The Informational Crisis & Political Polarization in American Society

By: Sara Ibrahim

Edited by: Allison Rhee and Hannah Cheves

  The spread of misinformation, proliferated by powerful platforms such as Facebook, Twitter, and Google, is one of the most important legal issues affecting political polarization and discourse today. According to the legal concept of systemic duty of care, content moderation should be obligatory in order to mitigate the detrimental effects of misinformation. Additionally, to hold platforms accountable for effective content moderation, Congress should consider serious revisions to Section 230 of the Communications Decency Act. 

            Currently, Americans are suffering from an informational crisis, where the spread of misinformation[1] is shared at an alarming rate— profoundly polarizing those of different political affiliations. Misinformation has been found to spread at a faster rate than true information: according to an MIT Sloan School of Management research project, “falsehoods are 70% more likely to be retweeted on Twitter than the truth, and reach their first 1,500 people six times faster.”[2] Additionally, according to a Pew Research study, false information “may actually be accelerating the process of polarization” by “driving consumers to drop some outlets, to simply consume less information overall, and even to cut out social relationships.”[3] Political polarization results in the demonization of opposing political parties, which exacerbates legislative inaction greatly. Compromise and political discourse is increasingly difficult to have when each side does not respect the other enough to collaborate. 

The effects of polarization go far beyond just politics. As a society, polarization segregates people, making them cling to their own social and political groups and refusing to bridge over to other groups, further dividing us as American citizens. Misinformation is spreading faster than true information, making misinformation an epidemic that affects many facets of society. 

Search engines contribute to the polarization of American society by manipulating how their users see facts. Search engines are first and foremost businesses where consumer attention is the product. In the documentary The Social Dilemma, whistleblowers from Google and Facebook speak on how our worldviews are limited by search engines. They assert that many factors, including where you live and your personal search history, affect your search results. For example, if you Google search “climate change is,” you will find the suggested searches to be anywhere ranging from “a hoax” to “disrupting the planet” depending on what Google knows about your search history, preferences, and location. These results also may not always be scientifically accurate as the algorithm is not programmed to provide suggestions based on true and accurate information, but rather to keep the attention of consumers. This results in the spread of misinformation, which results in the polarization of thought, because each person now relies on a different set of facts. When we all have different facts, meaningful discourse surrounding controversial issues becomes difficult and compromise is unlikely. 

           Through content moderation, rules, and regulations consistent with a systemic duty of care, platforms’ systems need to be modified to prevent online harm.[4][5]  This is nuanced because there is no clear definition of what is classified as “harmful”. Taking down posts that are illegal is one thing; however, “harmful” is an arbitrary and subjective standard. Many would make the argument that removing “harmful” content is a breach of freedom of expression and content moderators should not have such authority. However, this argument ignores that free speech is not absolute and has limitations such as libel and slander, and that these limitations are widely considered to be “harmful.” Moreover, content moderators should have the authority to regulate their content, and the law should foster harm-reductive content moderation.

            Section 230 of the Communications Decency Act is one of the most important existing laws when it comes to platform regulation and is crucial to discuss when talking about online misinformation. It essentially grants platforms immunity from liability regarding third party posts while simultaneously allowing them to moderate posted content. Section 230 has been broadly interpreted and gives no incentive for platforms to take down harmful content. It should be revised to only apply to platforms that enact effective content moderation.[6] Generally, conservatives want to repeal Section 230 as they argue it has been used to silence conservative voices. Liberals argue the opposite, that Section 230 allows platforms to ignore slanderous and harmful content, enabling hateful speech. However, Section 230 does not mention neutrality or impartiality. It merely allows companies to set their own regulations when it comes to content moderation, which is harmful because, as noted earlier, companies are in the business of keeping consumers’ attention, not protecting the truth.             

Ultimately, the spread of misinformation is an issue that results in political polarization and the perpetuation of echo chambers— affecting all aspects of American life and political discourse. Without agreeing on what information constitutes facts, it becomes very difficult to solve any other issues or for meaningful conversations to take place, which then rules out the possibility of political actions to take place as well. To keep meaningful discourse and the hope of unity alive Section 230 must be modified, as it has the power to hold search engines accountable and help curb the spread of misinformation. This legal issue is pivotal and it is the basis of every other issue because if each person has their own facts, divisions are created, which threatens societal stability and peace. Moreover, content moderation should be enacted under the legal protections of systemic duty of care and Section 230 in order to mitigate political polarization and keep meaningful discourse and unity alive. 

