Abstract
Excerpted From: William J. Fife III and Beylul Solomon, Indigenous Rights: A Pathway to End American Second-class Citizenship, 32 Southern California Review of Law & Social Justice 59 (Winter, 2023) (387 Footnotes) (Full Document)
Struggles for fundamental rights are gaining momentum in America, especially in American lands existing outside of statehood. Washington D.C., Puerto Rico, and Guahan (officially known as “Guam” in the present day, but this paper will use the Indigenous term “Guahan”) are all exercising their right of self-determination through community-based dialogues and referendums alongside legislative efforts for potential statehood and voting rights. The movement to end second-class citizenship in America is ramping up. One of the remaining racist legacies of the “separate but equal” Plessy-era SCOTUS rulings from the early 1900s are the Insular Cases. The “Insular Cases” are a collective series of SCOTUS rulings in response to litigation arising from newly acquired territories of the “American empire” in the aftermath of the Spanish-American War of 1898. They include Downes v. Bidwell, which enshrined, to varying degrees, second-class citizenship in American territories. Second-class citizenship applies to millions of residents of U.S. territories that are U.S. citizens (or “nationals” in the case of American Samoa) but do not have the right to vote for the President, do not have representation in the U.S. Senate, have non-voting representation in the U.S. House of Representatives, receive lower federal funding relative to states, and have stark poverty and health disparities. The tentacles of U.S. imperialism and the Insular Cases' reach even includes the human rights black hole of Guantanamo Bay in Cuba, whose origins also date back to the Spanish-American War of 1898. In addition to Guantanamo Bay, Cuba, the war created the U.S. territories of Guahan, the Philippines, and Puerto Rico.
As awareness of the Insular Cases and demands for legislative solutions continues to grow, any conversation about reforming systemic racism is not credible without also including the foundational Doctrine of Discovery-based cases. President Jefferson, as well as other Founding Fathers, recognized the Doctrine of Discovery against Indigenous land rights and implemented an American version called “Manifest Destiny” for westward “expansion” with the Louisiana Purchase and the Lewis and Clark expeditions. The basis for the international law of colonialism, the “Doctrine of Discovery” was integrated into America legally in 1823 with the seminal property law case that all U.S. attorneys read about in law school: Johnson v. M'Intosh (“M'Intosh”). essentially legalized land theft and thus the eventual genocide of Indigenous peoples through the religiously-authorized Doctrine of Discovery (that is, an arbitrary logic that other White Europeans had taken land before, thus making it incontestable). The “Doctrine of Discovery” is a collective of papal bulls (Vatican-based authorizations) that provided the framework for European empires declaring ownership of land from non-Christian peoples on the basis of their religious beliefs. Starting with M'Intosh, the Doctrine of Discovery was incorporated into American law, and used by other nations such as Canada. From the Northwest Ordinance of 1787 and continuing through today, the U.S., as an “American empire,” dexterously (or conveniently) chose which international laws it would select, such as ignoring the Royal Proclamation of 1763, which protected Indigenous land rights west of the thirteen colonies, and implementing the Doctrine of Discovery. Neither M'Intosh nor the Insular Cases are currently possible without the Vatican-based Doctrine of Discovery, so the Insular Cases are in reality just a subset of Doctrine of Discovery-based case law, which we will later describe as the “Discovery Cases” (M'Intosh-related cases & the Insular Cases combined).
These examples of active case law have varying impacts on populations living in U.S. territories. The Insular Cases impact all U.S. territories. The Discovery Cases, along with the Equal Protection Clause, specifically impact Indigenous peoples living in U.S. territories who fear that closer union with the U.S. would destroy their culture through the loss of Indigenous land rights. One of the most notorious Insular Cases, Downes v. Bidwell, references M'Intosh three times and “discovery” nine times. Denouncing the Insular Cases alone would address symptoms and not root causes. To adequately discuss the Insular Cases requires a new classification and terminology - a broader scope to include the Insular Cases and all other cases based on the Doctrine of Discovery under the larger umbrella term of what we call the “Discovery Cases.” This could result in rooting out the arguably unconstitutional religious authorization of the Doctrine of Discovery from the American legal system. The Doctrine of Discovery is the foundation for international law with regard to the dispossession of Indigenous land rights. If the Founding Fathers had no issue using international law to dispossess Indigenous peoples, then international law can be used today as a remedy, such as legislatively implementing the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP).
