Lon Fuller, continued; Ronald Dworkin

1.

TOPIC FOR TODAY: Lon Fuller, continued; Ronald Dworkin
(we may not finish this all today)
• Retroactivity
• “Equal justice under law”
• Midterm control; preparation
• Lon Fuller’s “Eight Conditions of Law,” continued
• Ronald Dworkin
• Short writing

2.

Retroactivity
Did the notes on retroactivity I posted on Telegram help?
Is anyone still finding it hard to
understand why law,
to guide human conduct,
must generally not be retroactive?

3.

Retroactivity
In short:
if a law enacted today,
makes something illegal today
that was legal yesterday,
that law cannot have guided human behavior yesterday-it became law too late to do that.
So it ignores the purpose (according to Fuller) of law.

4.

Retroactivity
A retroactive law is like saying:
“What would you like for lunch yesterday?

5.

“Equal justice under law”: from your friend, the dictionary
I do not remember
looking up in the dictionary
the meaning of a preposition
(for example: to, in, at)
I learned prepositions when I learned to speak.
I know what they mean.
But do I?

6.

“Equal justice under law.”
Definition of the preposition, ‘under’
• extending or directly below.
• "vast stores of gas under the North Sea"
• at a lower level than
• "the room under his study”
• controlled, managed, or governed by
• the province is now under martial law”
Comments or questions?
=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=https://www.google.com/search?q=define+under&rlz=1C5CHFA_enUS831US831&oq=define+under&aqs=chro
me..69i57j0i512l9.1480j1j7&sourceid=chrome&ie=UTF-8

7.

“Equal justice under law”
Mira started the conversation on ”Equal justice under law.”
In his answer to the question,
“What is the purpose of law?,”
he suggested that the purpose of law is…

8.

“Equal justice under law”
Mira started the conversation on ”Equal justice under law.”
In his answer to the question,
“What is the purpose of law?,”
he suggested that the purpose of law is…
“to find [the] golden mean between rules and justice.”

9.

“Equal justice under law”
The golden mean is
a good middle way
between
two extremes
[=two things that oppose each other].

10.

“Equal justice under law”
Here is a question.
I would like you to keep it in mind
as we look ahead to Unit Two of the module
on legal interpretation.

11.

“Equal justice under law”
Is the purpose of adjudication (decision by a judge)
to find the golden mean
between
interpreting according to the letter of the law, and
interpreting according to the spirit of the law?”

12.

A few more words on the purpose of law
• In the end-of-lesson writing last time, I asked you: what according to
Fuller, is the purpose of law?
• Some people answered by stating Fuller’s view. Some just gave their
own opinion.
• I talked about Fuller’s view in the lesson. You didn’t have the slides in
time for the writing.
• But the answer was in the Notes and Exercise on Fuller that I
uploaded to Telegram before the last lesson.

13.

A few more words on the purpose of law
• That suggested to me, that some people are reading the uploads
before the lesson, and some are not.
• If you have not been reading the pre-lesson uploads--reading them is
the way to prepare for the lesson.
• And good way to strengthen your learning, is to review the slides I
upload after a lesson.
Which brings me to the midterm control...

14.

Midterm control
• It will be on this module, not the standard module you would have
taken from a regular TSUL professor.
• It will be on Unit 1 of this module, which I hope to complete next
Tuesday. I plan to use part of next Tuesday’s lesson to review and take
questions on Unit 1.
• I don’t yet know exactly when you will get the midterm. That has to
be decided by the department. I don’t think it will be next week. If
you have questions about the timing, ask Maksud.

15.

Midterm control
• There was little assigned reading in this module. The best preparation
is to review the slides. You have all of them so far. I will continue to
upload the slides for the lessons.
• To organize your review of Hart, look at Slides #73 and #74 of the
lesson on 14 March.

16.

Midterm control
• This midterm control will be a test of what you learned and
understood from the readings, assignments, exercises, and class
discussions in this module. I am interested in your own synthesis (=
синтез) of what you learned.
• This midterm control is not a research paper. Do not do any research
outside the module materials.
• I mention this now, so you will have time to prepare by reviewing the
slides.

17.