NOTES:

1. false information that is disseminated regardless of intent

2. Sara Brown, “MIT Sloan Research about Social Media, Misinformation, and Elections,” MIT Sloan School of Management. October 5, 2020, https://mitsloan.mit.edu/ideas-made-to-matter/mit-sloan-research-about-social-media-misinformation-and-elections.

3. David A. Graham, “Some Real News About Fake News,” Atlantic (Atlantic Media Company, June 12, 2019), https://www.theatlantic.com/ideas/archive/2019/06/fake-news-republicans-democrats/591211/.

4. A systemic duty of care is a legal standard that states that “platforms are dependent on their users’ social connections and, thus, are obliged to reduce online harms to those users.”.

5. Alex Engler, “How Biden Can Take the High Road on Misinformation,” Lawfare, 2020, https://www.lawfareblog.com/how-biden-can-take-high-road-misinformation.

6. Olivier Sylvain, “Section 230's Challenge to Civil Rights and Civil Liberties,” Columbia University, April 6, 2018, https://knightcolumbia.org/content/section-230s-challenge-civil-rights-and-civil-liberties.

BIBLIOGRAPHY:

 Brown, Sara. “MIT Sloan Research about Social Media, Misinformation, and Elections,” October 5, 2020, https://mitsloan.mit.edu/ideas-made-to-matter/mit-sloan-research-about-social-media-misinformation-and-elections.

Engler, Alex. “How Biden Can Take the High Road on Misinformation,” Lawfare, 2020, https://www.lawfareblog.com/how-biden-can-take-high-road-misinformation. 

Graham, David. “Some Real News About Fake News,” The Atlantic (Atlantic Media Company, June 12, 2019), https://www.theatlantic.com/ideas/archive/2019/06/fake-news-republicans-democrats/591211/.

Sylvain, Olivier. “Section 230's Challenge to Civil Rights and Civil Liberties,” Knight First Amendment Institute at Columbia University , April 6, 2018, https://knightcolumbia.org/content/section-230s-challenge-civil-rights-and-civil-liberties.

Author's Social Media Usernames: Twitter (@ibrahimrsara) and Instagram (@ibrahimm.s)

Kramer vs. Kramer and the Kafkaesque Resolution of Disputes in Family Law

By: Avanish Kar

Edited By: Allison Rhee and Danielle Spitz

The 1979 classic film Kramer vs. Kramer, starring Academy Award-winning performers Meryl Streep, Dustin Hoffman, and Justin Henry, portrays the struggles of an American couple fighting over custody of their only child, who is wedged in between his parents’ marital issues. While the movie showcases the struggle between two adults and the pain and suffering they cause their child, it also asks a broader and more socially relevant question: is our legal system obstructing justice instead of providing it?

Although the movie was released over 40 years ago, the problems portrayed in the plot still persist in our families and courtrooms. The story centers around Ted Kramer, a New York-based workaholic executive at a top advertising firm who is too busy to pay attention to his family life. This work-life imbalance causes his homemaker wife Joanna emotional turmoil, and his son Ben to be devoid of paternal care and attention. While Ted achieves new heights in his career, his wife’s displeasure increases and he comes home one day to find his wife leaving him and their son. The following few weeks are difficult for Ted and Ben, who face a great deal of trouble balancing Ted’s career, Ben’s schoolwork, daily chores, and the painful loss of the woman of the house. However, as time passes, Ted realizes the importance of Ben in his life and reciprocally, Ben develops an unbreakable bond with his once emotionally distant father. In a turn of events, after being away for 18 months, Joanna is back to regain custody over Ben. Ted, being possessive of his son, refuses to give in to Joanna’s demands and what ensues is a mentally and financially taxing courtroom battle between Ted and Joanna. 

Ted perfectly embodies the problems inherent in our legal system when asked by his lawyer to list the pros and cons of pursuing the case against Joanna for custody of their child. There was no entry in the “pros'' column, while there were many in the “cons” column, which included: “Money,” “No Privacy,” “Work affected” and “No social life.” While these are very valid concerns for any litigant, they draw attention to additional problems with our legal systems that need to be highlighted and addressed. 

The very purpose of legal systems worldwide is to ensure that our dispute resolution processes are easy, accessible and beneficial to all parties whilst maintaining a degree of objectivity and fairness during the entire process. The legal drama between Ted and Joanna in the movie is completely absent of these elements, which make any legal system reliable and credible. 