A. United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP)
UNDRIP is the most comprehensive international Indigenous rights instrument, covering a wide range of issues that recognize the traumatic histories and living legacies of colonialism. It contains forty-six articles that address all aspects of human rights, including culture, environment, language, education, and health. A main component of UNDRIP that is stated several times throughout the Declaration is the importance of Indigenous peoples' land rights. Article 26 of UNDRIP states, “Indigenous peoples have the right to the lands, territories and resources which they have traditionally owned, occupied or otherwise used or acquired ... have the right to own, use, develop and control the lands, territories and resources that they possess by reason of traditional ownership or other traditional occupation or use, as well as those which they have otherwise acquired ... [and] States shall give legal recognition and protection to these lands, territories and resources. Such recognition shall be conducted with due respect to the customs, traditions and land tenure systems of the indigenous peoples concerned.” UNDRIP has a diverse track record with many different Indigenous peoples and governments and includes a variety of mechanisms to utilize via the United Nations. Indigenous rights are international human rights - they do not threaten non-Indigenous peoples' rights. Indigenous rights are not beneficial exclusively for Indigenous peoples; everyone can benefit from a diversity of cultures. Humanity suffers when entire cultures and languages become extinct - whether they are Indigenous or not. The Discovery Cases are a White supremacist stain on the American judicial system and continue the destructive legacies of genocidal colonialism through the present day, especially for Indigenous peoples. Indigenous land rights, such as Article 12 of the CNMI Constitution, which stipulates that only people of “Northern Marianas Descent” can own land, should not have to rely on the Insular Cases in order to exist as an unincorporated territory. UNDRIP-based legislation could be an alternative solution to these issues.
UNDRIP is currently legally unenforceable in the U.S., although it could provide persuasive support in domestic courts. Enforceability requires the implementation of UNDRIP-based legislation. This can happen at both the local and federal levels. The strongest international example of implementation is Bolivia, which incorporated Indigenous rights into their national constitution. Be that as it may, this comparative analysis focuses on local and federal UNDRIP-based legislative actions in Canada that would be in the realm of comparability for a U.S. territory such as the CNMI and the U.S. at the federal level. If the U.S. Congress were to legislate UNDRIP-based laws similar to Canada, this would establish protections for Indigenous cultural survival that eliminate territorial concerns regarding closer political union with the U.S. - whether it be citizenship, reunification, or statehood.
B. Implementing Indigenous Rights
In an age of relative progress in gender and sexual equality, concepts of feminism and LGBTQ+ rights find roots in ancient Indigenous culture. The status of matrilineal or matriarchy-based cultures is core to many Indigenous peoples, including the Indigenous Chamorro people of the CNMI. Historically, the Chamorro people had both Maga'lahi male chiefs and female Maga'haga chiefs, and their cosmological origin story involves equally powerful brother and sister bonds. and Maga'haga denoted the highest-ranking position in a clan for Chamorro people, and women held control over resources such as land rights and favorable divorce outcomes. Two of the most prominent Indigenous rights advocates in recent history are the Trask sisters of Hawaii. The late Professor Emerita at the University of Hawaii, Dr. Haunani Kay Trask, wrote extensively on the value of UNDRIP. Dr. Trasks' sister, attorney Miliani Trask, is a co-drafter of UNDRIP and the first elected leader of Ka Lahui Hawaii. Artist and former CNMI Representative Cinta Kaipat, one of the first CNMI Chamorro-Refaluwasch females to obtain her Juris Doctor, is an example of a modern-day Maga'haga that continues to engage in art and advocacy for Indigenous rights, especially for her homeland of the Northern Islands that include the volcanic island of Pagan. If an Indigenous Renaissance is possible, listening to the voices of Indigenous female leadership could be a wise strategy worthy of consideration.