Midterm control
• If there is anything in the module so far that you do not understand,
ask me or Maksud. Talk to me after a lesson. Or, email me at
[email protected] with questions, or if you want to make an
appointment to meet me in my office.
• Please note: I won’t be teaching the lesson next Thursday, 6 April.
Maksud will be teaching in my place. And I won’t be reachable, over
Telegram or email, from next Wednesday evening, 5 April, through
next Saturday evening, 8 April.
Now, back to Fuller…

18.

Lon Fuller exercise: Question 4
4. Imagine that I say, in the classroom:
“When you complete your assignment,
bring your assignment to the Dean’s office.”

19.

Lon Fuller exercise: Question 4
What’s the problem?

20.

Lon Fuller exercise: Question 4
I didn’t say which Dean.
So you wouldn’t know where to bring it.

21.

Lon Fuller exercise: Question 4
If the purpose of laws,
as rules,
is to govern human conduct,
the laws have to be written clearly enough
for people to know
what they are expected to do or not to do.
This is the requirement of clarity.

22.

Lon Fuller exercise: Question 4
Another example:

23.

Lon Fuller exercise: Question 4
Imagine a university rule:
“Any student can be disciplined (=penalized)
for inappropriate [=неприличный?] behavior.”
Is this rule clear?
(Or, clear enough, for you to know what not to do)?

24.

Lon Fuller exercise: Question 4
“Any student can be disciplined (=penalized)
for inappropriate [=неприличный?] behavior.”
What’s the word that causes the problem?...

25.

Lon Fuller exercise: Question 4
What’s the word that causes the problem?
‘inappropriate’

26.

Lon Fuller exercise: Question 4
You know what the word ‘inappropriate’ means.

27.

Lon Fuller exercise: Question 4
But you don’t know specifically
what the university administration
believes is inappropriate.
You don’t know specifically
what not to do.

28.

Lon Fuller exercise: Question 4
Again:
If the purpose of laws,
as rules,
is to govern human conduct, …

29.

Lon Fuller exercise: Question 4
…the laws have to be written clearly enough
for people to know
what they are expected to do or not to do.
This is the requirement of clarity.
Question 5…

30.

Lon Fuller exercise: Question 5
5. Imagine that I say, in the classroom:
“Bring your assignment tomorrow
to Building 3, Room 210.
I repeat:
bring your assignment tomorrow to
Building 2, Room 212.
Anyone handing in more than one copy of the assignment
will get a grade of zero.”

31.

Lon Fuller exercise: Question 5
What’s the problem?...

32.

Lon Fuller exercise: Question 5
Remember again the purpose of law, according to Fuller…

33.

Lon Fuller exercise: Question 5
If the purpose of laws,
as rules,
is to govern human conduct,
the rules cannot require people
to do two things that are inconsistent [непоследовательный ?]
with each other.
This is the requirement of consistency.

34.

Lon Fuller exercise: Question 5
Another example:

35.

Lon Fuller exercise: Question 5
Suppose one section of a law said,
a business owner must allow a government inspector
into her place of business,
while another section of the law said,
a government inspector may enter a place of business
only with the owner’s consent.
=-=-=-=-=
See Ralf Donielson, “Legal Inconsistencies” (2019)
(https://digitalcommons.law.lsu.edu/cgi/viewcontent.cgi?article=1436&context=faculty_scholarship
#:~:text=17%20Here%20are%20some%20examples,they%20are%20not%20irreconcilably%20so.),
p. 24, citing Cardiff v. United States, (U.S. Court of Appeals for the 9th Circuit, 1952).

36.

Lon Fuller exercise: Question 5
Even if the inconsistency is a mistake,
so long as the mistake is not corrected by the legislature,
people
seeing inconsistent laws
do not know what they are permitted to do.

37.

Lon Fuller exercise: Question 5
In Fuller’s words:
there is “a confused [сбивает с толку?]
direction to the citizen.”
On to Question 6…

38.

Lon Fuller exercise: Question 6
6. Imagine that I say, in the classroom:
“If you do not bring your assignment
to the person in Building 3, Room 235
by 5:00 pm tomorrow,
you will receive a grade of zero.”…

39.

Lon Fuller exercise: Question 6
Suppose that the door to Room 235 is always locked,
no one ever answers when you knock on the door,
and there isn’t enough room
for you to slide your assignment under the door.

40.

Lon Fuller exercise: Question 6
What’s the problem?

41.

