Frank J. Remington Center

Spring Newsletter 2015

Newsletter Contents

Director’s Report

By Carrie Sperling, Interim Director of the Remington Center

Carrie SperlingYou may have heard about the recently published study on attorney happiness. The legal blog Above the Law discussed the study under the headline, “Public Interest Lawyers Are Happier.” Happier than whom, you ask? The articles claim that lawyers who work as public defenders, prosecutors, and legal aid lawyers are generally happier than lawyers in large or prestigious law firms.  The New York Times, the ABA Journal, and Findlaw also covered the study’s findings but focused on the fact that lawyers who make less money are happier. Findlaw’s headline was a bit deceptive, claiming that “Poor Lawyers are the Happiest.” That’s not exactly what the study found.  The study presents a much more nuanced picture of lawyer happiness.

In their study, Lawrence Krieger and Kennon Sheldon actually found autonomy, relatedness, competence, and internal motivation highly correlated with lawyers’ happiness. By contrast, they found that income, class rank, and membership on law review has a low or no correlation with lawyer happiness. Their study confirms what is found in other professions: people are happier when they exercise more control over their work, their work aligns with their values, and they connect with others in a meaningful way. On the other hand, people do not grow considerably happier as their incomes increase, and prestige does not bring the happiness people expect that it might. 

Krieger and Sheldon say that today’s legal education is part of the problem.  “[T]he factors most emphasized in law schools—grades, honors, and potential career income, have nil to modest bearing on lawyer well-being.” “[T]he current data show that the psychological factors seen to erode during law school are the very factors most important for the well-being of lawyers.”  According to the researchers, we are doing something to law students during their law school experience that fosters their unhappiness.

The authors argue that law students need a different focus. Instead of worrying about class rank or whether they’ll make law review, students would better serve themselves by learning how to be competent lawyers, how to work collaboratively, and how to practice law with the highest of ethical standards. They should seek opportunities to experience the joy of working in jobs that align with their values, in settings that give them the autonomy to make their own decisions, with connections to others who are also deeply engaged in their professional lives.

This is just what the Remington Center does. We take Frank Remington’s legacy seriously – quietly and earnestly encouraging students to engage in meaningful work. We open their eyes to various careers in public service, and we give them a solid connection with, and understanding of, their communities. We require students to pursue the professional high road, and we encourage them to see not just legal issues, but how the law impacts people’s lives.

This summer, the Remington Center will give another class of students the opportunity to practice that skills and develop the mindset that will make them resilient, collaborative, and ethical lawyers.  Just like the students who participated in the Remington Center before them, I believe that wherever these students eventually decide to practice – whether a prestigious law firm, a prosecutor’s or public defender’s office, or a corporate headquarters – these experiences  will serve them well, helping them develop meaningful and happy careers in the law. 

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Comings and Goings

For the first time in a long time, there are no changes to report to the Remington Center staff. The Remington Center did “graduate” approximately 70 students in May, and has another 60 students who started at the end of May, with another 15 or so students who will be starting in the fall. In addition, Kate Hanley, a visiting barrister from Dublin, Ireland, is observing and assisting at the Wisconsin Innocence Project this summer.

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Staff/Clinic News

Keith Findley, assistant professor and co-director of the Wisconsin Innocence Project, and former WIP clients were prominently featured in the May issue of the ABA Journal in an article entitled, “These JD-Carrying Exonerees Are Using Their Experiences to Right Wrongs.” Professor Findley will publish Assessing Experiential Legal Education: A Response to Professor Yackee, in a forthcoming issue of the Wisconsin Law Review; he has recently presented around the country on topics related to the Wisconsin Innocence Project and problems resulting from the testimony of eye witnesses and experts.

Keith Findley and Lindsey Cobbe (WIP supervising attorney), several Wisconsin Innocence Project students,Wisconsin Innocence Project and a WIP exoneree (and later Law School graduate) Chris Ochoa held an informational presentation in April at the Wisconsin State Capitol regarding wrongful convictions and the need for fair compensation for those wrongly convicted and imprisoned in Wisconsin. Following the presentation a bipartisan duo of legislators pledged to introduce legislation that would provide an exoneree with compensation of $50,000 per year of wrongful incarceration, without a cap on the amount that could be paid to an exoneree. At this time, Wisconsin provides $5,000 per year of wrongful incarceration, with a $25,000 cap on the compensation that can be paid.

Kate Judson, an Innocence Network Fellow with the Wisconsin Innocence Project, authored “What Child Welfare Attorneys Need to Know about Shaken Baby Syndrome,” which was published in March in the ABA Children's Rights Litigation Newsletter.

John Pray (clinical professor and director of the Criminal Appeals Project) and Steven Wright (supervising attorney for the Wisconsin Innocence Project) coached teams of students who briefed and argued an actual criminal case in front of the United States Court of Appeals for the Armed Forces, which held oral argument on the case at the Law School in April. See the article on the students’ work for the case, below.

Mary Prosser, associate clinical professor and LAIP supervising attorney, testified in April before the Madison Common Council, which was set to vote on a committee-endorsed ordinance that would prevent anyone on the state sex offender registry from living within 2,000 feet of a school or community center. Professor Prosser pointed out to the Common Council that the sex offender registry includes, among other persons, juveniles convicted of consensual sex with another juvenile. She also provided citations to numerous studies showing that laws such as the proposed ordinance are usually more harmful than helpful to a community. The Common Council chose not to vote on the proposed ordinance and sent it to committee for further study. Professor Prosser also served on panels at the University addressing issues surrounding police killings of unarmed African American men.

Jonathan Scharrer, director of the Restorative Justice Project, guest lectured at Northwestern University’s mediation clinic and at its restorative justice seminar. He also served on several panels for Law School student organizations and the undergraduate political science honor society.

Carrie Sperling, assistant clinical professor, co-director of the Wisconsin Innocence Project and interim director of the Remington Center, has added another hat and is now also the Law School’s associate dean for curriculum and experiential education. She presented in April to the Madison Academic Staff Association on the work of the Wisconsin Innocence Project, its role as a leading clinical legal education program, and its impact reforming the criminal justice system.

Adam Stevenson, associate clinical professor and director of the Oxford Federal Project and Federal Appeals Project, gave a presentation in April at the University of St. Thomas School of Law’s symposium, “Reviewing Clemency in a Time of Change.”