Finally, if there were willing and interested parties, legislative implementation of UNDRIP could lay the groundwork for statehood, as Indigenous peoples in U.S. territories could be more agreeable to closer political union with the U.S. if cultural safeguards are in place. Statehood is the only available way for territories to remain American, obtain individual and collective voting rights, and end second-class citizenship. The recent “For the People Act” would be a step in the right direction in creating a congressional task force to address territorial voting rights. If cultural land rights for the Indigenous peoples of the CNMI exist at the federal level, then reunification would be a compelling argument for consolidation into statehood. Reunification efforts between Guahan and the CNMI have failed in the past in vastly different circumstances, but that does not mean failure in modern times. Chamorros were partitioned and separated, played off each other, and used to work against their own people by multiple colonialists, especially most recently under the Japanese occupation pre-World War II. Consider the environment that created the divisions between Guahan and CNMI Chamorros to this day:
When a Guam Chamorro commits an indiscretion against the Japanese, he gets one lash. On the other hand, when a Saipan Chamorro commits an indiscretion, he gets 10 lashes. The reason for this is that a Guam Chamorro was not raised by the Japanese and thus may be expected to commit an indiscretion. However, a Saipan Chamorro was raised by the Japanese and is not supposed to commit an indiscretion.
Steve Limtiaco, World War II Deepened Rift Between Guam, Saipan CHamorus
All historic and current intra-Marianas tension arguably would not exist but for genocidal colonialism and partition. Furthermore, implementing UNDRIP puts citizenship and statehood on the table for American Samoa as well, since federal UNDRIP law would protect cultural rights and alleviate Indigenous cultural survival fears. If all territories felt like their Indigenous rights were legally protected, there would likely be a unanimous condemnation of the Insular Cases. With unanimity, a consensus could move forward with actions that address systemic racism and repeal the Insular Cases as well as all of the additional Discovery Cases, which would address the roots of today's second-class citizenship in America.
Although UNDRIP-based legislation at the federal level may for a time be improbable, the hypothetical is possible, considering both the Republican and Democratic parties are strong in the Marianas and thus have bipartisan appeal in Washington D.C. The people of the Marianas are currently marketing material for the Republican party in the sense that they show that the GOP is not just a “White” political party. The first gubernatorial endorsement for then-candidate Donald Trump in the 2016 presidential campaign was Indigenous Republican Governor Ralph Torres of the CNMI. Statehood for the Marianas should appeal to both major political parties. Ideally, if the CNMI led with UNDRIP-based legislation, and if Congress also legislated Indigenous rights, the CNMI and Guahan could pursue statehood together. There is no ending second-class citizenship without full voting rights, which requires statehood. Indigenous rights-based legislation could be the key to addressing disparities and synthesizing international human rights law with U.S. foreign and domestic policy while ending second-class citizenship in U.S. territories.
C. Discovery Cases and the Roots of American Second-Class Citizenship
Along with the institution of slavery and female disenfranchisement in coverture, the roots of American second-class citizenship began immediately upon debasement from colonized to colonizer. These roots reside in American “Manifest Destiny” colonialism of Indigenous lands from “sea to shining sea” to create “incorporated territories” that would gain first-class citizenship upon obtaining statehood. The Insular Cases go further by racist judicial fiat in creating “unincorporated” territories - mostly non-White territories not on a track for statehood that can thereby exist outside the full application of the Constitution in seemingly perpetual inequality. Fortunately for both the CNMI and U.S., the U.S. federal law referred to as the Covenant created the CNMI-U.S. political integration and can be amended through mutual consent (or unilaterally by the U.S. federal government). The Covenant agreement arguably makes the CNMI the most empowered of the territories, although they still lack essential voting rights and equal access to all three branches of government - just like all other U.S. territories.
While the CNMI “agreed” to the Covenant and thereby “agreed” to be treated as second-class citizens, the circumstances in which that took place must be critically contemplated. Second-class citizenship that included Indigenous land rights and limited self-government at the time was commonly considered a tremendous improvement after hundreds of years of brutal genocidal colonialism, World War II-based bombing causing the destruction of their islands, followed by years of internment camps under the U.S. The CNMI Founding Fathers deserve credit for a deal that included Indigenous land rights protections after surviving centuries of occupation by colonizers that did not allow them the freedom to move about and utilize their lands as they saw fit. However, the journey for true self-determination does not have to end in inequality. These CNMI foundational leaders were wise to leave open the ability to amend the Covenant so that the CNMI could continue decolonization for greater self-determination in the future.
If the people want out of second-class citizenship and wish to remain American, the CNMI needs to pursue statehood. If the CNMI alone without Guahan were to pursue statehood, and if the Northwest Ordinance of 1787's minimum population requirement of 60,000 or more to be eligible for statehood is still in effect for “incorporated territories” transitioning out of “unincorporated” status, then the CNMI would have to wait until its population of approximately 47,000 increases. If they reunified with Guahan and pursued statehood together, they would have a combined population of over 200,000 and gain immediate eligibility. Recent Census data revealed a shocking 12% drop in the CNMI population since 2010, so reunification might be even more crucial than ever if the CNMI desires political equality for its people.
