gets hold of the alleged perpetrator of such acts state that gets hold of the alleged perpetrator of such acts to try the person, even though the acts did not occur in the to try the person, even though the acts did not occur in the state’s territory, the person is not a national of that state, state’s territory, the person is not a national of that state, the victims are not nationals of that state and the state’s the victims are not nationals of that state and the state’s security is not threatened by the activity. The types of security is not threatened by the activity. The types of activities that permit universal jurisdiction are genocide, activities that permit universal jurisdiction are genocide, war crimes, crimes against humanity, torture, slavery, war crimes, crimes against humanity, torture, slavery, piracy, operating a stateless vessel. piracy, operating a stateless vessel.

A-G of Israel v. EichmannA-G of Israel v. EichmannJudgment of the Supreme Court of Israel Judgment of the Supreme Court of Israel

(1962) (1962) How did Israel get personal jurisdiction over Eichmann?How did Israel get personal jurisdiction over Eichmann? Run through all of the possible bases of jurisdiction that Run through all of the possible bases of jurisdiction that

Israel might have asserted to establish jurisdiction over Israel might have asserted to establish jurisdiction over Eichmann for the murder of Jews and others occurring in Eichmann for the murder of Jews and others occurring in Europe during WWII (1939-45).Europe during WWII (1939-45).

Which, if any, of these bases do you find convincing?Which, if any, of these bases do you find convincing? Why did the court refuse to decline jurisdiction on the basis Why did the court refuse to decline jurisdiction on the basis

of Israel’s violation of Argentina’s sovereignty? Why of Israel’s violation of Argentina’s sovereignty? Why shouldn’t the remedy for that violation run to the shouldn’t the remedy for that violation run to the defendant? defendant?

Which other countries might have had a better basis for Which other countries might have had a better basis for trying Eichmann? Would they have provided a better trying Eichmann? Would they have provided a better forum?forum?

Arrest Warrant CaseArrest Warrant Case (Congo v. Belgium) 2002 I.C.J. 3(Congo v. Belgium) 2002 I.C.J. 3

What crimes did the arrest warrant issued by What crimes did the arrest warrant issued by Belgium accuse Yerodia of committing?Belgium accuse Yerodia of committing?

What was the basis for Belgium’s assertion of What was the basis for Belgium’s assertion of jurisdiction over Yerodia?jurisdiction over Yerodia?

Who was Yerodia and where did his alleged Who was Yerodia and where did his alleged crimes take place? Against whom were the alleged crimes take place? Against whom were the alleged crimes committed?crimes committed?

The ICJ upheld the right of immunity for Yerodia The ICJ upheld the right of immunity for Yerodia (see the ICJ immunity decision at pp. 164ff.) so it (see the ICJ immunity decision at pp. 164ff.) so it did not discuss the basis of Belgium’s jurisdiction, did not discuss the basis of Belgium’s jurisdiction, although several separate opinions did so.although several separate opinions did so.

These judges thought the Court should have ruled on the legitimacy of These judges thought the Court should have ruled on the legitimacy of Belgium’s jurisdiction before considering the issue of immunity and Belgium’s jurisdiction before considering the issue of immunity and noted that the arrest warrant must have been based on universal noted that the arrest warrant must have been based on universal jurisdiction as the Belgian legislation permits the assertion of universal jurisdiction as the Belgian legislation permits the assertion of universal jurisdiction for serious violations of international humanitarian law (the jurisdiction for serious violations of international humanitarian law (the laws of war) without any connection to Belgium. Other states’ laws of war) without any connection to Belgium. Other states’ legislation for prosecuting war crimes requires some connection with legislation for prosecuting war crimes requires some connection with the forum or indicates which treaty must have been violated. Case law the forum or indicates which treaty must have been violated. Case law also requires a connection with the forum or a treaty violation. The also requires a connection with the forum or a treaty violation. The Geneva Conventions require prosecution or extradition of persons Geneva Conventions require prosecution or extradition of persons found within their territory accused of grave violations of the found within their territory accused of grave violations of the Conventions.Conventions.

Q: Must the accused be in the territory of the state asserting Q: Must the accused be in the territory of the state asserting jurisdiction to validate universal jurisdiction? Had Belgium actually jurisdiction to validate universal jurisdiction? Had Belgium actually asserted jurisdiction by issuing an arrest warrant or was it simply asserted jurisdiction by issuing an arrest warrant or was it simply preparing to assert jurisdiction? preparing to assert jurisdiction?