The Wisconsin Innocence Project recently learned that it had received a grant of $14,800 from the Evjue Foundation to continue its work pursuing justice for the wrongly convicted. The Foundation is the charitable arm of The Capital Times newspaper and provides grants that support educational, cultural, and charitable organizations in Madison and Dane County.

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Student Awards

Mary ProsserStudents who have taken part in the Remington Center clinics won a significant number of awards at the Law School’s Honors and Awards Ceremony in May. They were awarded numerous Moot Court awards and “Service, Commitment, and Contribution” awards, as well as awards for academic excellence and contributions to the Wisconsin Law Review. Below are the Remington Center students who were awarded “clinical awards.”

Heather Jansen, 3L (Family Law Project), was awarded the Catherine Manning Memorial Award for outstanding contributions to the Legal Assistance to Institutionalized Persons program.

Jared Prado, 3L (Oxford Federal Project, Prosecution Project), was awarded the Clinical Legal Education Association Outstanding Student Award.

Catherine White, 2L (Wisconsin Innocence Project), received the Melvin J. Friedman Memorial Scholarship for exemplary work in the Wisconsin Innocence Project.

Tiffany Elizabeth Woelfel, 2L (LAIP), was awarded the Julie Strasser Scholarship for demonstrating concern for the needy and working to benefit society.

Hannah Wrobel, 3L (Restorative Justice Project; Prosecution Project), was awarded the Abner Brodie Award for outstanding achievement in legal study and practical application of the law.

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Featured Articles

An Interview of John Pray

By Steven Wright, Clinical Instructor, Wisconsin Innocence Project

At our Remington Center staff meeting, we discuss the process by which we will focus our vision for the center’s future. We agree to conduct interviews of one another, to solicit feedback about our strengths and aspirations. I get assigned John Pray, and I write John an e-mail with an invitation to lunch. He replies quickly, signing his e-mail JP, and, as I read his brief acceptance of my invite, I find that I’m a little nervous.

The assignment is somewhat intimidating. John Pray’s a faculty giant, a public-interest lawyer who’s spent his entire twenty-nine-year legal career teaching at the Remington Center. He started in LAIP, co-founded the Wisconsin Innocence Project, now directs the Criminal Appeals Project. His service has earned him a ton of accolades: a 2010 teaching award from the law school, an Equal Justice Medal from Milwaukee’s Legal Aid Society, a Civil Libertarian of the Year recognition from the Wisconsin ACLU.

John PrayBy chance, our lunch happens on a Friday, three days after John argued a case before the Wisconsin Supreme Court. The issue, in that case, is one that only an appellate lawyer could love—the sufficiency of evidence in the face of a tricky jury instruction. The Supreme Court hearing was, by any standard, strange. The courtroom, with its famed wall-length murals, is packed. Thirty-plus high-school students fill each of the Court’s hardwood seats, dull-eyed teens that hide their cell phones beneath their coats and send texts throughout the forty-minute argument.

John claims to hate oral argument, but he performs like a maestro. He has prepped, mooted, rehearsed key refrains that are strong, polished, and well-delivered. At the end of the hearing, John greets some of the high-school students, asks how they think he performed. The kids are kind and supportive: they smile, they nod, they say a job well done. But one of the chaperons---a parent who clearly bursts to share an unsolicited opinion --- asks whether John is just trying to get a guilty-man off on a technicality. John smiles, he nods, he’s as polite as the high-school students who have already lost all interest. But, in that moment, I’m a little angry, and I’m reminded of the importance of the Remington Center, reminded that we can’t depend upon the general public to protect the rights of indigent men and women accused of crimes.

Back at lunch, at the University Club on fried-fish Friday, John asks the difference between the breaded Walleye and the breaded Cod. The waitress gives the question thought, says that the Walleye has a “Lake-y” taste, a detail that, for some reason, both intrigues and disturbs me. What exactly does a Wisconsin lake taste like? John, though, is undeterred. He orders the Walleye, with extra tartar sauce.

We start our conversation with pleasantries. John shares tips to keep students engaged at the semester’s end; I share my experience teaching, this first year, at the Remington Center. But the conversation quickly shifts to the point of our interview and, for a moment, I feel a little overwhelmed. I need John to condense twenty-nine years of experience into the forty-minutes it will take to deep-fry and eat a fish that taste like a Wisconsin lake.

We eventually reach the questions exploring the highlight of his long career.  And, without missing a beat, John starts to talk about the exoneration of Christopher Ochoa. Ochoa spent fourteen years in a Texas prison for a rape and murder he didn’t commit. The true killer, a born-again repentant man serving three life sentences, had, years after Ochoa’s conviction, written confessions to the police, to the district attorney, and to the then- Governor of Texas: George W. Bush. Ochoa reached out to Keith and John, and he would become the Wisconsin Innocence Project’s first exoneration.

John’s been slouching for most of our lunch, but when he speaks about this exoneration, he sits up, starts to speak with a mix of pride and passion. He describes the day of the 2002 exoneration hearing, a day unlike any other in his entire life, complete with throngs of cameras and reporters and a news-copter that circled overhead. I imagine something akin to the Academy Awards, John in a tux stepping out of a stretched limo and onto a red carpet. I know, of course, that the hearing was not nearly that dramatic, but, as the conversation continues, I realize that this exoneration is John Pray’s Oscar, an accomplishment like no other in the world, a once-in-a-lifetime prize he’s worked hard to earn and can now set atop his shelf like a trophy. For the rest of his life, John Pray can point to Chris Ochoa’s exoneration and say, I did this.

John, of course, would go on to help exonerate others --- Chaunte Ott and Steven Avery. But John says there’s something different about Chris Ochoa, something a little more complex than the fact that Ochoa was the project’s first exoneration. I have my own suspicions. Perhaps, the case feels special because it is special---a physical manifestation of all the good that the Remington Center can do. Chris spent fourteen years behind bars, then spent the next fourteen years building a new life: first as a UW undergrad, then a law student who worked in the Remington Center, now a successful attorney in his own right. The case has a certain symmetry, a narrative arc all its own, one where the good guys win, and where an innocent-man was set free; none of which would have happened if not for Keith Findley and John.

Our food arrives, and we shift from past to present to future. John says he wants to preserve the strengths of the Center, wants future generations of faculty to continue to enjoy the freedom and diversity-of-cases. To do that, John says the Center will need to continue to demonstrate its importance, to prove to decision-makers and stakeholders that we’re worthy of their money and their trust. We, as a clinic, must continue to"" forge relationships, to reach-out to the community, to faculty and administrators, to the legislators who oversee our budget.  I think about the Supreme Court argument, about the chaperon who called John’s case a technicality. I wonder how best to persuade such a person that our cases have value, that we fight for principles as well as people. 