The most problematic aspect of what was showcased in the movie during the legal proceedings was that there was an adversarial system of dispute resolution between an ex-husband and an ex-wife.The adversarial system has many benefits, especially in criminal trials. One of these is that “the right to confront your accuser” which is enshrined in the 6th Amendment to the Constitution of the United States, is in the best way exercised [1]. However, even the most tenuous of relationships between a husband and wife should ideally not be characterized as one which is adversarial (unless there are criminal charges involved). This is because the focus of the attorneys shifts from arguing on the merits of the case with respect to the law, to engaging in a character assassination of the litigants. 

This was seen in Kramer vs. Kramer quite evidently, especially when Ted’s lawyer informs him that their side has the burden to prove that Joanna was an unfit or cruel mother in order to ensure that he gets custody of Ben. Ted’s lawyer follows through with this idea and engages in a very harsh line of questioning, even going so far as to asking her how many boyfriends she has had in order to extract a confession that she has not been a good mother. This is reciprocated by Joanna’s lawyer, when he tries to allude to the fact that Ted was an inept parent because he failed to protect Ben from an injury which was purely accidental and beyond his control. This type of adversarial questioning only worsens the relations between two already distant individuals and does no good to either side. 

Furthermore, the role of the court in perpetuating gender norms by assigning particular roles to men and women is an example of outdated thinking and arbitrariness, which is aptly dismantled by the movie. The fact that emphasis was placed on ideas like “motherliness”, where women have the exclusive ability to care for their children in certain ways, was refuted by showing the audience that with the right amount of intent and diligence, men can take care of the child like a woman is traditionally expected to. This is very poignantly expressed in the movie. In the beginning of the movie, Ted is unable to make French toast for Ben, but when Ben is ready to go to his mother after she wins the court case, Ted perfectly makes it. This shows us that changes are possible and that the rigid legal system must be reformed to account for the possibility of change. 

Therefore, in light of the above arguments, it can certainly be said that as shown in Kramer vs. Kramer, the litigant, who for the courts is merely a litigant, loses out as a parent regardless of the outcome of the case. This happens when they are subjected to the Kafkaesque injustices that are meted out by the courts which have failed in their primary duty of providing justice in a non-prejudicial manner. The only way to improve this is by making judges rethink their gender biases. 

Recent examples of initiatives in this direction are the international conferences organized by the National Supreme Court of Justice of Mexico where hundreds of judges engaged in a thoughtful discussion of court decisions from across the globe with regard to gender bias [2]. More such initiatives should be encouraged in other jurisdictions which are in desperate need of a gender sensitive judiciary.

NOTES:

1. “Right to Confront Witness.”, Legal Information Institute, Cornell Law School https://www.law.cornell.edu/wex/right_to_confront_witness

2. Vanessa Ruiz, “The Role of Women Judges and a Gender Perspective in Ensuring Judicial Independence and Integrity. (Ruiz 2019)”, January 8, 2019, UNODC https://www.unodc.org/dohadeclaration/en/news/2019/01/the-role-of-women-judges-and-a-gender-perspective-in-ensuring-judicial-independence-and-integrity.html

BIBLIOGRAPHY:

Benton, Robert, dir. 1979. Kramer vs. Kramer.

Ruiz, Vanessa. 2019. “The Role of Women Judges and a Gender Perspective in Ensuring Judicial Independence and Integrity.” UNODC. https://www.unodc.org/dohadeclaration/en/news/2019/01/the-role-of-women-judges-and-a-gender-perspective-in-ensuring-judicial-independence-and-integrity.html.

Legal Information Institute, Cornell Law School. n.d. “Right to Confront Witness.” Legal Information Institute. Accessed September 23, 2021. https://www.law.cornell.edu/wex/right_to_confront_witness.

The FTC’s Fight to Police Big Tech: FTC v. Facebook, Inc.

By: Iris Lin

Edited By: John Perales Jr. and Dheven Unni

On December 9, 2020, the Federal Trade Commission (FTC) sued Facebook for illegal monopolization. According to the FTC, Facebook has been engaging in anticompetitive conduct for years. Such conduct includes the 2012 acquisition of Instagram, the 2014 acquisition of WhatsApp, and the intimidation of competitors. The FTC claims that Facebook’s conduct stifles competition, harms consumers by leaving them with few choices for social networking, and deprives advertisers of the benefits gained from competition. The FTC is seeking a permanent injunction in federal court that could “require divestitures of assets, including Instagram and WhatsApp; prohibit Facebook from imposing anticompetitive conditions on software developers; and require Facebook to seek prior notice and approval for future mergers and acquisitions” [1]. This lawsuit is particularly notable because the FTC is changing its position on deals they approved at the time. When Facebook acquired Instagram and later WhatsApp, the FTC cleared both deals. This new lawsuit, however, sends “a warning to American business that no sale is ever final” [2].