Arrest Warrant CaseArrest Warrant Case: Joint Separate: Joint Separate Opinion Opinion of Judges Higgins, Kooijmans & Buergenthalof Judges Higgins, Kooijmans & Buergenthal

Q: Are these judges endorsing universal jurisdiction or not? Q: Are these judges endorsing universal jurisdiction or not? If so, in what circumstances? If so, in what circumstances?

Note: In 2003, Belgium restricted its jurisdictional statute Note: In 2003, Belgium restricted its jurisdictional statute after some members of NATO threatened to call for moving after some members of NATO threatened to call for moving the HQ of NATO out of Brussels. the HQ of NATO out of Brussels.

Q: What does this hostility to, or reluctance to address the Q: What does this hostility to, or reluctance to address the legitimacy of, universal jurisdiction teach us about legitimacy of, universal jurisdiction teach us about that basis that basis for jfor jurisdiction? urisdiction?

Arrest Warrant CaseArrest Warrant Case: Joint Separate Opinion of : Joint Separate Opinion of Judges Higgins, Kooijmans & Buergenthal continuedJudges Higgins, Kooijmans & Buergenthal continued

ExtraditionExtradition What is extradition? Does it require a treaty?What is extradition? Does it require a treaty? US v. Alvarez- MachainUS v. Alvarez- Machain, 504 U.S. 655 (1992), 504 U.S. 655 (1992) What was it that A-M was alleged to have done?What was it that A-M was alleged to have done? How did A-M come to the US?How did A-M come to the US? Why didn’t the US use the US-Mexican extradition treaty to get Why didn’t the US use the US-Mexican extradition treaty to get

custody of A-M? custody of A-M? What is the rule of specialty?What is the rule of specialty? What was A-M’s central argument?What was A-M’s central argument? Why didn’t that argument work?Why didn’t that argument work? Do you agree with the Court’s interpretation of the US-Mexican Do you agree with the Court’s interpretation of the US-Mexican

extradition treaty? Why did Justices Stevens, Blackmun and O’Connor extradition treaty? Why did Justices Stevens, Blackmun and O’Connor dissent? dissent?

Q: If you represented State X that had an extradition treaty with the US Q: If you represented State X that had an extradition treaty with the US with essentially the same language as the US-Mexican treaty, what with essentially the same language as the US-Mexican treaty, what language would you want inserted into a revised treaty?language would you want inserted into a revised treaty?

Immunity from Jurisdiction: Diplomatic Immunity: Immunity from Jurisdiction: Diplomatic Immunity: Read The Vienna Convention on Diplomatic Read The Vienna Convention on Diplomatic

Relations, Epps, Doc. Supp. p. 127ffRelations, Epps, Doc. Supp. p. 127ff

Why give diplomats immunity at all?Why give diplomats immunity at all? How broad is diplomatic immunity under the How broad is diplomatic immunity under the

Convention? See VCDR arts. 23, 29,31, 39(2).Convention? See VCDR arts. 23, 29,31, 39(2). What if an ambassador murders someone while What if an ambassador murders someone while

s/he is serving as ambassador abroad? What can s/he is serving as ambassador abroad? What can the host state do? See VCDR arts. 9, 32(1).the host state do? See VCDR arts. 9, 32(1).

What about the embassy buildings, the diplomatic What about the embassy buildings, the diplomatic papers and the diplomatic bag? See VCDR arts. papers and the diplomatic bag? See VCDR arts. 22(1), 24, 27, 30. 22(1), 24, 27, 30.

Should the scope of diplomatic immunity be Should the scope of diplomatic immunity be narrowed? If so, how?narrowed? If so, how?

US Diplomatic and Consular StafUS Diplomatic and Consular Staff f CaseCase (U.S. v. Iran) 1980 I.C.J. 3(U.S. v. Iran) 1980 I.C.J. 3

What happened to give rise to this case?What happened to give rise to this case? Why was Iran responsible for the actions of the students?Why was Iran responsible for the actions of the students? Which provisions of the VCDR (and the VCCR) were Which provisions of the VCDR (and the VCCR) were

found to have been violated by Iran?found to have been violated by Iran? Why did the Court not accept Iran’s argument that US Why did the Court not accept Iran’s argument that US

interference in the internal affairs of Iran (allegedly through interference in the internal affairs of Iran (allegedly through the CIA’s engineering the overthrow of the government the CIA’s engineering the overthrow of the government headed by Dr. Mossadegh in 1953 and then substituting headed by Dr. Mossadegh in 1953 and then substituting the Shah) justified the embassy and consulate seizures?the Shah) justified the embassy and consulate seizures?