We finish our meal, and I look-up: we’re the last patrons here. The wait staff huddles in the corner, kind-eyed yet clearly eager for us to leave. We pay our bills, and, as we head through the door, the staff rushes to flip over chairs and to clear our table. On the walk back to the law school, John says that he’s nearing retirement, that he’ll miss both the work and the colleagues who have become his friends. I ask him how he’d like to spend his retirement, and he shrugs, as though to say he’s not one-hundred-percent sure. I can’t imagine such an accomplished man could ever take it easy, but, as we say our goodbyes and go our separate ways, I’m certain that John Pray deserves a rest.

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Teaching Sentinel Events in Introduction to Criminal Procedure—Spring 2015

Clinical Professor Michele LaVigne stood in front of her Introduction to Criminal Procedure class on its first day in January and told the 60 students in front of her that they had something in common with her. Like her, they likely had not yet looked at the class’ textbook.

Professor LaVigne had agreed that day to teach the class for a colleague whose unanticipated illness prevented her from teaching the class. Professor LaVigne had last taught this class more than 20 years ago, although she had certainly stayed current on many of the rapidly changing and developing issues through her work as director of the Public Defender Project at the Remington Center and her other class teaching, including a class she developed on the 4th, 5th, and 6th Amendments. She will readily admit that she taught the class “on the fly,” staying only a week or two ahead of her students as she developed the course.

Michele LaVigne and friendOver the past years Professor LaVigne had become convinced that the legal profession and the larger community are desperately in need of a new model for talking about and assessing the effectiveness and fairness of the criminal justice system. In 2013, she became aware of the emerging “sentinel event review” approach to addressing adverse events at all levels of the justice system. Professor LaVigne immediately saw great potential in this type of review and wanted to thread this approach to the justice system into her teaching of criminal procedure.

According to James M. Doyle, a prominent Massachusetts lawyer and one of the leading advocates for this approach, a sentinel event

is a significant, unexpected negative outcome that signals a possible weakness in the system or process. Sentinel events are likely the result of compounded errors and – if properly analyzed and addressed – may provide important keys to strengthening the system and preventing future averse events or outcomes.

Sentinel event review is standard protocol in hospitals. For “typical” negative events in a hospital – the sponge left in the patient after surgery or the surgical removal of the wrong leg – there is never a single error that led to the mistake, but rather a long series of missteps along the way. By identifying where these missteps may have occurred, hospitals can then institute changes that will diminish the likelihood of future errors.

The impetus for the sentinel event review approach in criminal justice is the recognition the criminal justice system, unlike hospitals, lacks a means to fully account for, and learn lessons from, errors in the system. Traditional legal mechanisms and analysis seek to identify a single source of blame for error that occurs within the criminal justice process. We then ask whether that error was “bad enough” to warrant relief for the individual who has been harmed.

Sentinel event philosophy specifically rejects this type of “bad apple” explanation for things going wrong. It argues that pointing fingers and equating blame with accountability have a crippling impact on efforts to prevent future errors. Most errors that occur in the criminal justice system, such as wrongful conviction, racial disparity, mass incarceration, excessive use of force, prosecutorial misconduct, or ineffective assistance of counsel, are “organizational accidents” resulting from a series of missteps, no one of which could have caused the bad outcome independently. However, if blame and, by implication, punishment, are the primary objectives of any review, then the latent systemic weaknesses that may have caused or allowed the “bad apple” will not be investigated. Sentinel event review does not ask who, but why; it examines an event, not a person.

The goal of the sentinel review process for a criminal justice negative outcome is to have all system stakeholders – police, investigators, social service providers, teachers, prosecutors, defense attorneys, judges, lawmakers, community members – work together in a non-blaming review. The National Institute of Justice, which is part of the United States Department of Justice, is exploring whether sentinel event reviews can play a role in addressing criminal justice errors. It has chosen and provided funding for three locations to undertake such a process for a sentinel event. Milwaukee is one of the three locations.

But back to Professor LaVigne and her Criminal Procedures class. Although Professor LaVigne used the textbook that she had never seen before the first day of class, she developed a curriculum that wove the sentinel review approach into most aspects of the teaching of criminal procedure. The understanding that all systems play a role in the quality and outcomes of criminal procedure was integrated into teachings on a variety of subjects including the investigation of crimes, prosecution, the defense function, sentencing, and how those convicted of crimes are treated once they are released from custody.

Professor LaVigne arranged for James Doyle and Milwaukee County District Attorney John Chisholm, both contributing authors for the NIJ Report "Mending Justice: Sentinel Event Reviews," to present a lecture for the Institute for Legal Studies’ Law and Society Series in March. Both attorneys also agreed to come to Professor LaVigne’s class and discuss their work with her students. They could hardly have refused: James Doyle had been Professor LaVigne’s clinical supervising attorney when she was a law student at George Washington University, and John Chisholm (an LAIP alum) had been a student in Professor LaVigne’s Substantive Criminal Law class.

Professor LaVigne’s curriculum and the occurrence of a real world, sentinel event in Madison converged to provide an incredible – and difficult – learning experience for the students in her Criminal Procedures class. On February 23, Professor LaVigne began teaching a section on the law of police use of force. On February 25, Madison Police Chief Mike Koval came to class and discussed challenges in policing, including the use of force by police. On March 4, James Doyle and John Chisholm met with Professor LaVigne’s students to explain how a sentinel event review operates in the criminal justice realm. Two days later, an unarmed African American teenager was shot and killed by a white Madison police officer.

The students then watched as the needs, wants, anger, abilities, and understandings of multiple communities played out: the police, the African American community, the school community, the prosecutors, the defense attorneys, the friends and family of the victim, the police union. They saw the police chief who had just spent time in their class, balance and understand the demands and angers of the various communities, preventing the violence that has scarred other communities in the past year.

Professor LaVigne believed “it would have been grossly irresponsible” to ignore what was going on in the community as she taught her Criminal Procedures class. She immediately modified the curriculum to give the students a chance to discuss these events. At that time there was not much information available to the students, and there were a lot of different opinions and raw emotions among the students. At the end of the semester, after considerably more information about the shooting had been revealed, Professor LaVigne and the students again discussed the situation, applying principles from sentinel event review. There was still no consensus, but the conversation demonstrated that the students had moved toward a more sophisticated understanding of the myriad facets not only of the shooting, but also of the systemic issues in play.

