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A Constitutional Analysis On Abortion

Spoiler I am Pro Choice

A Textural and Adaptive Understanding of the US Constitution’s 10th&14th Amendments and how they apply to US Abortion Issues.

Fair Warning this is gonna be a A LONG READ. If you are not prepared for a long breakdown of the US Constitution and many many many other factors that go into a analysis. Please keep scrolling. I almost lost my sanity writing this.

For those of you continuing this journey. You’re welcome for the brain pain.

The Prologue

In this article we will be breaking down the claim that Abortion is a US Constitutionally Protected right. In this article we will be breaking down the US Constitution in 2 ways, through Textualism and Adaptive Law. This article is a opinionated peace done through research and understanding of the US Constitution. This Article in no way, shape, means, or forum shall be taken as Legal Council and shall be treated purely in a opinionated manor. Not of one from a expert review. It is the hopes of this article to challenge both pro life and pro choice voters, to research and interpret the law in new or different manors.

Chapter 1

Textural Review

Beginning our textural interpretation of the US Constitution, we must first understand what a textural interpretation is. As Defined by the US Congress along with Harvard, Princeton, Stanford, Yale, and all other US Practicing Law Schools. Textualism is a mode of legal interpretation that focuses on the plain meaning of the text of a legal document. Textualism usually emphasizes how the terms in the Constitution would be understood by people at the time they were ratified(or put into place), as well as the context in which those terms appear. An example of Textualism can be seen by US Associate Justice Antonio Scalia, when they argued against US Judges treating the Constitution as a Living Constitution.

For the sake of the chapter of this article, we shall stand by the traditional meaning of Textualism as stated above.

Subchapter 1-1

The 10th Amendment

“The powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to the people.”-10th Amendment, US Constitution, December 15th, 1791

What I want to, from a textural interpretation, focus on, when applying the 10th amendment to abortion, is the portion of delegation. The US 10th Amendment gives us a power chain strictly from the beginning. Which shows truly before times of the Civil War what the protocol of law should be. Which is US, State, then People.

Now when we are speaking of 1791 and looking back into the day of ratification, we can see this was in about mid way through George Washington’s first term as President of the newly United States. This was also the famous time of The Bill Of Rights, and as Historically notated, was introduced by James Madison, to win both houses of Congress and States. Focusing on Rights-related amendments, ignoring suggestions that would have structurally changed the government. While argumentatively protecting the people of the United States from being trampled upon by their newly found government. At this time the main freedoms in fear were that of Speech, Press, Religion, Searches, and Seizures.

So when we are applying the 10th Amendment to Abortion, in a textural understanding, we must focus on those primary objectives of the amendment.

Let’s start with a main and sought out claim of Religion. When we turn the pages of current review of world religions and their stances on Abortion. The topic is muddy at best. While some Religious leaders see abortion affirming interpretations others are seeing the polar opposite. Which leads us to a stand still.

Because the US Government cannot establish religious views per the First Amendment. But also the people cannot establish an across-the-board understanding of their own either. Which leads to a puzzle. How can you justifiably use Religious Freedom to protect your right to an Abortion, if you have no textural consensus of that right within your own? The simple and sad answer? You can’t.

With opposing experts and religious leaders conflicting on their views of the matter. You would be hard pressed, at best, to prove to the government that this does in fact tie into your religious beliefs. Thus for defacing your argument if you were to obtain a universal consensus in the future.

So let’s focus on the not so commonly challenged rights of focus during the time. Search and Seizure.

When we look into Search and Seizure issues of the time they were primarily surrounding property in all regards. From land, livestock, homes, crops, and in some cases children. Now that’s where I would like to begin my focus. Children and their historical application to parents to be treated as property vs American Citizens of the United States.

When we look back towards 1791 and into the issue, we can see multiple cases where children are treated as property in both criminal and civil law. When it’s for simple property damages caused by a child and the parents are held civilly liable. Or if it’s where a child has in deed committed a crime and the parents were then held criminally responsible.

We can look back into history and even find a recent textual beginning of parental responsibility law in 1903 where the first Juvenile Court was constructed. And even see in modern times in Michigan when speaking of the 2021 Mass Shooting of Oxford High School.

