Tangle - The independent state legislature theory.
Episode Date: December 8, 2022We're covering the independent state legislature theory, and the arguments around it that happened before the Supreme Court on Wednesday. Plus, a question about Elon Musk and free speech.Read the stor...y about how the Pinckney Plan became a key element in this case here.You can read today's podcast here, today’s “Under the Radar” story here, and today’s “Have a nice day” story here.You can subscribe to Tangle by clicking here or drop something in our tip jar by clicking here.Our podcast is written by Isaac Saul and produced by Trevor Eichhorn. Music for the podcast was produced by Diet 75.Our newsletter is edited by Bailey Saul, Sean Brady, Ari Weitzman, and produced in conjunction with Tangle’s social media manager Magdalena Bokowa, who also created our logo.--- Send in a voice message: https://podcasters.spotify.com/pod/show/tanglenews/message Hosted on Acast. See acast.com/privacy for more information.
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From executive producer Isaac Saul, this is Tangle.
Good morning, good afternoon, and good evening, and welcome to the Tangle Podcast,
the place we get views from across the political spectrum. Some independent thinking without all that hysterical nonsense you find everywhere else. I'm your host, Isaac Saul, and on today's episode, we're going to be talking about
the independent state legislature theory, more specifically, Moore v. Harper, which
is the case that is currently in front of the Supreme Court.
Before we jump in, though, first of all, some breaking news and a promotion for tomorrow.
Brittany Griner, the WNBA star who was held for months in a Russian prison,
was released on Thursday in a one-for-one prisoner swap for international arms dealer
Victor Bout. That is our quick hit number one. It's also a preview of tomorrow because given
the importance of this story and the fact that it just happened about an hour before I recorded
this, I am going to write about this hour before I recorded this. I am going
to write about this in tomorrow's Friday edition. I'm going to push the thing we had teed up to
publish tomorrow. So as always, if you want to receive that edition, you need to go to
readtangle.com slash membership. Now, I know many of you speaking of this are exclusively podcast
listeners. So I did want to give you a heads up
that Trevor and I have been exploring the idea of a paid podcast version, basically getting our
Friday editions into podcast form and paywalling them and maybe finding a way to link up our
current membership with the podcast membership so people who are
members already can get access to the paid podcast. We're working on it. We're making
progress. I think so far, my understanding is that we're going to be able to do it.
And I hope to have that for you fairly soon. So I know many of you have asked for that.
Please stick with us. And yeah, we should have some Friday edition podcast down the road. I'm hopeful. Fingers crossed.
All right. So with that out of the way, we'll jump in with our other four quick hits for the day.
Number two, the state of Indiana is suing TikTok, alleging that the platform is deceiving consumers about its content and data security. Number three, in Peru, Congress swore in Vice President
Dina Baluarte as its new president after the impeachment and arrest of Pedro Castillo.
Baluarte becomes the first female leader of Peru. Number four, on the heels of a Senate
victory in Georgia, Democratic Majority Leader Chuck Schumer will be formally voted in for
another two years as Senate leader. Number five, former Theranos COO Ramesh Sunny Balwani was
sentenced to 13 years in prison after being convicted of defrauding investors.
Ex-CEO Elizabeth Holmes
was sentenced to 11 years. The Supreme Court is hearing arguments today about a fringe legal
theory that could give Republican legislatures the right to overturn state election results.
It centers around a legal idea called independent state legislature theory,
and it is gaining ground among conservative Republicans, most notably Trump supporters.
It's an attack on our system of checks and balances, and it would create chaos in our
elections. Our democracy works best when power is shared, not abused.
On Wednesday, the Supreme Court heard oral arguments in a test of the so-called Independent
State Legislature Theory, or ISL, which is the idea that the Constitution gives state
legislatures unfettered authority to regulate federal elections, with little to no oversight
from state courts.