Although the students did not see a formal sentinel event review take place, their understanding of the process gave them significant tools to process the situation that arose in their community, to see the multiple factors that led to this tragic event, and to appreciate the various communities’ reactions and demands. Criminal procedure and all its elements played out in front of them; their understanding of the “sentinel event” process gave them the tools to analyze the situation in depth. 

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The Costs of Conviction: A Proposal for Equity and Fairness

By Ben Kempinen, Clinical Professor and Director of Prosecution Project

Ben KempinenWorking in the Remington Center, first with the LAIP Program and, for the last twenty-five years, as director of the Prosecution Project, has given me an opportunity to know and work with a number of incredible and creative criminal justice system shareholders. My ongoing involvement with the criminal justice system has also revealed that parts of the system are not ideal and are often neither fair nor cost effective ways of making our communities safer. One such part is the statutorily required financial obligations imposed largely on those least able to pay. This short essay suggests one modest response to this problem – entrusting our circuit court judges to fashion accountability decisions to fit the circumstances of the particular case.

Legislatures frequently look to convicted offenders to contribute to the costs of their prosecution, confinement, and supervision, and increasingly, to fund other public works unrelated to criminal justice. This is neither new nor radical. Indeed, enshrined in our state constitution is a requirement to transfer fine and forfeiture revenues to the state school fund.[FN1] And, most would agree that persons should be accountable for at least some of the public costs resulting from their decision to engage in unlawful conduct.

However, when money is the sole metric for accountability two separate justice systems emerge – one for those with sufficient resources to pay their legal financial responsibilities and another for the poor who cannot. The latter system is larger, less fair and more costly to offenders, their families and local government. Our current statutory scheme does not give circuit court judges the power to effectively deal with this population. Offenders who cannot pay legal financial responsibilities should not be punished for being poor. Nor should they be given a free pass. Rather, they should have the opportunity to repair the harm they have caused by other means, such as community service. This opportunity can be accomplished by expanding the statutory power of circuit court judges to allow community service to satisfy not only fines, as permitted by current law,[FN2] but all legal financial obligations in those situations where the offender lacks the financial means to pay.[FN3]

Poverty and crime

Persons living in poverty are significantly over-represented as both perpetrators and victims of crime.[FN4] The vast majority of persons charged with criminal offenses are eligible for public defender representation, which is calculated at 115% of the 2011 Federal Poverty Guidelines.[FN5] The inescapable reality is that a large portion of the offender population lives on the margins of society and lacks the means to pay significant legal court obligations.

Although there are signs the United States is slowly emerging from the recent recession Wisconsin has lagged behind in several respects. For example:

  • Adjusted for inflation, median household income in the state declined 14.5% between 1999 and 2010, according to U.S. Census Bureau[FN6];
  • 51 of Wisconsin’s 72 counties have below average median incomes[FN7];
  • 13.2% of Wisconsin residents live in poverty, less than the national average of 15.9%; 36.3% of African Americans live in poverty,  more than10% higher than the national average; Hispanic poverty rate is 23.8%, slightly higher than the national average of 23.2%; White poverty rate is 9.6%, slightly lower than the national rate of 11.6%[FN8];
  • 28.7% of working families in Wisconsin are working poor; 23.8% of jobs in Wisconsin are at minimum wage jobs and many working families in Wisconsin experience housing and food insecurity.[FN9]

Wisconsin’s significant, low-income population is largely responsible for paying increasing sums of money to underwrite the costs of our justice system and other public works.

The Costs of Conviction

Every person convicted of a crime in Wisconsin may be incarcerated, fined, or placed on supervision as part of their sentence.[FN10] In addition to the sentence imposed or any restitution owed,[FN11] in all cases all offenders are ordered to pay the following:

  • crime laboratories and drug law enforcement surcharge
    • $13 for each count
    • Wis. Stat. § 165.755(1)(a), (2)
  • criminal court fees
    • $163 each case
    • Wis. Stat. § 814.60(1)
  • crime victim/witness surcharge
    • Misdemeanors = $67, each count
    • Felonies = $92, each count
    • Wis. Stat. § 973.045(1)(a), (b)
  • Deoxyribonucleic acid (DNA) analysis surcharge
    • Misdemeanors = $200, each count
    • Felonies = $250, each count
    • Wis. Stat. § 973.046(1g), (1r)

The minimum amount a convicted offender must pay in every misdemeanor case is $443, for felonies it is $518. If there are additional or more serious charges, the legal financial responsibilities of an offender will be higher, often totaling thousands of dollars.

Responsibility and authority for collection

The clerk of the circuit court has primary responsibility to collect monies that offenders are ordered to pay.[FN12] Counties are financially responsible for the costs related to collection even though most monies collected do not remain in the county. Clerks may arrange for and manage a payment plan for offenders – for which the offender may be charged; they also have statutory authority to contract with private collection agencies.[FN13]

There are a variety of remedies available when an offender fails to timely pay legal financial obligations.

  • Interception of tax refunds – Wisconsin law authorizes the Department of Revenue to intercept the tax refunds of persons with outstanding legal financial obligations. Wis. Stat. § 71.935
  • Suspension of driver’s license. Wis. Stat. § 343.30
  • Incarceration in the county jail for up to 6 month. Wis. Stat. § 973.07
  • Community service is available only for nonpayment of fines. Wis. Stat. § 973.05(3)

Interception of tax refunds is a relatively cost-free means of recovering monies owed from offenders. Other remedies have been less successful and can created unintended costs. For example, suspension of driver’s licenses has resulted in an increase in persons prosecuted for driving after suspension rather than a significant increase in the recovery of monies owed. More than half of the driving after suspension cases in Wisconsin at this time are the result of nonpayment of legal court obligations rather than driving violations.[FN14] Prosecution of these cases is a direct cost to the county. Conviction results in additional legal financial obligations added onto existing unpaid obligations. For many offenders the practical consequence is that obtaining a driver’s license is beyond reach. This invariably makes obtaining or retaining employment more difficult.