However the question would be how were parents held responsible prior to 1903 and the establishment of Juvenile Law?

Historically speaking it was understood the crimes of the child were the crimes of the parents. Just as if a dog were to bite a child. The owner of said dog would be held responsible. Your only defining difference of charges would lean on intent. Did the parent persuade the child into beating up another or did the parents lack of supervision lead to the incident?

But I digress to remain on topic. For the sake when it comes to Search and Seizure, we can clearly see Children being deemed as property when it comes to a historical practice and understanding. And that being the property of the parents or guardians of the time.

So for the time period it would NOT be out of realm, to deem a textural understanding of a child to be properly of their said guardians or parents. So how could we texturally understand warrantless search and seizure to abortion, under this interpretation?

In some regards when it comes to medical practice it can be seen that the opinion of the US Government over any property without warrant could be seen as a seizure. As an Abortion of a child is the removal of property from the parent. And thus to seize child without warrant to remain in said womb could be deemed as a warrantless seizure. Thus now infringing upon the mothers right of protection from said action.

Most deem seizures as removal of property however this is not true in all cases. Where we witness a more commonly applied seizure of this manor to bank accounts. When speaking of a suspect of a financial crime or even a crime of financial benefit. The US Government tends to seize their assets and freeze their bank accounts.

And when considering the textural understanding a child is property of the parent of which womb the child resides. This can be now seen as a seizure of their property, when freezing the mothers option to abort their child. Because when seizing assets in a bank account the US Government doesn’t take away your money. However they freeze you from using said property during the time of seizure. This understanding can also be applied, and factually has been, when it comes to custody dispute cases and family law.

So we have established constitutional backing to the right of an abortion now right? Not necessarily. We have established a few things. And even introduced a textural understanding of seizure to children. However this does not necessarily grant you a right to an abortion under medical practice.

Using this interpretation can and historically has been very dangerous when it comes to children. Seeing children as property has historically lead to US children having less rights and freedoms than most Americans. Including currently the lack of voting and firearms rights.

However we aren’t far from making a connection through that understanding and interpretation to Abortion being a US Constitutional Right.

Now as we said at the beginning the 10th amendment hands over any powers not delegated by the US constitution to first the US Government, State, and then the people.

So now we must look at US Property Law, as we know, and the right to protection from warrantless search a seizures.

“The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.”-4th Amendment US Constitution, March 1st, 1792

While a State or federal Law is not in itself inherently a Seizure, it can surely lead to said actions. Thus looking back at even the US Gold Ban(Executive Order 6102) from US President Franklin D. Roosevelt. Which forbid the “hoarding” of gold coin, bullion, and certificates.

However this case shares something in common with abortion. And this is the argument of, what is deemed to be unreasonable?

During the time of US Executive Order 6102 we were seeing a shortage in US Gold and Silver. And the United States fiscal future was in trouble. So it was deemed reasonable due to the fact it was done in the idea of protecting and preserving the US Economy.

But How does this apply to Abortion?

Well currently the US is a unprecedented low birthing rate. While experts claim for a sustainable birthing rate to be that of 2 children per US Woman. We are at 1.62. When it comes down to percentages we are down to 12.012 births per 1000 people. Or a 1.2% birth rate. So it can be deemed reasonable, that in order to maintain a healthy birthing rate, you must limit the ability to abort potential life. Thus protecting the US Population and Economy.

However we have proven to raise our birthing rate in the United States. Because from 2021 to 2022 we have seen a .09% raise in birthing rate. But can you prove that to be of enough significance to justify not stabilizing the economy now vs later?

This would be from which your textural debate would turn gear towards a statistical debate. And when it comes down legally. This would no longer be considering the law but more so focusing on circumstances and chance.

But at this point we have now connected Abortion to a US Constitutional right but not a completely unalienable right. As this right can still, even under this interpretation and understanding, be governed against by US Law or Executive Order.

Sub chapter 1-1 Synopsis

When it comes to the 10th Amendment we have established a chain of command when it comes to Law. And that of US, State, then people.

We have found no legal consensus when it comes to the right of religion, as the US Gov is forbidden to establish US Law on religion based on the 1st Amendment. And currently the people of the United States have yet to find a consensus on either religious affirmation or damnation of abortion.