Lon Fuller exercise: Question 6
Again:
If the purpose of laws,
as rules,
is to govern human conduct,…

42.

Lon Fuller exercise: Question 6
…the laws must be possible to obey.
To punish someone
for failing to do something that is impossible,
is unfair.

43.

Lon Fuller exercise: Question 6
This is the requirement of possibility.
On to Question 7…

44.

Lon Fuller exercise: Question 7
7. Imagine that I say, in the classroom:
“Bring your assignment to Room 209
by 5:00 pm tomorrow.”
An hour later,
I send you a message on Telegram, saying,
“…Room 207.”

45.

Lon Fuller exercise: Question 7
30 minutes after that,
I send you another Telegram message, saying,
“…Room 205.”
15 minutes after that,
I send you another Telegram message, saying,
“…Room 203.”

46.

Lon Fuller exercise: Question 7
What is the problem?

47.

Lon Fuller exercise: Question 7
I know I am repeating myself,
But it is important to remember the purpose of law,
according to Fuller.
Remembering the purpose of law
will make it easier to remember and to understand
the 8 conditions of Fuller.

48.

Lon Fuller exercise: Question 7
Remembering the purpose of law,
according to Fuller,
helps you see how the eight conditions are related.

49.

Lon Fuller exercise: Question 7
Remembering the purpose of law
helps you see
how all 8 conditions
are grounded in…

50.

Lon Fuller exercise: Question 7
…the purpose of law,
and the concept of a a rule
--what a rule is,
or, what a rule has to be–
to do its job as a rule:
to govern people’s behavior.

51.

Lon Fuller exercise: Question 7
If the purpose of laws,
as rules,
is to govern human conduct…

52.

Lon Fuller exercise: Question 7
..if the laws change too fast,
people may not be able to stay up to date with what the laws say.
To punish someone
for failing to obey rules
that change often, within a short time,
is unfair.

53.

Lon Fuller exercise: Question 7
But don’t we have to be able to change the laws?

54.

Lon Fuller exercise: Question 7
Fuller would say, of course:
laws need to change,
and will change.
But if the laws change too often,
people may not be able to stay up to date
with knowing what the laws say.

55.

Lon Fuller exercise: Question 7
This is the requirement of stability [ =стабильность?]
(This is related to the requirement of publicity,
and also, in a way, to the requirement of possibility
--people have to be able to keep up.)
Now to the last question, Question 8…

56.

Lon Fuller Question 8
Imagine that I say, in the classroom:
“Bring your assignment to Building 3, Room 235, 4 April
by 5:00 pm 4 April.
Your assignment will be considered late, and receive a grade of zero,
if you do not bring it to Room 235
by 5:00 pm on 4 April.”
But then, I give a grade of zero,
to all papers received after 3:00 pm on 4 April.

57.

Lon Fuller Question 8
What is the problem?

58.

Lon Fuller Question 8
I didn’t follow the rule that I had announced.
I changed the rule.

59.

Lon Fuller Question 8
One more time:
If the purpose of laws,
as rules,
is to govern human conduct, …

60.

Lon Fuller Question 8
…the laws should be applied and enforced, as written
(unless there is a good reason not to do this—remember Elmer’s case).
This requirement Fuller calls, “congruence” (= конгруэнтность?).

61.

Lon Fuller Question 8
Today’s end-of-lesson writing will be:
• Tell me, what is (Fuller’s idea of) congruence?
• Ask me any questions you have about Fuller’s idea of congruence.
• Write your thoughts about one aspect of congruence that interested you.
--You might want to make some notes on that during the lesson.

62.

Lon Fuller Question 8
The condition of congruence
is related to
what other condition of
Fuller?
Think back…

63.

Lon Fuller Question 8
The condition of congruence
is related to
the condition of publicity:
if police officers, for example,
don’t follow the rules as written,
then--
--even if the rule is written,
and, even if you read it,
you still won’t know whether
what you read,
will be (the same as)
what the police officer will do.

64.

Lon Fuller Question 8
But, remember:
As we said earlier,
about the importance of publicity:
If the rule is written,
and you can read it,
you can at least hold the officer
accountable to the written rule.
(That is, if you can rely on the
court’s decision to be congruent
with the written rule.)

65.

Lon Fuller Question 8
What other condition is the
condition of congruence
related to?

66.