If a foreign diplomat commits a serious crime, can If a foreign diplomat commits a serious crime, can the host state ever prosecute the diplomat? the host state ever prosecute the diplomat?

Who was Makharadze? How was it possible that Who was Makharadze? How was it possible that he had been convicted of crimes in the U.S.?he had been convicted of crimes in the U.S.?

What is the gist of Knaab’s complaint? What is the gist of Knaab’s complaint? Why did the court dismiss the complaint even Why did the court dismiss the complaint even

though Makharadze was no longer a diplomat and though Makharadze was no longer a diplomat and the Republic of Georgia had waived his immunity the Republic of Georgia had waived his immunity for the criminal case?for the criminal case?

Knaab [representative of Waltrick’s estate] v. Knaab [representative of Waltrick’s estate] v. Republic of GeorgiaRepublic of Georgia

U.S. District Court 1998U.S. District Court 1998

Case Concerning Armed Activities on the Territory of Case Concerning Armed Activities on the Territory of the Congothe Congo

(Democratic Republic of Congo v. Uganda) (Democratic Republic of Congo v. Uganda) 2005 I.C.J.--- (Uganda’s second counter-claim)2005 I.C.J.--- (Uganda’s second counter-claim)

What was Uganda’s claim?What was Uganda’s claim? Does the VCDR apply during armed Does the VCDR apply during armed

conflict? Does this make sense?conflict? Does this make sense? How could Uganda represent the claims of How could Uganda represent the claims of

both Ugandan citizens and noncitizens?both Ugandan citizens and noncitizens?

Consular ImmunityConsular Immunity

Read the Vienna Convention on Consular Read the Vienna Convention on Consular Relations, Epps Doc. Supp. p. 141ffRelations, Epps Doc. Supp. p. 141ff

How is the scope of consular immunity How is the scope of consular immunity different from the scope of diplomatic different from the scope of diplomatic immunity? immunity?

Could a consular officer be prosecuted for Could a consular officer be prosecuted for murder or drug dealing if the consul’s state murder or drug dealing if the consul’s state refused to waive his/her immunity?refused to waive his/her immunity?

Head of State and Other Ministers’ Immunity Head of State and Other Ministers’ Immunity Regina v. Bow Street Magistrates Ex Parte Regina v. Bow Street Magistrates Ex Parte

Pinochet, House of Lords, UK 1999 Pinochet, House of Lords, UK 1999

Who was Pinochet?Who was Pinochet? How did he get to the UK? How did he get to the UK? What did Spain have to do with the case?What did Spain have to do with the case? What crimes did Spain accuse Pinochet of What crimes did Spain accuse Pinochet of

committing?committing? What was the basis for Spain’s jurisdiction? Is What was the basis for Spain’s jurisdiction? Is

such a basis for jurisdiction a good idea?such a basis for jurisdiction a good idea?

Head of State and Other Ministers’ Immunity Head of State and Other Ministers’ Immunity Regina v. Bow Street Magistrates Ex Parte Regina v. Bow Street Magistrates Ex Parte

Pinochet, House of Lords, UK 1999 continuedPinochet, House of Lords, UK 1999 continued What is an extradition treaty?What is an extradition treaty? What is the double criminality principle in What is the double criminality principle in

extradition treaties? How does the UK apply the extradition treaties? How does the UK apply the double criminality provision? double criminality provision?

What was the scope of immunity accorded to What was the scope of immunity accorded to Pinochet? What law establishes this immunity? Pinochet? What law establishes this immunity?

Finish this sentence: The UK court upheld Finish this sentence: The UK court upheld immunity on all claims against Pinochet immunity on all claims against Pinochet except…………because…………except…………because…………

Why was Pinochet never sent to Spain?Why was Pinochet never sent to Spain? Pinochet died in 2006 before the Chilean cases Pinochet died in 2006 before the Chilean cases

were concludedwere concluded..