We however did find legal grounds for a right against warrantless seizures of persons/property. However we have heeded to the dangers of considering children as property and acknowledged, with cases like E.O. 6102, that this would not be an unalienable right. And subject to what is deemed reasonable or unreasonable.

So when it comes to the US Constitution’s 10th Amendment. There is currently a US Government Power delegated to the 4th Amendment protecting a woman’s right to an Abortion through textural interpretation.

Subchapter 1-2

The 14th Amendment

“No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”-14th Amendment US Constitution July 9th, 1868

When it comes to Abortion textural interpretation of the 14th Amendment I feel as if we must focus on the word “Person”. I mean that is, after all is said and done, the main grass roots of the Abortion topic of the United States. And that is…

“Can You Define Personhood?”

Personhood is currently an unsettled, while at the same time, settled argument. Much like this article, personhood is a very opinionated definition. And as it currently stands there is no medical consensus on the definition of personhood.

Legal definition has been founded as “any individual person as well as natural and legal entities”-18 U.S.C. § 2510(6) Which argumentatively still does not define a person. Because can you really use the word you are defining to define the word?

Merriam-Webster English Dictionary Defines Person as; “human, individual. sometimes used in combination especially by those who prefer to avoid man in compounds applicable to both sexes.”

But when we look into the medical world a person in the womb has yet to be founded widely. But also agreed upon at each definition.

Well what definitions do we currently have of personhood in the medical field?

We have Life defining personhood. Because without life a person would not exist. And as we currently, medically and biologically, understand, life begins at conception. Of which a 3rd set of DNA unique from both mother and father is presented.

We have Heartbeat defining personhood.

Not only seen in medical understanding but also legal. A heartbeat has been deemed as a characteristic of personhood and life. For without a heartbeat one could simply not live. We have seen this even used, previously to current abortion topics, in state legislature under the “Heartbeat Bill” presented in states like Tennessee (HB 0077) and Arizona (HB 2483).

We also have the argument of electronic brain function/development. However researchers were doing this study under the idea of defining human consciousness. Because electronic consciousness has been used to define personhood when it comes to terms of deaths and coma patients. However, at the time of writing this article, there is still no scientifical, medical, or biological finding to show at which point consciousness begins during electronic brain function. And only has been founded when it ends and defines death.

However medically all three arguments have been founded as equally valid additions to define personhood. As they all root from the same original basis of necessity to maintain life.

So can we really define personhood? Not at this current time. And we may never be able to define personhood in the future. Because of the fact there are so many factors that play into personhood, that it has become reasonably impossible to define it.

And if we use our Textural roots of defining an unknown or unsettled portion of the amendment. Well, quite frankly, it can get dangerous. As Personhood during the 1800s was used to propagate racist ideologies and present racist laws into existence.

Historically we can look back on how we used personhood to demean, demoralize, and villainize indigenous people of the United States. We also used the same tactics for slavery, segregation, Jim Crow Laws, etc….

So defining personhood through a textural debate has been done, however, it has also been deemed outdated and unconstitutional when it comes to the law. And even historically speaking, personhood has rapidly changed and evolved in definition within decades of understanding, if not faster.

So simply put. We cannot legally define personhood at this time.

Well does this end the argument of textural interpretation to validate Abortion to the US Constitution? Not Necessarily.

Because like the 4th Amendment, it also deals with property. And as we know from Subchapter 2, we have found a current interpretation of children being parental property. And have interpreted the 4th amendment to give you protection from seizure of said property in mother womb.

However this again is NOT an unalienable right. As we have seen cases before where a reasonable warrant or order can be obtained to seize your property in the interest of the US Economy.

Also applying this interpretation you also open yourself up to being seized or ordered to not terminate a pregnancy due to physical evidence in a possible sexual case.

How So?

Well if the pregnant mother is a rape victim and the pregnancy is a result of said rape. That child, fetus, or infant is now biological evidence of said rape. And terminating said child can be construed as tampering with evidence or destroying of evidence. While uncommon to charge a victim of a crime with this. It would not be out of the reach of the government to do so if they felt they had a need.