Lon Fuller Question 8
The condition of congruence is also related,
to consistency
(consistency between the rule as written and as applied), and…

67.

Lon Fuller Question 8
…to the concept of a rule.
If a ”rule,” as written,
says one thing,
but is not applied according to the way it is written,

68.

Lon Fuller Question 8
--in other words,
it is not used as a rule,
it is not functioning as a rule…

69.

Lon Fuller Question 8
Then-In what sense is it a rule?
(Something whose purpose is to govern people’s conduct.)

70.

Lon Fuller Question 8
As you know, the word “congruence” is used in geometry.

71.

Congruent = конгруэнтный

72.

Lon Fuller Question 8
You can see
that the triangles
are the same size:

73.

Lon Fuller Question 8
We say:
One triangle is congruent with
another triangle,
when,
if we imagine lifting up one triangle,
and putting it down on top of another,
the first “fits” on top of the other.
They “coincide” (=совпадают?).

74.

Lon Fuller Question 8
Please note:
The previous 7 conditions were mainly conditions on legislation.
The last condition is a condition on
the application and enforcement of law.

75.

Lon Fuller Question 8
“Congruence,” here, means agreement or harmony.
Fuller’s point is:
there should be agreement or harmony
between
the law as written,
and
official action
(how the law is applied and enforced).

76.

Lon Fuller Question 8
The idea is:
The application of laws
should match (be congruent with)
the way they are written.

77.

Lon Fuller Question 8
So, in my example:
Since I said
you had until 5:00 pm
To hand in your paper,
You should have until 5:00 pm
to hand in your assignment.

78.

Lon Fuller Question 8
If you are given until 5:00 pm,
the rule as applied (you are given until 5:00 pm)
matches (is congruent with)
the rule as written (you were given until 5:00 pm).

79.

Lon Fuller Question 8
In other words,
the “law” (of this situation)
is being followed:
it is properly applied to the situation.

80.

Lon Fuller Question 8
Why is failure of congruence a problem?

81.

Lon Fuller Question 8
Think again about the police.
Let’s say, the city street signs say the driving speed limit
is 60 kilometers per hour.
But if police officers stop cars and impose fines on some drivers
whose speed is only 40 kilometers per hour,
then…

82.

Lon Fuller Question 8
People won’t know what to expect from the police.
The people won’t know what the police expect of them.

83.

Lon Fuller Question 8
To repeat yet again:
If the purpose of laws,
as rules,
is to govern human conduct,
people must know
what they are expected to do and not to do.

84.

Lon Fuller Question 8
If government actors do not apply
and enforce the laws as written,
that is,
if the laws say one thing,
but government actors do
something else…
…then,
the laws will not tell people
what they are expected to do,
or not to do,
to avoid punishment.

85.

Lon Fuller exercise: Question 8
Now, here is another perspective on congruence:
Fuller calls congruence
“the most complex"
of the eight conditions of law.
Why?

86.

Lon Fuller Question 8
In part,
because congruence
“may be destroyed or weakened
in a great variety of ways: …”.

87.

Lon Fuller Question 8
Let’s start on this point
by going back to our police officers.
Suppose the speed limit for driving in the city
is 60 kilometers per hour.

88.

Lon Fuller Question 8
But one police officer
stops people
driving more than 40 kilometers per hour.
While another officer
doesn’t stop people
unless they are driving faster than 80 kilometers per hour.
What’s the problem?...

89.

Lon Fuller Question 8
Any officer who enforces
a lower speed limit,
or a higher speed limit,
is not following the law.
The officer’s enforcement of the speed limit
is not congruent
with the law announced to drivers.

90.

Lon Fuller Question 8
To review:
My enforcing a deadline for the submission of your assignments
different from the one I announced,
and the police officer enforcing a speed limit
different from the speed limit announced in the law,
violate the condition of congruence.

91.

Lon Fuller Question 8
But why
might a police officer
not follow the law?

92.

Lon Fuller Question 8
Suppose an officer sees
her mother
driving 80 kilometers an hour.

93.

Lon Fuller Question 8
The officer says, “It’s my mom.
She is driving faster than the speed limit,
but after all, she is my mom.”
So the officer does not stop her mom.
Why does congruence fail here?

94.

Lon Fuller Question 8
For the application of law to be congruent
with the law as announced,
the law must be applied in a way that is—impartial
( = беспристрастный? Непредвзятый?).
In other words,
each case must be decided on its own merits,
according to the law.