However, second-class citizenship in America will still exist even with voting rights as long as systemic racism remains alive and well in case law. Perhaps the two most infamously racist SCOTUS collections of active case law are Johnson v. M'Intosh and Downes v. Bidwell, and it is no surprise that they are intimately connected. Many people are familiar with the Insular Cases thanks to recent civil rights advocacy as well as pop culture. However, lesser known and far more shockingly racist are the original cases based on the Doctrine of Discovery, which includes the 1823 foundational American property law case of M'Intosh and its progeny. The case of Johnson v. M'Intosh, a dispute between two White men regarding ownership rights to Indigenous lands, is a Supreme Court ruling that removed ownership of land from Native American tribes and put it in the hands of the U.S. federal government based on Vatican authority and religious superiority.
If the abhorrent Insular Cases need to be discarded into the dustbin of history, M'Intosh demands equal scrutiny. M'Intosh's arguable First Amendment violations of freedom of religion would today be considered modern-day war crimes of land theft and genocide. A potential legal justification for SCOTUS to overturn these bigoted Discovery Cases could rely on the argument that any religious “decree” justifying land theft is an unconstitutional violation of the First Amendment. Implementation of UNDRIP could provide the congressional action that SCOTUS and territories alike demand to resolve the Insular Cases issue.
Reforms between the U.S. federal government and “non-states” are actively moving forward with proposed statehood for Washington D.C. and decolonization with self-determination considerations for Puerto Rico and Guahan that may also include statehood. Other U.S. territories, like the CNMI and American Samoa, have largely been outside this conversation due to concerns about cultural extinction under greater integration with the U.S. Thus, Indigenous rights legislation with a national action plan is a creative endeavor to address solutions not only to a post-Discovery Cases world, but also to pave the foundation for U.S. territories to potentially become states while safeguarding cultural survival. SCOTUS has the power to undo the historic White supremacist embarrassment of the Discovery Cases: “... (I)t is [the Supreme] Court's prerogative alone to overrule one of its precedents.” The U.S. Congress has similar discretionary power to do the same with the admission of new states, and Indigenous rights legislation could be the harmonizing nexus for these two branches of government to ameliorate American systemic racism. “... Congress's exercise of its express constitutional authority to decide to admit a new state is a classic political question, which courts are highly unlikely to interfere with, let alone attempt to bar.”
Global protest movements demanding an end to police brutality show the time is ripe to address systemic racism. For example, the Paris Climate Accords and the Iran nuclear deal did not survive the Trump presidency, but it is a credit to his administration that the U.S. commitment to UNDRIP remained unspoiled. Current President Biden served as the Vice President in President Obama's administration when the U.S. became a Signatory to UNDRIP. The Declaration has been proudly endorsed by the current Department of Interior Secretary Deb Haaland, the first Native American in a presidential cabinet. Bold Indigenous rights-based legislation at the local (CNMI), regional (Guahan, American Samoa), and federal levels (U.S. Congress) would incorporate international human rights law (Indigenous rights) with U.S. foreign and domestic policy (UNDRIP). America may be late to implementing UNDRIP, but it can and should legislate Indigenous rights that address legacies of genocidal colonialism, systemic racism, and provide a pathway to end second-class citizenship in its territories. Prior to discussing the legal implications of the Discovery Cases and how UNDRIP-based legislation could be implemented in a U.S. territory like the CNMI, it is necessary to review the CNMI's colonial history and the resulting impact it has had on the islands and people.
D. Territorial Focus: CNMI Historical Background
The Spaniards would have done better to remain in their own country. We have no need of their help to live happily. Satisfied with what our islands furnish us, we desire nothing. The knowledge which they have given us has only increased our needs and stimulated our desires ... They dare to take away our liberty, which should be dearer to us than life itself ....
The Spaniards reproach us because of our poverty, ignorance and lack of industry. But if we are poor, as they tell us, then what do they search for? If they didn't have need of us, they would not expose themselves to so many perils and make such efforts to establish themselves in our midst. For what purpose do they teach us except to make us adopt their customs, to subject us to their laws, and to remove the precious liberty left to us by our ancestors? In a word, they try to make us unhappy in the hope of an ephemeral happiness which can be enjoyed only after death.