While counter arguments can be made for post mortem DNA analysis. Along with studies. With no medical necessity to the procedure of an abortion. There may not be grounds for counter.

Because unfortunately as we look into this from a textural point of view. Mental health or repercussions have not been deemed as medical necessities currently.

Now I would like to focus again onto the actual 14th amendment, of which it says specifically “No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States”. We notice the 14th amendment did say you cannot abridge the privileges of citizens of the United States.

Let’s quickly define a Privilege shall we?

Webster Defines Privilege as “a special right, advantage, or immunity granted or available only to a particular person or group.”

And Buck’s Law Dictionary defines Privilege as “A particular and peculiar benefit or advantage enjoyed by a person, company, or class, beyond the common advantages of other citizens.”

But what was the definition of Privilege back in 1791? Well the origins of privilege isn’t far off from its current definition in law or Webster. As privilege comes from Middle English privilege, from Anglo-Norman privilege and Old French privilege, from Latin prīvilēgium (“ordinance or law against or in favor of an individual”), from prīvus (“private”) + lēx, lēg- (“law”).

So what could be a particular thing that women enjoy that men cant? Oh yeah pregnancy. And also in turn Miscarriages.

And while yes they do not enjoy miscarriages this does show women have the ability to carry or not to carry child. And thus it is a privilege. Which is only available to women.

And we can define abortion to be a synonym with a miscarriage through Oxford Dictionary which defines a abortion as “The act of giving untimely birth to offspring, premature delivery, miscarriage; the procuring of premature delivery so as to destroy offspring.”

So by definition both pregnancy and abortion then would be considered privileges. And by the 14th Amendment BOTH cannot have a law made or enforced to abridge.

Subchapter 1-2 Synopsis

We have found legal grounds to connect the 14th amendment to abortion as a right through the 4th Amendment. However like the 10th amendment it is argumentatively not an unalienable right. And is subject to multiple circumstances.

However when connected Directly through the 14th amendment by using the Oxford Definition of Abortion. And pairing that with the definition of privilege. You gain not only a unalienable right to abortion but also pregnancy.

Thus through this understanding Abortion is a Unalienable and Constitutionally Protected Right.

Inter-missionary Subtract

As we review the constitution for connections to abortions I would like to review a couple major red flag issues within this article. When we are talking about property it is dangerous to speak of children unborn or born in this context due to historical discrimination through the law.

We also must take into account moving into the next portion of this article on mental health. And how the law has yet to really define it as a necessity for medical procedures. And in claiming so is also dangerous. Due to historical procedures such as lobotomies, shock therapy, etc… Which have been deemed inhumane and immoral under the color of the law.

We also must understand this article is purely focusing on the US Constitution and the understanding of, through two different tactics. And argumentatively, two polar opposite tactics. While sometimes you can use both to your advantage. It is typically one or the other when it comes between the two.

Textural Law is Hard and rigid in this writers opinion. And does not sway. Textural law is black and white. And at its roots, is by the letter it is written.

Textural understanding of the Constitution is a very tricky thing in itself however. Because using textural understanding of the US Constitution is to ignore the historical understanding of even how the constitution was intended to be treated.

Because it’s own author Thomas Jefferson can be quoted stating “All human constitutions are subject to corruption and must perish, unless, they are timely renewed and reduced to their first principles.”

And also “The purpose of a written constitution is entirely defeated if, in interpreting it as a legal document, its provisions are manipulated and worked around so that the document means whatever the manipulators wish.”

Jefferson, the author of the US Constitution has both defined & addressed Textural and Adaptive practice in these statements.

How so? Textural is very to the core and grass roots. Sticking to the wording and historical writing of the law. Which applies to renewing and reducing to their first principles.

And adaptive is interpretative, manipulative, and very much so can be viewed as a “work around”. Of which Jefferson states defeats its purpose of being written.

So when it comes to Constitutional law it, in this writers opinion, should be done from only a textural point of view. But also done in a timely repetitive action. Or it should be scrapped and rewritten.

Synopsis of this intermission is that the US Constitution as it stands is not being interpreted as it was intended to be originally, nor has it been timely renewed and taken back to its first principles.

Chapter 2

Adaptive Review

Beginning our Adaptive interpretation of the constitution and how abortion is or isn’t a constitutional right. We must first also understand what adaptive interpretation is.