According to SCOTUSblog.com, based on how the Supreme Court rules, the case could upend
federal elections nationwide by eliminating virtually all oversight of those elections by
state courts. The case came before the Supreme Court from North Carolina, where Republicans had
created a gerrymandered map that was expected to produce 10 GOP victories in the state's 14
House districts. The state Supreme Court, with a 4-3 liberal majority,
voted along ideological lines to invalidate the map, citing free elections and equal protection
provisions of the state constitution. After the map was thrown out, the trial court appointed
three experts to redraw and implement a new map, which led to Republicans and Democrats
splitting the district seven apiece in the 2022 midterms. North Carolina Republicans
challenged that map, asking the Supreme Court to put it on hold and implement the map they had
drawn. The court declined but agreed to hear oral arguments in the case. In today's episode,
we're going to be referring to Timothy Moore and the legislators, the North Carolina Republicans
advancing the independent state legislature theory, and Rebecca Harper, North Carolina and
the state. Harper is a, North Carolina and the state.
Harper is a North Carolina voter, and the state is led by a Democratic governor and attorney general who are challenging the Republicans' advancement of ISL. The legislators advancing the independent
state legislature theory point to two clauses in the Constitution. The first, Article I's
Elections Clause, says the time, place, and manner of
congressional elections shall be prescribed in each state by the legislature thereof. The second,
Article II's Electors Clause, says states can appoint presidential electors for the electoral
college in such a manner as the legislature thereof may direct. Using these two clauses,
proponents of the theory argue that under the plain text of the Constitution, state courts are now authorized to supervise how legislatures run elections for both Congress and
the presidency. If the framers had wanted state courts or other entities to play a role,
they would have given power to each state, but they do not. They also note that it was very rare
for state courts to strike down congressional maps in the first few decades of the country's
founding. Meanwhile,
opponents of the theory say the clause was never understood, even at the time of the founding,
to hand unchecked authority to state legislatures. North Carolina argues that the legislature has
never claimed the power to prescribe federal election regulations that violate the state's
constitution and are immune from judicial review. Challengers of the original gerrymandered map say
it was universally understood that the state legislature was created by the state constitution, and
therefore the legislature's laws must comply with that constitution and are subject to judicial
review by the state's courts. North Carolina argues that the state Supreme Court has reinforced this
idea in numerous cases over the last century, repeatedly making it clear that state courts
have the authority
to consider challenges to election law.
The state says it is inconceivable that anyone could have misunderstood
the U.S. Constitution to bar state courts from enforcing the state constitution
or that it intended to allow state legislatures to run elections
with no oversight by state courts.
On Wednesday, during oral arguments,
justices seemed skeptical of Moore's
independent state legislature theory. While a few conservative justices seemed receptive to the
theory, it was not clear there was a majority to endorse it even on narrower grounds that would
preserve a role for state courts to enforce state laws. Because the Supreme Court ruled in 2019 that
federal courts can no longer hear partisan gerrymandering cases, state courts retained
that power to hear those challenges. If the court were to endorse the theory, state legislatures would
have near total control of drawing congressional maps. Today, we're going to take a look at some
arguments from the left is saying.
Many on the left frame this case as an existential threat to democracy and how our elections are run.
Some argue that the conservative justices seem quite skeptical of the theory and oral arguments.
Others suggest the Supreme Court endorsing ISL could upend the 2024 election.
In Vox, Ian Millhiser said it is potentially the biggest threat to free and fair elections
in the United States to reach the Supreme Court in my lifetime.
The argument for the ISLD is deceptively simple.
It can be summarized in three sentences.
The Constitution says that the
rules governing federal elections shall be made by each state's legislature. A governor, a state
supreme court, or a state constitution is not the legislature. Checkmate, libs. The problem with this
argument is that, at least at the time when the Constitution was drafted, and popularly elected
legislative bodies like the U.S. Congress were a relatively new innovation. The word legislature did not mean the elected body of men and women who make up the House and Senate.
It meant, as the Supreme Court explained in Arizona State Legislature,
the power that makes laws. And that power can be shared, Millhiser wrote.