Facebook was formed by Mark Zuckerberg and three other Harvard students in February 2004. It quickly became popular and rose from a small website exclusive to Harvard students to a worldwide platform in 2006. Throughout its lifetime, Facebook has faced multiple legal challenges. Six days after “The Facebook” went live, Zuckerberg and the founders of Facebook faced accusations by Cameron and Tyler Winklevoss and Divya Narendra that they had stolen the idea for the website. Next, Eduardo Saverin, chief financial officer and business manager for Facebook, filed a lawsuit against Facebook after being cut out by Zuckerberg in 2005 [3]. Facebook has also faced multiple privacy allegations, including the 2016 scandal where Facebook was accused of allowing fake Russian accounts to buy ads and spread fake news [4]. Most recently, in 2018, a Facebook hack affected 50 million users. This lawsuit, however, is monumental because by breaking up Facebook it could significantly reduce its power and dominance over the social networking industry.

In the beginning, Zuckerberg was seen as a superstar, a success story. He was a normal college student who created a platform that still defines the way we interact online. Due to these scandals and the increasing power of Facebook, however, this superstar reputation has started to shift more towards one of a villain. Sally Hubbard, director of enforcement strategy for the Open Markets Institute describes how “as companies get to become long-standing, durable monopolies, they start to treat people badly—they start to treat their consumers badly, they start to treat their employees badly, they start to treat other businesses badly. Because that’s what monopolies do” [5]. The FTC has exploited this perception in their lawsuit. It has portrayed Zuckerberg as a villain who seeks to eliminate all competitors and control every aspect of his company. 

Regardless of the outcome of the lawsuit, the negative public portrayal could be harmful to Facebook by impeding its relationship with current and future customers. The FTC has used dramatic language such as “the wrath of Mark” to portray Zuckerberg’s aggression in the technology sector. This language, coupled with damaging emails from Zuckerberg where he states the desire to eliminate competition, could persuade the public to loathe Zuckerberg and Facebook.

The case against Facebook is similar to a 2001 case, United States v. Microsoft Corporation, 253 F.3d 34, as both cases involved monopolies and were built on top officials’ explanations of their own conduct as opposed to just testimonies from workers. The government found memos from executives making predatory statements about eliminating competition, and Microsoft lost the case [6]. Microsoft was found to be liable for monopolization. Although relying on internal emails worked in the case of Microsoft, this strategy is often risky. At times judges have argued that antitrust law is interested in the economic effects of a business’s conduct, not the motives of its executives. Thus, emails from CEOs may work better at influencing the public than at making an economic argument in court. This “intent evidence,” however, can be key in convincing judges when other types of evidence may not be enough to make an antitrust case . In this particular case, Vanderbilt University Professor of Law, Rebecca Allensworth, explains how Zuckerberg’s emails are explicit in describing the desire to quash competition: “The court will find that relevant—and possibly damning” [7].

In response to the lawsuit, Facebook has focused on the legal aspects of the case. Facebook’s general counsel, Jennifer Newstead, issued a statement saying, “People and small businesses don’t choose to use Facebook’s free services and advertising because they have to, they use them because our apps and services deliver the most value”[8]. Facebook has been facing pushback from Washington for years now and has been already preparing for this major lawsuit. Facebook has integrated its apps on a technical level, possibly to frustrate a potential breakup. It has also increased its hiring of lawyers with antitrust litigation experience. Facebook has tried to set a narrative that it welcomes regulation but “that cracking down too hard could risk giving other countries like China a competitive edge in the fast-moving technology sector” [9].

Even if the FTC were to win the suit, the potential impact on consumers is unclear. The FTC complaint asks for Facebook to be forced to sell off WhatsApp and Instagram, but Facebook’s technical integration makes it challenging for new companies to easily adopt its separate apps [10]. Further, even if a breakup is feasible, it may not be ideal because it may not address the problem of competitive harm. If the FTC shows that the issue with the Instagram and WhatsApp deals was an impairment to consumer privacy, a breakup would be unlikely to protect this privacy.