Adaptive Interpretation, also known as Dynamic Interpretation is defined legally as "[t]he interpretation of a statutory provision by an interpreter is not necessarily the one which the original legislature would have endorsed" Which can be quoted from Oxford, Harvard, and many other universities.

As stated in my inter-missionary subtract adaptive interpretation is and has been deemed to be an unconstitutional review of the constitution. However for the sake of the article I will apply this logic to this topic. For the basis of the fact it is currently being used in politics and legal standings for Abortion.

Adaptive law under modern understanding is the review of old legislature to interpret into current understanding versus creation of new law.

We see Adaptive law more commonly used in case law. Where a bill, law, or legislature does not currently fit the case scenario. And thus needs to be applied to ratify a new bill, law, or legislature. And is more commonly seen in Supreme Courts and with Supreme Justices.

However before going into this chapter. Understand Adaptive Law has been controversially discussed and damned when applied to the US Constitution. For the US Constitution has argumentatively been seen as a non living document but one of stagnant foundation.

When it comes down to practice law. Adaptive Law is NOT currently widely accepted when it comes to constitutional interpretation.

Subchapter 2-1

The 10th Amendment

As we have established from Subchapter 1-1, we have found the 10th Amendment universally gives a chain of command to Law and Order. And that is of US, State, and then People.

But what we didn’t challenge was the delegation of the States to The People. We understand that currently, sense the revocation of Roe V Wade, the US does not have any powers delegated, when it comes to the regards of Abortion Rights. However how many states have actually delegated that it is not a constitutional right? Out of 50 States in the United States we have 13 states with a full ban, 5 allowing from 6-20 weeks, 8 that have decided to not change from the original Roe V Wade finding, and 22 not only legal but with new protections.

Let’s focus on the 13 for a singular minute. These states are still debating on what is a medical necessity. They still reserve the right for “Medical Necessity”. Well how is that defined currently in the law? Tennessee currently leaves No Exceptions with Lobbyists presenting legislature for medical necessities. But what is a Medical Necessity? At the current moment in most cases you have to define actually “Life Threatening”. And while medical conditions such as Ectopic Pregnancies(a pregnancy in which the fetus develops outside the uterus, typically in a fallopian tube.) this means until patients rupture or burst causing major bodily harm, there is no abortion or aide.

How is this even constitutionally happening? Honestly an overlaps in judgment. The US Constitution currently has no right to health. However you do have the right to Self Defense.

“Well wait a minute how is a baby a self defense situation?”

As the law currently stands in order to be protected by the law for self defense you must fear great bodily harm OR death. And in states where we have banned abortion we have also recognized the fetus as a living child. Therefore in these states it is in fact a person. Because while the Federal US Government does not define personhood, these particular us states have.

So by Law you can defend yourself from this said child. However depending on the state the doctor may not. While it is commonly accepted you can defend your own life. It is not commonly accepted to defend someone else’s life. And out of 13 states 6 of them have the wording to defend another’s life(Alabama, Idaho, Kentucky, Louisiana, Oklahoma, and Texas).

This is a hard stretch but a fitting defense, during a time where medical necessity has yet to be defined or allowed into current US Abortion bans in place. And most importantly isn’t a far stretch.

Remember when I said adaptive law is pretty much manipulation and usually reserved for case law? Well here you go.

“But how can I use this in current world?”

Civil Lawsuits against the states. You have grounds for Wrongful Death, Damages, Medical Expenses, etc… in these cases where you have mothers suffering medically from these pregnancies or dying.

These Civil Lawsuits paired with a strong constitutional stand your ground stance have potential for the footsteps to case law.

So now we have addressed the 13 states who have outlawed abortion. What about the others? Are they correct in there adaptations of the Constitution?

Legal Experts have universally agreed Roe V Wade held no constitutional ground. These experts can heard from Yale to Harvard across the United States. However that only dismisses 8 of the 50 United States. Honesty you will have to go through the rest to find out their constitutional findings.