95.

Impartiality can fail in various ways.
What was the way impartiality failed
in the case of the speeding mother?...

96.

Lon Fuller Question 8
Helping a friend or relative
in ways inconsistent with the law.
This is bias (= предубеждение ?)
in favor of someone.

97.

Now, suppose the officer
sees someone driving 20 kilometers an hour.

98.

The person is driving so slow, the officer can see who it is.
It’s someone who lives in her neighborhood.
The person is of a nationality different
from the nationality of the police officer.
The police officer says to herself,
”I never liked that kind of person,”…

99.

Lon Fuller Question 8
…so the officer waves to the person to stop,
and writes out a notice of violation.

100.

Lon Fuller Question 8
What is the way impartiality failed in this case?...

101.

Lon Fuller Question 8
What is the way impartiality failed in this case?
Discriminating against someone
based on their social identity.
This is bias, or discrimination, against someone.

102.

Lon Fuller, Question 8
Now suppose a different officer
sees a person driving 80 kilometers an hour
and stops the driver….

103.

Lon Fuller, Question 8
The officer says,
”You were driving too fast.
I have to give you a notice of violation.
Show me your driver’s license.”

104.

Lon Fuller, Question 8
So the driver takes out his wallet,
but instead of taking out his driver’s license
he takes out something else…
(Can you guess what?)…

105.

Lon Fuller Question 8
...five 100,000 som bills.
And the driver says,
“Officer, let me give you
my driver’s license.”

106.

Lon Fuller Question 8
The officer replies…
(Can you guess what she says?)
(What would you say
if you were the officer?)

107.

Lon Fuller Question 8
“In the Police Academy
I learned about
the congruence of law.
As a “law worker,”
a person responsible
for implementing the law as written,
I am going to give you a notice of violation.”…

108.

Lon Fuller Question 8
“And, by the way,
you are under arrest
for attempted bribery.”

109.

Lon Fuller Question 8
Although congruence did not fail in this case,
bribery is one of the ways congruence can fail.

110.

Lon Fuller Question 8
Bribery is one kind of corruption:
action by government actors
that is not according to the law, …

111.

Lon Fuller Question 8
but is, instead,
an abuse of official power,
for the sake of the government actor’s
financial benefit.

112.

Lon Fuller Question 8
Another reason for corruption
is a desire for political advantage,
Including the use of official power
to harm one’s political opponents.

113.

Lon Fuller Question 8
Another form of corruption
is action by a government actor
who does something he feels like doing,
just because he has the power,
(even if does not have the legal authority).

114.

Lon Fuller Question 8
These are all failures of impartiality.
Impartiality requires
the application of law
to be based on the merits
of each case.

115.

Lon Fuller Question 8
(A point of Legal English:)
A decision “on the merits”[“merit,” related to what someone deserves]
=a decision
based on ”the law as it applied
to the particular evidence
and facts
presented in the case...”
=-=-=-=-=-=-=-=-=-=-=-=--=-=-=-=-=-=-=-=-=-=-=-=-=
https://www.law.cornell.edu/wex/on_the_merits

116.

Lon Fuller Question 8
More on impartiality:
I said,
congruence is related, in a way,
to the condition of consistency.
We learned about consistency in the making of law.
But consistency is important in the application of law, too.

117.

Lon Fuller Question 8
When a judge,
ministry official,
prosecutor,
or police officer
applies the law,
the principle of consistency is...

118.

Lon Fuller Question 8
“Treat like cases alike.”

119.

Lon Fuller Question 8
In other words:
“Treat similar cases in a similar way.”
(And dis-similar cases, differently.)

120.

Lon Fuller Question 8
But what ARE “similar,” and “dissimilar,” cases?
A simple example:
• Father: (to his 7-year old son): ”It’s time to brush your teeth and go to bed.”
• Son: “Dinara [his 10-year old sister], too?
• Father: No, she doesn’t have to. She’s 10.”
• What is similar or dissimilar depends on reasons.

121.

Lon Fuller Question 8
We will come back to reasons, in Unit 2 of the module.

122.

Other causes of failures of congruence
(failures of impartiality or consistency)
In individual judges or officials: incompetence, including:
Ignorance
Stupidity
Carelessness
Indifference
Lack of commitment or will
Laziness

123.