Arrest Warrant CaseArrest Warrant Case(D.R.Congo v. Belgium)(D.R.Congo v. Belgium)

2002 I.C.J. 32002 I.C.J. 3

What crimes was Yerodia alleged to have committed?What crimes was Yerodia alleged to have committed? On what basis did Belgium assert jurisdiction over On what basis did Belgium assert jurisdiction over

Yerodia?Yerodia? Finish this sentence: The Court upheld immunity from Finish this sentence: The Court upheld immunity from

Belgian jurisdiction for Yerodia because ……….Belgian jurisdiction for Yerodia because ………. On what sources of law did the Court rely? On what sources of law did the Court rely?

Arrest Warrant CaseArrest Warrant Case(D.R.Congo v. Belgium)(D.R.Congo v. Belgium) 2002 I.C.J. 3 continued2002 I.C.J. 3 continued

Why was Belgium not permitted to be a persistent objector?Why was Belgium not permitted to be a persistent objector? Why did the ICJ not find the statutes of Nuremberg, the ICTY, Why did the ICJ not find the statutes of Nuremberg, the ICTY,

ICTR and ICC, which accord individual culpability to persons ICTR and ICC, which accord individual culpability to persons even if they hold high government positions, persuasive? even if they hold high government positions, persuasive?

Suppose Belgium wanted to try Yerodia for torture occurring Suppose Belgium wanted to try Yerodia for torture occurring before he became FM. Would he still have immunity? When before he became FM. Would he still have immunity? When would his immunity cease?would his immunity cease?

If the If the Pinochet Pinochet case came before the UK or any other national case came before the UK or any other national courts today, do you think that thecourts today, do you think that the Arrest Warrant Case Arrest Warrant Case would require the court to accord Pinochet immunity? What would require the court to accord Pinochet immunity? What remedy did the Court order?remedy did the Court order?

There is a blistering dissent in this case by Judge There is a blistering dissent in this case by Judge ad hocad hoc Christine Van den Wyngaert. Christine Van den Wyngaert.

Immunity of International Immunity of International OrganizationsOrganizations

Before a major international organization, particularly Before a major international organization, particularly a governmental international organization, will be a governmental international organization, will be willing to locate offices or headquarters within a willing to locate offices or headquarters within a particular state, the organization will want to enter particular state, the organization will want to enter into a treaty with the host state spelling out certain into a treaty with the host state spelling out certain immunities from the jurisdiction of the host state for immunities from the jurisdiction of the host state for persons employed by the organization or traveling to persons employed by the organization or traveling to the organization to take part in its activities. For the organization to take part in its activities. For example, the U.S. has such a treaty with the United example, the U.S. has such a treaty with the United Nations regarding the UN headquarters in New York.Nations regarding the UN headquarters in New York.

Sovereign Immunity and Sovereign Immunity and The Act of State DoctrineThe Act of State Doctrine

What is Absolute Foreign Sovereign Immunity and What is What is Absolute Foreign Sovereign Immunity and What is Restrictive Foreign Sovereign Immunity and what theory Restrictive Foreign Sovereign Immunity and what theory underlies these concepts?underlies these concepts?

What view of foreign sovereign immunity in US courts is What view of foreign sovereign immunity in US courts is favored by Legal Adviser Tate? Why does he take this favored by Legal Adviser Tate? Why does he take this position?position?

Many developed states now have legislation governing the Many developed states now have legislation governing the scope of immunity for foreign sovereigns in their courts. scope of immunity for foreign sovereigns in their courts. For example the U.S. Congress has passed The Foreign For example the U.S. Congress has passed The Foreign Sovereign Immunities Act of 1976 which adopts the Sovereign Immunities Act of 1976 which adopts the restrictive theory of foreign sovereign immunity.restrictive theory of foreign sovereign immunity.

What is The Act of State Doctrine?What is The Act of State Doctrine?

Problem p. 177-178Problem p. 177-178

First read First read The Nottebohm Case The Nottebohm Case (Liechtenstein v. Guatemala) 1955 I.C.J.4 at (Liechtenstein v. Guatemala) 1955 I.C.J.4 at pps. 270-275.pps. 270-275.

Then read the problem on pps. 177-178.Then read the problem on pps. 177-178. Next, answer questions 1 and 2 on p. 178.Next, answer questions 1 and 2 on p. 178.