Incarceration for nonpayment has also not proved to be an attractive option. If the offender truly is unable to pay, confinement is unlawful.[FN15] The county must bear the costs of incarceration which range from $50 to $200 per day, without obtaining any revenue from the offender.[FN16]

Uncollected obligations

At the time this essay was prepared, statewide statistics for uncollected legal financial obligations were not available. However, Milwaukee County, which represents between 20 and 25% of all cases, has made information available which provides some sense of the scope of the issue.

As of April of 2015, Milwaukee County had $72.9 million of uncollected accounts receivable for legal financial obligations, including the cost of efforts at collection (tax refund intercepts, private collections, and payment plans). Over a 20 year period collections have averaged approximately 9% of the total amounts ordered to be paid.

A possible solution: Community service as an option

A partial solution to the issue of unpaid court fines and fees is for the legislature to give judges the discretion to order community service in cases where the offender can demonstrate his or her inability to pay the fees. As shown above, a significant percentage of offenders live in poverty, and the payment of significant legal court obligations is beyond their reach. At the same time, many of these offenders have the ability to contribute to their communities through public service. Allowing the truly poor an alternative means of paying their debt to society preserves an important measure of accountability and can make our system more fair and cost effective. If this option is limited to those unable to pay, it will not cause a reduction in any revenue stream as a majority of these obligations are not collectable. 


1.   Since statehood the Wisconsin Constitution has required that fine and forfeiture proceeds fund public schools. Wis. Const. Art. X, § 2. One of the primary reasons for the creation of surcharges and assessments is to provide greater flexibility in the use of monies collected from offenders. A contemporary example of using offender legal financial obligations as a proxy for increased taxes is the plan to fund a new arena for the Milwaukee Bucks. One current proposal involves the transfer of the right to collect millions of dollars of unpaid fines, surcharges, costs and assessments from the city and county of Milwaukee to the state to fund the building of a new sports arena. See Bruce Murphy, How Abele Bailed Out Walker, Urban Milwaukee (June 11. 2015),

2.   See Wis. Stat. § 973.05.

3.   This proposal would grant circuit court judges the same powers that municipal judges currently have. See Wis. Stat. § 800.09(1b).

4.   See Darren Wheelock and Christopher Uggen, “Race, Poverty and Punishment: The Impact of Criminal Sanctions on Racial, Ethnic, and Socioeconomic Inequality” (2006),; Erika Harrell, et al., “Household Poverty and Nonfatal Violent Victimization 2008-2012” (2014),

5.   See (Legislative Reference Bureau Rule Filing, CR-12-017).

6.   See Wisconsin Median Income Plummets, Census Figures Show, Milwaukee J. Sentinel (Sept. 21. 2011),

7.   See Wisconsin Median Household Income, 2006-2010 by County,,

8.   See Who Is Poor in Wisconsin, Institute for Research and Poverty, University of Wisconsin,

9.   See Spotlight on Poverty and Opportunity,

10.  See Wis. Stat. §§ 972.13, 939.50-939.51.

11.  See Wis. Stat. § 973.20.

12.  See Wis. Stat. § 59.40.

13.  Id.

14.  See John Pawasarat and Lois Quinn, Issues Related to Wisconsin’s “Failure to Pay Forfeitures,” Driver’s License Suspensions (2014),;

15.  See State ex rel. Pedersen v. Blessinger, 56 Wis. 2d 286, 289, 201 N.W.2d 778 (1972) (unconstitutional to incarceration an offender for nonpayment of financial obligations if unable to pay due to poverty). This defense may be available to yet not asserted by a significant number of offenders with outstanding obligations who lack the either the knowledge to assert the defense themselves or the ability to retain counsel to assert the defense for them.

16.  Christian Henrichson, et al., The Price of Jails: Measuring the Taxpayer Cost of Local Incarceration, Vera Institute of Justice (May 21. 2015),

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The Restorative Justice Project: A Sister’s Story of Grief and Forgiveness

The Restorative Justice Project of the Remington Center facilitates “victim-offender dialogues” (VOD) throughout Wisconsin. The dialogues are initiated by a victim/survivor of a crime, and the Restorative Justice Project students co-facilitate face-to-face meetings between these victims and their offenders. Cases typically involve sensitive crimes and crimes of severe violence. This restorative justice process brings together victims/survivors and their offenders in order to find answers to a victim's questions or to seek an understanding that reaches beyond the crime itself, often with a profound positive impact on the lives of the people involved.
The following story about a devastating event, grieving, anger, and finally forgiving and going through the VOD process was written by the sister of a man killed by a drunk driver. She took part in a VOD co-facilitated by students in the Restorative Justice Project. The story was initially prepared as a presentation to the incoming class of students at the Remington Center.

A Change of Heart and of Mind

By Angel Wendt

First I would like to thank you for being here today. I am so honored to be standing in front of you today sharing a small piece of my story. I have to admit I was never much of a public speaker, especially when it came to matters of great emotional connection, but this whole process, although terrifying, has brought such peace and calm with each connection that I can not imagine what life was like being shy and reserved again. I have only been connected with the restorative justice program for about a year and half. In this time I have leapt out of my skin to show people around me the monumental impact that their decisions make on other people.

To begin understanding my story I need to go back 26 years. I was little and my mom and dad brought home a little bundle of joy that turned out to be my baby brother. Life was changing in a dramatic way. I went from being an only child to having a younger brother, who by the way was “wonderful in every way.” I loved him, of course I did, as any big sister would. I loved him so much I was willing to use him as a guinea pig for all my outlandish ideas and experiments. I loved him so much that he drove me bananas.
We had fabulous fun together, we really did, most of the time, well some of the time, well actually I should probably say occasionally. It was as story book as you would expect, nothing short of stereotypical sibling love.

As we grew up, we developed a fabulous relationship and I can honestly say I was honored to have him in my life. He was a fabulous young man who gave unconditionally, loved without reserve and took the day on as if it would truly be his last and made use of every moment he was granted. 

The unfortunate truth of the story, though, is that although I will always remember him as a great young man, that is all I have to hold onto. A memory. A hazy dream of sorts of a life I once knew.

On March 17, 2010, my brother Mike left work at Menards to go home for the night while at the same time a man who had had too much to drink was driving down the same road. Shortly after 10:00 PM this intoxicated man moved into my brother’s lane of traffic to pass a vehicle and never returned to his own lane. He hit my brother’s car, what for all intensive purposes we will call “head on.” The brunt of the impact was taken by the left front quarter of my brother’s vehicle. His airbags never deployed, his seatbelt caught after my brother had already hit his windshield. 