Even more causes of failures of congruence
(failures of impartiality or consistency):
Because of how a legal system is set up:
Not enough judicial independence.
Judges might not make decide cases
with impartiality and consistency if…

124.

Even more causes of failures of congruence
(failures of impartiality or consistency):
They have to submit their proposed decisions
for approval by political officials; or
The judges understand
that they cannot
-–without penalty—
make decisions political officials will not like.

125.

Another cause of failure of congruence arising from how a legal
system is set up.
Not that there is not enough judicial independence, but…
There is too much judicial independence.
For example:
If the system does not observe the principle:
“No person may judge her own case.”

126.

Another cause of failure of congruence arising from how a legal
system is set up.
What is wrong with a judge deciding a case
in which she has a financial or other interest?...

127.

Another cause of failure of congruence
arising from how a legal system is set up.
In that case:
will
—can—
the judge be impartial?

128.

Another aspect of congruence: how to protect it
Because of the many ways
congruence can fail,
safeguards [гарантии? мера безопасности?]
of congruence
are necessary.

129.

Another aspect of congruence: how to protect it
This is why,
according to Fuller,
there are many “procedural devices
designed to maintain” congruence.

130.

Another aspect of congruence: how to protect it
“A conscientious[= effort must be made
to determine whether [the laws have been violated]
and to impose the correct penalty…

131.

Another aspect of congruence: how to protect it
“Thus a legal system must make provisions [=arrangements]
for conducting orderly trials and hearings;
it must contain rules …
that guarantee rational procedures
of inquiry [расследование?]…
reasonably designed to [determine] the truth…”
--John Rawls, A Theory of Justice (1971)

132.

Another aspect of congruence: how to protect it
[a legal system] must contain rules …that guarantee
rational procedures of inquiry [расследование?]…
reasonably designed to [determine] the truth…”
A quick look back to test your knowledge:
Are these rules of procedure primary rules or secondary rules?

133.

Another aspect of congruence: how to protect it
[a legal system] must contain rules …that guarantee rational procedures
of inquiry [расследование?]…reasonably designed to [determine] the truth…”
A quick look back to test your knowledge:
Are these rules primary rules or secondary rules?
Secondary.
Hart calls them “rules of adjudication.”
They are the rules that govern court procedures.

134.

These procedural SAFEGUARDS of congruence include:
The right to be heard,
to tell your side of the story,
in a public trial.

135.

These procedural SAFEGUARDS of congruence include:
The right to be represented by a lawyer.

136.

These procedural SAFEGUARDS of congruence include:
The right to appeal to a higher court,
to review decisions in a lower court.

137.

These procedural SAFEGUARDS of congruence include:
Prohibition of torture
(as a means of getting evidence;
obviously, torture is more than a failure of congruence.)

138.

These procedural SAFEGUARDS of congruence include:
In the common law tradition,
what we call habeas corpus.
This is a formal request to a court
that a person who is detained [here, = locked up] or imprisoned,
be brought before a judge
to determine if the detention, or imprisonment, is lawful.

139.

These procedural SAFEGUARDS of congruence include:
(Legal English:)
Habeas corpus is a Latin phrase
that means, literally,
‘You have the body [of the prisoner].”

140.

Another SAFEGUARD of congruence:
Note, also, the constitutional provision
that serves as a safeguard on congruence:
We have discussed it before…

141.

Another SAFEGUARD of congruence:
…a constitutional safeguard of congruence.
The principle of separation of powers

142.

Another SAFEGUARD of congruence:
This principle
serves to protect
the independence of the judiciary
from the legislative and the executive branches
of the government.

143.

REVIEW: FULLER’S 8 CONDITIONS OF LAW
1. There must be legal RULES
2. The rules must be PUBLIC
3. The rules must be PROSPECTIVE
4. The rules must be CLEAR
5. The rules must NOT BE
INCONSISTENT
6. The rules must be ABLE TO BE
OBEYED
7. The rules must NOT CHANGE
TOO MUCH
8. The rules must be
IMPLEMENTED AS WRITTEN

144.

Short writing
Congruence: remember what our
police officer said (and did)…
• What is congruence?
• Ask any questions you have
about it.
• Write your thoughts about one
aspect congruence that
interested you.

145.

END OF LESSON