They treat our history as fable and fiction. Haven't we the same right concerning that which they teach us as incontestable truths? They exploit our simplicity and good faith. All their skill is directed towards tricking us; all their knowledge tends only to make us unhappy. If we are ignorant and blind, as they would have us believe, it is because we have learned their evil plans too late and have allowed them to settle here.
Let us not lose courage in the presence of our misfortunes. They are only a handful. We can easily defeat them. Even though we don't have their deadly weapons which spread destruction all over, we can overcome them by our large numbers. We are stronger than we think! We can quickly free ourselves from these foreigners! We must regain our former freedom!
Chamorro Maga'lahi Chief Hurao
The Commonwealth of the Northern Mariana Islands (CNMI) is the geo-strategic westernmost U.S. territory of fourteen islands, immediately north of Guahan, and is closer to China than California. Most Americans probably do not know that the CNMI even exists, let alone that it is a part of America, yet it plays a major role in the U.S. military's “Pivot to Asia” amongst hyper-tensions with China.
The Chamorro people accomplished great feats such as leading the first Remote Oceania culture and settlement at least 3,500 years ago with megalithic latte stone structures, ancient cave art, and fast Indigenous Sakman sailboats (also known as “flying proas”). They also had their own cosmology, calendar, and astronomy, along with pescatarian diets, water-based lifestyles, and a matrilineal-based culture. The destructive legacies of nearly 500 years of war, disease, and forced acculturation by genocidal colonialism, first under the Spanish, then German and Japanese, before the arrival of the Americans, left a wake of disparities for Indigenous peoples. A range of roots for inequities in the Marianas include second-class citizenship status with unequal access to all three branches of government via the lack of individual and collective voting rights, health care funding brinkmanship, and historic systematic efforts to push the Chamorro language to extinction.
Although there are CNMI constitutional laws recognizing Indigenous land rights such as Article 12, UNDRIP-based legislation could build on that foundation to expand the field of laws beyond just one Indigenous issue. Article 12 of the CNMI Constitution preserves land rights for Indigenous peoples having Northern Marianas descent. Currently, the combined twenty-nine percent minority population of Indigenous peoples overwhelmingly dominate local electoral politics. The CNMI's Indigenous cultural survival may initially seem secure. Yet, with diminishing native language fluency and discussion to destroy perhaps one of the most important domestic Indigenous rights laws in America by discarding Article 12, cultural survival is indeed under threat.
Before the 17th century Spanish “Reduccion” system of genocidal colonialism in what is now called the “Marianas” archipelago of Guahan and the CNMI, the islands were all one united home to the Indigenous Chamorro people. The Indigenous Chamorros fought and resisted arguably one of the most powerful nations on earth at the time-Spain-for thirty years of “divide and conquer” warfare. The violence and disease at the hands of the Spanish resulted in the decimation of the Chamorro population by at least eighty to ninety percent. Surviving Chamorro people were forced to endure a “convert-or-die” colonial mindset, with benefits and privileges going to “good Christians” but never full freedom. Although now partitioned since the conclusion of the Spanish-American War of 1898, the Indigenous peoples of Guahan and the CNMI still share deep-rooted familial and cultural bonds that are undermined by legacies of division.
Studies suggest a strong cultural identity correlates with positive health outcomes. Alternatively, disconnection from Indigenous culture can result in greater negative health outcomes. A strong culture would presumably be a united one. Several attempts to reunite the archipelago separated by colonialists were unsuccessful in the past. Reunification would be a great catalyst to pursue statehood together, as the U.S. has denied Guahan the right of self-determination by maintaining Guahan as a “non-self-governing territory.” The United States can be labeled a “colonizer” because it still has territories on the list of the UN's Non-Self-Governing Territories, such as Guahan, American Samoa, and the U.S. Virgin Islands. The CNMI is not on the list following its integration into the U.S. via the federal law of the Covenant, even though they are treated as second-class citizens without voting rights. This democratic purgatory in which an area is not technically a colony, but also not fully free with equal voting rights, provides a spectrum of outcomes for the CNMI. The Indigenous peoples of the Marianas deserve the right to decolonize in a way of their choosing; independence, free association, and integration are the main options.