It took several years to gain the strength to view photographs of my brother’s car and the image I hold now is one where no human body would have fit. All the meanwhile, the other driver ended up on the other side of the road in the ditch. When emergency vehicles arrived on the scene my brother was taken to the funeral home by the ambulance and the other driver was taken via helicopter to the hospital yelling outlandish tales of his age and lack of intoxication. 

My parents were awakened that night by the sheriff and one of his officers who had come to bring the personal items my brother had on him, his wallet, ID badge, etc. They called me shortly after this visit to inform me of what had happened. At 1:00 am I decided I needed to be with them and drove to their house. I sat with family, having no words to describe how I was feeling. I was a lost soul. I listened to my father sob that evening like I had never heard before. My father is the pillar of strength around which I have patterned my life and I never realized how painful it could be to experience someone’s turmoil and tragedy and be completely without control. There was nothing I could do to take this pain away from my family and it tore me up knowing so.

As the days dragged on, I thought that this was going to be my great demise also. My heart was tired and I could see no way out. During this time in life, I was a terrible wife, I was a terrible mother, I felt like I was a terrible person. All I could do was perseverate on the fact that my brother was no longer alive and it was this other man’s fault.

I took it as my personal mission to make this other man’s life as miserable as I possibly could. I rounded up people who were willing to speak against his character to the detective. I watched his every move during court hearings. I made it my business to do God’s business and ensure they gave this man all he had coming. It gave me purpose and meaning again. It brought back my drive to live and continue. I felt that with this I could make his wrong a right, the world would come back into balance, and I would feel less empty.

This dream was shattered, though, when I was riding in the car with my three-year-old son. He asked me, as he had asked me before, what happened to Uncle Mike. I tried to explain without details that Uncle Mike had been in a car crash and he is with God now. This time he followed my statement with “why.” Now how on earth do you explain to such a small child that sometimes people are selfish and sometimes they do not take others safety into consideration and sometimes they just don’t care? To my small son in the back seat I just said “the other man driving made a really bad choice.” For a brief moment there was silence, and then he stated, “maybe a lion should eat him.” At first I thought this was funny. I had even let it run through my mind how different our world would be if we subjected those with poor judgment to consumption by lion.

In the quiet of my heart, though, it resonated, that he was thinking these thoughts because that is how I was running our lives. I had put myself in the place of judge and jury. I had not taken into consideration the other man’s feelings or story. Quite honestly, up until I started speaking with our county’s restorative justice program, I didn’t even consider that he had a story. 

My father was truly the reason I was inspired to start speaking about forgiveness. Through this whole process of grieving and depression he kept reminding me that it wasn’t my job to be judge and jury, but it was my job to forgive. He led by example and did just that. He participated in a victim-offender dialogue (VOD) before I was even ready to consider this option; he went to the VOC with the prime objective of extending to the man who killed my brother forgiveness from him and our family. He lived out for me in bold colors that at the end of the day you can focus on what’s tearing you apart or you can keep your eyes on what is holding you together. You see forgiveness truly doesn’t release the wrong-doer from their responsibility, it releases you from your bondage to the pain. His message got through to me and I began to speak about forgiveness.

After my father’s visit with the man who killed my brother, I continued to speak about forgiveness, inspired by my father’s strength and courage. My heart had changed and I too was ready to not only personally extend forgiveness, but also hear the man’s story, validate his pain, and apologize for the angst I have caused him.

That is where the Restorative Justice Project enters my story. I had amazing facilitators who not only let me take the process at my own speed but truly embraced the pain I was feeling. They showed me that it was perfectly okay to not actually be okay. They reminded me that okay might not be something I can hold in my hands today but someday I would be strong enough to say that I was okay. Through our discussions I felt that I was learning how to balance holding on to the amazing memories and feelings while letting go of the painful ones. They inspired me to stand up and smile again because allowing the pain to take second stage is not a sign of giving up but rather a practiced strength. I realized through this that so much of what I was doing in this process was inspired by what my brother had inspired in me. 

When the day finally came that I was sitting face-to-face with the man who killed my brother and I feared I would come out of my skin and scream at the top of my lungs about all of the pain he had caused me, all I felt was empathy. My tears weren’t tears of sorrow for myself, they were for him. I came to realize that we were more alike than we were different, both pained and grieving the loss of the same amazing young man. I shared with him beautiful memories of growing up with such a “wonderfully perfect” little brother. We laughed together. It was awkward at first, but comfort quickly followed. He shared painful memories of mistakes made, chances taken, and lessons learned. It was in this moment that the anger I felt for him disappeared and in an unexpected moment of peace and grace, as we both cried, that I looked into his eyes and he was no longer the man who killed my brother, he was Lee. He had depth and character. He had emotion and expression. He had a heart and a soul.

Today I stand before you a drastically changed person. This process was painful, at times agonizing. There is nothing fabulous or glitzy about it. But I wouldn’t change if for the world. I am proud to say I am the older sister of Mike. I am equally as proud to say that I met Lee and my life will never be the same again!
Thank you for everything you are about to embark on. The next changed life may be yours to witness.

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Remington Center Students Practice Before the U.S. Court of Appeals for the Armed Forces

The invitation came like a bolt out of the blue.

The United States Court of Appeals for the Armed Forces – the federal appellate court that oversees military courts-martial – announced that the entire five-member court would hold an oral argument at the University of Wisconsin-Madison Law School, and, best of all, the Court had invited Remington Center students to participate as parties. 

The Court, seated in Washington DC, holds oral argument at law schools across the nation as a part of a judicial outreach program. The judges – each a civilian appointed by the President, confirmed by the Senate – grant law students permission to serve as amicus curiae, better known as Friend of the court. As amicus curiae, the students write and file an appellate brief and present a ten-minute oral argument before the judges. It is a rare and special opportunity, but, there is one catch. The court’s busy docket requires students to work according to a compressed schedule. In this case, Remington Center students had just eight weeks to master both the facts and the law. 

The facts in this case were fairly straight-forward. Postal authorities had intercepted a marijuana-scented package addressed to the defendant, a specialist in the US army. These postal authorities, joined by military police, received a warrant permitting investigators to deliver the package to the defendant's home, and, once the package entered the home, to search the immediate vicinity in which the package would be found. Investigators set-up a controlled delivery; that is, an investigator posed as a postal carrier to deliver the package. However, when investigators tried to deliver the package to the defendant's house, no one was home. Investigators set the package on the house's doorstep, and they waited for two hours. Eventually, the defendant's stepson arrived home and picked up the package. As soon as the stepson entered the house, investigators swarmed. They seized the package, the stepson, and searched the entire house, where investigators found drugs & drug paraphernalia. The court asked the students to brief and to argue the constitutionality of searching the defendant’s entire home. 