As companies grow and aim to acquire more competitors, fears about one company becoming too powerful become significantly more relevant. The FTC is therefore working to prevent these companies, such as Facebook, from monopolizing their particular industries. The FTC claims that competition will be harmed if Facebook acquires or merges with other companies, which will negatively impact consumers and advertisers. Antitrust cases can be difficult to resolve, however, as the case must be evaluated on economic concerns and company intent. Regardless, the federal court’s will have a strong hand in shaping future consumer interaction with Facebook and will set the stage for a new era of technology centered antitrust cases.

NOTES:

1. “FTC Sues Facebook for Illegal Monopolization.” Federal Trade Commission, December 9, 2020, https://www.ftc.gov/news-events/press-releases/2020/12/ftc-sues-facebook-illegal-monopolization

2. Brian Fung, “Facebook must be broken up, the US government says in a groundbreaking lawsuit.” CNN,10 December 2020, https://www.cnn.com/2020/12/09/tech/facebook-antitrust-lawsuit-ftc-attorney-generals/index.html 

3. Sabrina Barr, “When Did Facebook Start? The Story Behind A Company That Took Over The World.” The Independent, 23 August 2018, https://www.independent.co.uk/life-style/gadgets-and-tech/facebook-when-started-how-mark-zuckerberg-history-harvard-eduardo-saverin-a8505151.html 

4. Christopher McFadden, “A Brief History of Facebook, Its Major Milestones.” Interesting Engineering, 7 July 2020, https://interestingengineering.com/history-of-facebook

5. Craig Timberg and Drew Harwell, “Government’s antitrust case against Facebook seeks a villain in Mark Zuckerberg.” Washington Post, 10 December 2020, https://www.washingtonpost.com/technology/2020/12/10/facebook-lawsuits-zuckerberg-villain/

6. Rebecca Haw Allensworth,  “As regulators close in, Zuck’s long email trail poses an existential threat to Facebook.” Quartz, 23 December 2020, https://qz.com/1949679/why-the-ftcs-anti-facebook-lawsuit-stands-a-chance/ 

7. Allensworth, “As regulators close in.”

8. Fung, “Facebook must be broken up.”

9. Fung, “Facebook must be broken up.”

10. Allensworth, “As regulators close in.”

BIBLIOGRAPHY:

Allensworth, Rebecca Haw, “As regulators close in, Zuck’s long email trail poses an existential threat to Facebook.” Quartz. 23 December 2020. https://qz.com/1949679/why-the-ftcs-anti-facebook-lawsuit-stands-a-chance/ 

Barr, Sabrina. “When Did Facebook Start? The Story Behind A Company That Took Over The World.” The Independent. 23 August 2018. https://www.independent.co.uk/life-style/gadgets-and-tech/facebook-when-started-how-mark-zuckerberg-history-harvard-eduardo-saverin-a8505151.html 

Craig Timberg and Drew Harwell. “Government’s antitrust case against Facebook seeks a villain in Mark Zuckerberg.” Washington Post. 10 December 2020. https://www.washingtonpost.com/technology/2020/12/10/facebook-lawsuits-zuckerberg-villain/

“FTC Sues Facebook for Illegal Monopolization.” Federal Trade Commission. December 9, 2020. https://www.ftc.gov/news-events/press-releases/2020/12/ftc-sues-facebook-illegal-monopolization

Fung, Brian. “Facebook must be broken up, the US government says in a groundbreaking lawsuit.” CNN. 10 December 2020, https://www.cnn.com/2020/12/09/tech/facebook-antitrust-lawsuit-ftc-attorney-generals/index.html 

McFadden, Christopher. “A Brief History of Facebook, Its Major Milestones.” Interesting Engineering. 7 July 2020, https://interestingengineering.com/history-of-facebook

Equal Pay: Bridging the Gender Wage Gap

By: Reese Rosental Saporito

Edited By: Danielle Spitz and Maayan Abouzaglo

The gender wage gap has been prevalent for decades. In the United States, women are paid on average 82 cents for every dollar a man makes for doing the same job.[1] The progression towards equal pay has been slow, and if it continues at this rate, women will still be fighting against the wage gap until 2093.[2] In 1963, Congress passed the Equal Pay Act (EPA), which made it illegal for women to receive less pay than men when performing the same jobs requiring the same skills.[3] However, it is evident that this act has not performed the way it was intended, and these words must be backed by action. This act needs to be enforced by the government through legal protections and holding institutions accountable for upholding Equal Pay legislation.