Political union with the U.S. evolved during the late 1970s after decades of United Nations “Trust Territory” status following World War II, yet CNMI residents still cannot vote for the President of the United States (POTUS), and their U.S. Congressional delegate cannot vote in Washington D.C. To complete the trinity of three branches of government, the current judge of the highest court of the CNMI is Indigenous but was appointed by the POTUS and confirmed by the U.S. Senate, not by CNMI Americans. If the Chamorros of Guahan want to integrate into the U.S., reunification and statehood with the CNMI would make the strongest argument to end second-class citizenship in the Marianas.
Local and federal UNDRIP-based legislation could maintain current agreements regarding Indigenous land rights in the territories and preserve cultural survival for future generations with increased political equality. If the Indigenous peoples of the CNMI and Guahan want to not only reunite, but also remain with the U.S., UNDRIP-based legislation is an ideal version of what statehood in the U.S. could look like for Indigenous peoples currently in territories. This would at least bring the Marianas out of second-class citizenship.
[. . .]
UNDRIP-based legislation can be a medium to begin the process of healing via shared community-building that recognizes Indigenous rights as international human rights law. Legitimate arguments of sovereignty from Indigenous peoples around the world should be evaluated on a case-by-case basis, as Indigenous peoples have the right for self-determination that allows them to maintain sovereignty or submit to another Sovereign. Indigenous peoples exercising their right of self-determination via integration with the United States deserve their rights to be respected and enforceable. If the U.S. is honest about their foreign and domestic policy, implementation and enforcement of those purportedly supported policies for Indigenous rights is the logical next step. Strengthening Indigenous culture at a higher level of the public sphere benefits the entire community by enhancing international human rights law as well as cultural survival, and this could be pivotal for the CNMI. All of the above, with legal protections at the local and federal levels with UNDRIP-based legislation, could be used as a pathway to reunification, statehood, and a solution to end second-class citizenship in U.S. territories, while ensuring cultural survival.
Applying UNDRIP-based legislative approaches could be a creative vehicle to give the CNMI and other Indigenous-based U.S. territories unanimous support to denounce the Insular Cases. If there is unanimity against the Insular Cases, U.S. territories could move forward together to end second-class citizenship for nearly 4 million Americans by implementing UNDRIP-based legislation and offering statehood to any U.S. territory that wishes to remain American. Poetic justice would have the Marianas reunify into statehood together if the Indigenous people desire to do so. Indigenous rights legislation could also create a foundation to additionally discard all Discovery Cases. Cultural survival increases with Indigenous rights legislation, as Indigenous peoples are still under attack from exploitative powers. In a world of increasing instability from the climate crisis, war and potential nuclear annihilation, pandemics, etc., an Indigenous Renaissance could help the CNMI remain independently sustainable, if need be, thus ensuring self-determination. The Indigenous Chamorro blessed the CNMI with a wonderful legacy: an Inafa'maolek blueprint for a harmonious way of life with each other and nature.
If Indigenous rights are implemented at the federal level, statehood is the ticket for the CNMI out of second-class citizenship and territorial purgatory. Reunification could also bring enhanced cultural identity for the Indigenous peoples of the Marianas. UNDRIP-based legislation at the local and federal levels could create legally protected space for a culturally-enriched society. For America to end second-class citizenship, equitizing further integration, independence, or free association must be on the table for U.S. territories. If America wants to keep their geo-strategic positioning during the Pivot to Asia, this would require federal protections for Indigenous cultural rights, which could catalyze Indigenous territories' interest in statehood. Finally, ending second-class citizenship in U.S. territories can embrace diversity and reduce socioeconomic and healthcare disparities, thereby ensuring cultural survival for Indigenous peoples. If states and territories are laboratories for democracy, the CNMI could be an influential domino in implementing UNDRIP in the U.S. and ending second-class citizenship in the process.
William J. Fife III, Associate Professor of Social Sciences and Fine Arts, Northern Marianas College. B.S., Public Affairs 2001, Indiana University; M.A., International Relations 2010, University of Indianapolis; J.D. 2013, Florida Coastal School of Law.
Beylul SolomonAssocia, te Professor of Education for Rehabilitation and Human Services Concentration, Northern Marianas College. B.A., Social Sciences with a concentration in Psychology 2000, University of Bridgeport; M.A., Psychology 2002, Pace University; Ph.D., Developmental Psychology 2009, Yeshiva University.