But as it pertains to the 10th Amendment. The US government has yet to find a constitutional understanding. But wait can we? Well going off Textural Interpretation that Children are in fact Property and under the 4th amendment. Then Yes. Because the US Government has in fact the right of protection from warrantless seizure of property given to the people. Thus also outweighing the state government. However, without the government recognizing that particular interpretation into the 4th amendment, and interpretation of child=parental property, there is no grounds for the US Gov to rule on any state abortion law.

Could Abortion be deemed Illegal in the US Gov eyes through this practice? Yes and no. The Gov could not criminalize abortion under this interpretation because they are in fact defining a child, infant, or fetus as property of the mother or guardian.

The only counter argument could be to define personhood. Which currently both the medical and legal jury are in a constant deliberation or recess on. And this even goes to Law Institutes as-well. As sources such as LawInsider have defined a human being from fertilization to full gestation. Cornell has defined a human being as one being “Borne Alive” which is to be extracted from the mothers womb. And the definitions continue to vary.

And simply without a US Government Deliberation on the subject resulting in a consensus you won’t see it happen.

However stepping away from the constitution. The 10th Amendment can still apply. As the Government does not recognize neither the right to ban or protect abortion rights. They however do retain the rights of federal regulation.

More commonly seen in our National Drinking Age, and more recently raised age minimum for Tobacco Products.

The US Government can always enable a act that which penalizes states that continue to outlaw abortions in the United States.

A example of this would be the 1984 MNDA Act which raised the federal minimum drinking age to 21 but however cut Federal Highway Funding for states that did not wish to participate by 10%. Of which all US states participated in.

With recent times dangling the privatized medical field infront of the US Government to take over a proposed 60% controlling interest in hospitals across the country. And the CARES act showing that the government can and has given monetary aid to hospitals. It is not out of possibility for the government to propose a counter of 40% funding to the 13 states who wish to keep abortion illegal. And 60% to the states who wish to keep it legal. But the same can also be said vise versa. And acts can always be repealed or demolished unlike constitutional rights.

Sub chapter 2-1

Synopsis

The 10th amendment still can still be applied paired with the 4th amendment. However in general in current times without another understanding of the us Constitution it does not.

However the 10th Amendment could also be applied if the government were to wish to implement a ACT surrounding medical funding to the states. Allowing them to either outlaw or protect abortion via financial cuts to their medical budget.

Current Understanding of US Castle Doctrine, or “Stand Your Ground”, could be adapted in 3rd party self defense states, that currently outlaw abortions without medical exceptions.

Subchapter 2-2

The 14th Amendment

Well as stated before to recap from chapter 1 subchapter 1-2. We found Textural connection and understanding of abortion as an unalienable right. Through both ““No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States” and just Persons.

But how could we expand on this through a adaptive approach to law?

Well, as Adaptive law should be interpreted, it should be done through civil and case law. But how do we do that with an already strong connection to the 14th Amendment through Textural?

Well this is where it is good to know both sides of the interpretation process. As Textural is great for constitutional understanding, Adaptive is great for Civil Practice law. And unlike Roe V Wade we can have a attachment to the 14th amendment with a modern case or cases.

Again we go back to civil court where we are suing states for wrongful death, losses, health, unnecessary injury, etc… and now apply our textural understanding.

What could be some counter arguments in a case?

With adaptive law we will have oppositions try to define things that have yet to be defined by textural law. And thus they will try to argue Persons or Property. While we have seen law applied to both cases in different ways. We cannot say without a doubt it has been used in a adaptive interpretation.

Referring back to Personhood again there are many counters and valid definitions to personhood. You can kick your heels in to stick by textural interpretation. Or you can even do both.

Use the basis of textural interpretation. And use the Textural to adapt and apply your dismissal to adaptive approaches to the constitution when it comes to personhood. Because as defined by Law, textural interpretation is the only way to interpret the constitution.

Subchapter 2-2

Synopsis

When you find a strong case of textural understanding of an amendment directly connected, there is no need to adapt any more. As you are truly going off the black and white words off the paper. And no amount of smoke and mirrors from anyone can change that.

When it comes to a textural approach vs adaptive in Constitutional understanding. Textural is going to outweigh.

If you are a fellow lawyer reading this. Or law student. Take note that this is what your legal aid is for. Either it be a Legal Assistant or fellow Associate. This deep dive of info, is nothing to take alone.

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