""Within days of the invitation, the Remington Center had assembled two teams. John Pray, director of the Criminal Appeals Project, would supervise two second-year law students, Veronica Sustic and Jake Blair. Together, these three would argue that Fourth Amendment permitted the search of the defendant’s home.  Steven Wright, clinical instructor with the Wisconsin Innocence Project, would also supervise two second-years, Catie White and Curtis Hinca. This second team would argue that the evidence violated the Fourth Amendment. 

All six met together to discuss initial logistics. At that meeting, the teams agreed that both sides would be completely separate. No sharing of information. No discussing arguments. No revealing appellate strategy. The six also agreed that there would be no more group meetings.

The next six weeks, both teams immersed themselves in Fourth Amendment caselaw. The students wrote memos summarizing the 550-page record, and each team went through the painstaking process of drafting a brief: research, draft, revise; research, draft, revise; research, draft, revise. Each team also called their respective counterparts: the lawyers who too would argued on behalf of the government, and the lawyers who would argued on behalf of the defendant. In these calls, the students considered the facts not appearing in the record, asked whether the lawyers had considered other options. In pursuit of the perfect brief, students worked around their busy academic schedule, some even sacrificed their weekends and Spring Break. 

After submitting their brief, the students focused their energies on oral argument. Veronica Sustic would argue as amicus on behalf of the government; Curtis Hinca would argue as amicus on behalf of the defendant. The students held moots, testing phrases and arguments, and received feedback from their teammates and peers. Some details that glowed on paper, they noticed, now seemed dull and unconvincing; some details, once thought weak, now seemed to come alive with rhythm and melody.
The day of the argument, in the law-school classroom where the court held its afternoon session, every seat was filled. The argument, open to the public, beaconed a cross-section of the Madison legal community: lawyers and judges, alumni and pre-law undergraduates, law school faculty and staff. A federal marshal manned the door, and both Dean Margaret Raymond and the clerk of court offered an introduction welcoming all to the argument. 

In his argument opposing the search, Hinca emphasized the Fourth Amendment’s intent to protect the sanctity of the home. The government, Hinca told the court, did not have sufficient grounds to invade the defendant’s home. In her oral arguments supporting the search, Sustic emphasized the government’s relatively low burden of proof.  The students answered complex hypotheticals, some anticipated, some not, and each judge prodded the students’ positions, testing boundaries, asking about the larger policy implications if a proposed argument should succeed.

At the end of the argument, the court accepted the case and congratulated students on a job well done. The case remains pending while the judges continue to weigh the case. In the meantime, the four Remington Center students wait patiently for the court’s opinion, eager to know which argument prevailed. 

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Student Articles

An “Older” Student’s Clinical Experience

By May Lee, 2L

As a 38-year-old mother of five children, I decided that instead of buying a hot red sports car or escaping to a sunny beach island to appease my mid-life crisis, I’d go to law school. At least that’s the version I jokingly recite when people shockingly ask why I have chosen to come to law school at this phase in my life.

May LeeI understand why shock is a perfectly natural reaction. Most of my classmates are at least a good decade younger than me and in very different places in their lives. Ironically, while everyone else wonders how I do what I’m doing, from my perspective, I actually wonder the very same thing about my young classmates. As I have been experiencing the rigorous academic and emotional challenges of law school, I am more and more amazed at how resilient so many of my colleagues are. And though I would never have considered myself an age-biased person, reading, writing, studying, and working right alongside my younger counterparts has given me an exponentially renewed respect for the deep tenacity I see in so many of them. I’ve witnessed the resilience and tenacity firsthand during my time as a student attorney in the Wisconsin Innocence Project (WIP).

Through WIP, I built meaningful friendships with other, much younger, law students as well as trusting relationships with my clients. WIP not only gave me a chance to enrich my learning experience by performing work that attorneys do on a daily basis, but through work with student partners, I got to see the incredible talent that other students brought to their writing, investigation, and courtroom experiences. There is a certain kind of accomplishment we all were able to gain by filing motions in court on behalf of the futures of our clients, by building relationships with those clients, and by working in a professional setting with partners and supervising attorneys.

My time at WIP began with a four-day hearing in Green Bay on a shaken baby syndrome (SBS) case. My partners and I worked with a team consisting of two WIP students from the previous year and two lead supervising attorneys. This hearing was not just some theoretical or hypothetical exam question that, at worst, would impact just my grade. No, this hearing was real life; it was our client’s life. He depended on all of us to be prepared, thorough, and competent. Our team read through numerous pleadings, transcripts, and articles. We prepared witnesses, arranged the schedules of our experts, and consulted with the attorneys on the facts, legal arguments, and strategies. All my years of work gave me invaluable experience, but ultimately would not provide me an advantage over my younger partners when it came to learning the law.

In the process of preparing for this case, we were educated on the evolving science surrounding SBS. Developing science provided us with new evidence to support our case. Formerly, the medical community believed that a triad of injuries found in a child were exclusively the result of shaking or abuse. Recently, further research has demonstrated that those same injuries can be the result from accidents such as short falls.

Though we jump started our clinical work with this case, my partners and I certainly were not yet ready to jump in and be lawyers. However, that experience started our preparation to be ready for the work that we will someday face as practicing attorneys.

As valuable as the actual work we did, are the relationships I built with my partners. Despite our age differences, my partners and I created a group chat for the three of us to have a forum to check in with one another. We discussed school related topics and at other times used the chat as an outlet to vent to one another (though, admittedly we sometimes just gossip like law students do, of course). One of the times our group chat was most useful was when the three of us were pushing through to draft our nearly 100-page motion. We worked diligently on the motion; however, the night before it was due, there was still plenty of work left to be done. That night, the three of us stayed up into the wee hours of the next morning. We encouraged one another to stay awake, to keep at it. It was important that we met the deadline we were given, not just for the sake of meeting a deadline, but for the sake of doing quality work for our client.