The wage gap is a systemic gender issue that is rooted in the laws of the United States, and therefore must be reformed through policy. Though created to remedy this issue, the EPA has failed in practice. When the EPA was passed, its purpose was to put “an end to historical wage discrimination against women.”[4] While progress has been made from women earning 56% of men’s salaries in 1963 to 82% today, true equal pay has still not been achieved.[5] Another issue regarding the efficacy of the EPA is that it includes exclusions that are essentially loopholes for employers to pay women less than they do men without being punished by law.[6] An example of an exclusion is merit, for which people who produce “higher quality” work receive higher compensation that is highly subject to bias.[7] These loopholes allow for “justified” and legal gender-based discrimination in wages, therefore invalidating the EPA’s claim to end the historic wage gap for women.

In an attempt to combat this, The House of Representatives reintroduced the Paycheck Fairness Act (PFA) in 2019. This would not only increase the penalty for violations of equal pay, but it also forces corporations to disclose information revealing that any pay inequalities are based on factors other than sex.[8] The Harvard Business Review did a study that showed how the gender wage gap decreases when legislation requiring companies to disclose disparities in pay is present.[9] The issue with the EPA was the lack of resources to enforce the policies, making the legislation inadequate in mending the wage gap.[10]

Congress needs to ameliorate the EPA by getting rid of the exceptions that leave room for discrimination and implementing stronger enforcement of the rules laid out by the act. The EPA can be better enforced through the creation of a governmental branch responsible for continuously obtaining wage reports from companies all over the country, and cross-checking salaries to ensure women are receiving the same pay as men for the same work. The law must be used to challenge both wage discrimination and the inadequacy of the EPA, and legal protections must be in place to vindicate the rights of employees and hold corporations accountable for failing to recognize these rights.[11] To help in this accountability and to eliminate the aforementioned loopholes, the language of the act needs to be rectified to make it clear that wage differences among genders are truly based on factors other than sex, such as the presence of a master’s degree or strong recommendation letters.[12] In a world where money is the root of many problems, it is time that all people are paid equally for the work they complete, so that they can better their lives and the lives of those they take care of. Equal pay for women not only empowers young women to pursue their dreams in not traditionally female-dominated fields, while knowing that they will receive equal financial treatment. It will help push families out from below the poverty line and lead to an overall higher quality of living. Therefore, immediate action is utterly necessary to truly accomplish what the Equal Pay Act initially set out to achieve. 

NOTES:

1. AAUW:  The Simple Truth about the Pay Gap

2. AAUW

3. NCSL: The Current State of Equal Pay Laws

4. Why the Equal Pay Act and Laws Which Prohibit Salary Inquiries of Job Applicants Can Not Adequately Address Gender-Based Pay Inequity

5. EPA Not Adequate

6. EPA Not Adequate

7. EPA Not Adequate

8. CNBC: House passes new bill aimed at closing the gender pay gap

9. CNBC 

10. ACLU Paycheck Fairness Act

11. Rhetoric vs. Reality: Making Real Progress on Equal Pay

12. Rhetoric vs. Reality

BIBLIOGRAPHY:

Bleiweis, Jocelyn Frye and Robin. “Rhetoric vs. Reality: Making Real Progress on Equal Pay.” Center for American Progress. Accessed January 31, 2021. https://www.americanprogress.org/issues/women/reports/2019/03/26/467778/rhetoric-vs-reality-making-real-progress-equal-pay/. 

“Equal Pay for Equal Work: Pass the Paycheck Fairness Act.” American Civil Liberties Union, April 4, 2013. https://www.aclu.org/other/equal-pay-equal-work-pass-paycheck-fairness-act. 

Katherine McAnallen, Kathy Brangoccio. The Current State of Equal Pay Laws. Accessed January 31, 2021. https://www.ncsl.org/research/labor-and-employment/the-current-state-of-equal-pay-laws.aspx. 

Kerenzulli. “House Passes New Bill Aimed at Closing the Gender Pay Gap.” CNBC. CNBC, April 21, 2020. https://www.cnbc.com/2019/03/28/house-passes-new-bill-aimed-at-closing-the-gender-pay-gap.html. 

Mello, Jeffrey A. “Why the Equal Pay Act and Laws Which Prohibit Salary Inquiries of Job Applicants Can Not Adequately Address Gender-Based Pay Inequity - Jeffrey A. Mello, 2019.” SAGE Journals. Accessed January 31, 2021. https://journals.sagepub.com/doi/10.1177/2158244019869106. 

“The Simple Truth about the Pay Gap.” AAUW, December 8, 2020. https://www.aauw.org/resources/research/simple-truth/.