As we continued to progress with our work for this client, we began to experience an increasing sense of his trust and confidence in us. He sent us letters, made drawings as a sentiment of his appreciation, and often verbally expressed his gratitude for us. In our final call to him as his student attorneys, it was personally a very bittersweet conversation. Yes, he would be in the hands of new students and capable attorneys who would handle his case going forward, but there was also a sense of melancholy. I realized the dynamics of several relationships were evolving with this closure. We would no longer directly be seeing our client through to the next steps of his legal pursuits and my partners and I would soon be moving on to the next adventures of our legal pursuits, separately. The decision to participate in WIP as well as to come to law school as an older student was the right one, although I still think wistfully of red sports cars and island beaches during exam periods.

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Applying the Restorative Justice “Circle Process” to Diversity Discussions

By Sarah Zwach, 2L

Recent police shootings of unarmed minority males around the country have sparked a debate in the nation about perception, stereotypes, and police use of lethal force. While being trained as a Restorative Justice Project facilitator in the summer of 2014, I wondered if the “circle” process that I was learning could be applied to this debate. My idea was that by using the circle process, a dialogue about race and perceptions on the UW Madison campus could repair some of the harm stereotypes cause and could also create awareness and challenge students to question those perceptions in the future.

The circle process is a facilitated dialogue technique and is based on the principle that all participants are equal. Specifically, the process places importance on both talking and listening to ensure mutual understanding and provide for deeper, more meaningful discussion. Due to the way the circle process is conducted, I thought the process would provide a safe environment where all voices could be heard and students of diverse backgrounds could converse with their peers. With the support of Jonathan Scharrer, the director of the Restorative Justice Project at the Remington Center, I reached out to and met with various persons connected with University of Wisconsin-Madison campus housing to discuss the use of the circle process in the dorms.

Restorative JusticeIn the spring, I met with representatives from the UW Multicultural Student Center, the Community Relations Office and the Dean of Students Office about the circle process. They suggested that I talk to the coordinator of an upcoming Diversity Day event at Union South. I did this and was invited to fill a 20-minute slot at the event. I had only two weeks to prepare and was not sure anyone would show up, let alone participate. After all, there were similar events at the same time as mine and getting students to talk about diversity can be as uncomfortable as pulling teeth.

After setting up for the dialogue on the day of the event, I waited for someone, anyone, to show up. Ten minutes after the discussion was supposed to start, I was still waiting. While eating my complimentary Babcock ice cream, I thought about how hard I had worked to develop the program and convince others that it was worth investing in. As I was about to leave, the coordinator of the Diversity Day decided to combine the last three events.

After participating in the other two events, fifteen students sat down for the circle discussion. I explained that the circle would be facilitated by a “talking piece”: the person with the talking piece talks while the others listen. This dynamic ensures the circle is a safe place for everyone to share their opinions.

I asked everyone to state their name and to share what they like or dislike about their name. This helped everyone get to know each other and relate a piece of their identity they did not chose. Some students shared that they did not like their name because it was unusual and difficult to pronounce. These students also described that because their name was unusual, it could be a source of alienation among their peers. In efforts to be accepted, these students described how they came up with more commonplace nicknames to use instead of their birth names. Other students stated that they did not like their names because they were common and wished they had more unique names so they could feel different from their peers and more unique.

After getting to know each other, the students participated in an activity called “Circles of Our Multicultural Selves.” Each student was given a piece of paper with a flower design on it. The student put his or her name in the middle of the flower’s circle and then wrote groups the student identified with in the petals. I asked the students to think about a time when they felt proud to be a member of a certain group, a time when it was painful to be a member of a certain group, and one thing they wish people would never say about one of their groups.

I hoped students would think about other groups they identify with, in addition to the conventional associations society often focuses on. By adding to the groups that make up their identity, students would expand the definition of diversity and also provide additional grounds with which to relate to one another.

Students included groups such as race, ethnicity, gender, sexual orientation, disability, college major, body type, hobbies, age, and where they are from. Students also described the groups they felt proud to be a part of and groups that were painful to be a part of. All students wrote down static groups but explained that they typically identified with one group more strongly than others, which tended to be a group they were most proud to be a part of.

Students also explained that society often pinned them into one crowd and ignored other groups they more strongly identified with. One student described his struggle with being an African-American male and identifying as homosexual. He noted that society tries to pin him as being just a black male and ignores the fact that he identifies as homosexual as well. He pointed out that the groups he identities with are not mutually exclusive and that the convergence of the groups makes up his identity. He further explained that when we ignore all the complexities that make each of us who we are, we harm our identities and undermine their importance.

This theme radiated around the circle. As the talking piece went around, students echoed his sentiment and explained that sometimes they get caught up being so proud to be a member of one group that they forget about the other groups they are a part of. Students expressed how phrases the media and their peers use to describe the groups they identify with encourage this mentality and belittle the groups they are proud to be a part of. For example, students explained that labels like “thug,” “alien,” and “someone like you” harm their individuality because the labels insult a group they identify with. They further explained that these labels harm their identity because the labels negatively impact society’s perception of their group; the perceptions we have of others and ourselves can harm our identities. By acknowledging this harm, the students were helping each other repair that harm without even realizing it.

After an hour of dialogue, the students gave closing remarks. The students in the circle were very diverse, yet each contributed to the others’ understanding of group perceptions. Each student also listened to the others, thus helping repair some of the harm those perceptions have had on individuals in the group.

I hope this discussion is just one of the many the UW Madison campus will have about diversity. The more students talk about diversity, the multi-facets of their identity, and the perceptions that result from them, the more likely the students are to respect their peers, challenge each other’s perceptions, and create a less biased community.

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Friends of the Remington Center Endowment In Need of Support

The Friends of the Remington Center Endowment (FORCE) provides small stipends for the students who choose to enroll in the summer clinical programs and summer externships of the Remington Center. Even this small stipend is very much needed, and appreciated, by the students. The initial capital to establish FORCE came from Frank Remington and his family. Others, mostly alumni of the Remington Center clinical programs, have provided additional donations. Unfortunately, the Endowment is not self-supporting, and runs the risk in the near future of not being able to support students in the manner it has in the past.

Given that we represent underserved prison populations, there is no obvious base of financial support for the Remington Center.  As such, we depend on the support of our alumni and those friends who have demonstrated an interest in the mission of the Remington Center clinics.

If you can provide financial support of any kind, it would be greatly appreciated. Donating to FORCE through the UW Foundation is simple and can be done online, if that is your preference. To donate, please follow this link.

Thank you.

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