Just as the U.S. president plays a role in making federal laws through their veto power,
so too can states allocate that legislative power among their various branches of government. Davis confirmed that this lawmaking
power may be given in part to the people of the state as a whole through a referendum process,
he added. Smiley confirmed that a portion of the legislative power may be wielded by a state
governor through his or her veto power. Arizona state legislature confirmed that a portion of
this power may be given to a bipartisan commission. Indeed, if you doubt this definition of the word legislature,
I encourage you to read the Moore petitioner's brief. Specifically, I encourage you to read
page 14 of their brief, where they quote four dictionary definitions of the word legislature.
Only one of those four definitions from a dictionary published four decades after the
Constitution was drafted even plausibly could be read as support for the ISLD. In the New Republic, Matt Ford said the
independent state legislature theory had a rough day in court. At oral arguments on Wednesday,
Justice Amy Coney Barrett appeared deeply skeptical of the North Carolina Republicans'
approach to the independent state legislature theory, especially when it came to practical
applications for the court. At one point, the justices questioned David Thompson, who argued on behalf
of the state lawmakers, about a 1932 case where the Supreme Court held that a governor's veto
didn't violate the elections clause, which runs counter to the theory's reading of that clause.
Thompson tried to dismiss the gubernatorial veto as a mere procedural hurdle, which did not appear to persuade Barrett. The court's three liberal justices were unsurprisingly hostile toward the
theory, but even some of the conservative justices appeared uneasy with the theory as articulated by
the state lawmakers. Kavanaugh remarked at one point that their version seems to go further than
the Rehnquist's in Bush v. Gore, referring to a concurring opinion by then-Chief Justice William
Rehnquist during the 2000 election dispute, Ford said. As a concurring opinion, Rehnquist's opinion is not
binding precedent on the courts, but it has served as a touchstone of legitimacy for the theory over
the last two decades. Kavanaugh is unusually familiar with that case because he worked on
George W. Bush's legal team at the time. So did Roberts, whose questions focused on narrower ways
to resolve the case and may have signaled unease with the maximalist approach. Adam Pritzker and
Lauren Popper Ellis said the case could help election deniers seize the White House in 2024.
If taken to its radical extreme, this reading of the Constitution would give state lawmakers,
not governors or state courts, authority over not only how the maps get drawn,
but also over all the rules about how federal elections are administered, how the votes get
counted, and even which candidate wins, they wrote. If endorsed by the Supreme Court, the
independent state legislature doctrine could open the door to giving state legislators the power to
decide, for example, which presidential candidate will receive their state's electoral college votes
regardless of how the people actually voted. In practice, we could see a rogue legislature,
displeased with their state's election results, spur manufactured chaos and delays,
and invoke the ISL as justification for them to step in and unilaterally send its own slate of
electors to participate in the electoral college vote for president, with no clear path for the
state's governor or courts
to check their actions, they said. Though the elections clause hasn't been understood this way
in the past, such a reinterpretation isn't all that hypothetical. In the aftermath of the 2020
election, former President Donald Trump used ISL as the centerpiece of his efforts to convince
Republican lawmakers in key states to overturn the will of their voters and declare him the winner.
It didn't work then, but if ISL gets the stamp of approval from the Supreme Court's current right-wing supermajority,
it might work in 2024.
Alright, that is it for the leftist saying, which brings us to what the right is saying.
The right is divided, with some arguing the court should embrace the plain text of the Constitution
and others saying that ISL has no legitimacy. Some say endorsing ISL could bring order to
elections and allow the states to fully exercise their power. Others say the theory has no support
in history or legal precedent. The Wall Street Journal editorial board says the justices should endorse the theory and
bring clarity before the 2024 elections.
The dispute in Moore v. Harper involves a House redistricting plan passed in 2021 by
the North Carolina legislature, the board said.
That map was invalidated by the state Supreme Court, which said it was a partisan gerrymander
and therefore prohibited under the state Supreme Court, which said it was a partisan gerrymander and therefore prohibited under the state constitution. The North Carolina Constitution says nary a word about partisan
gerrymandering. The state justices instead cited clauses that guarantee free elections,
a right to assemble, freedom of speech, and equal protection of the laws. The Pennsylvania
Supreme Court did a similar trick in 2020 when it extended a deadline for mail ballots,
citing a promise of free and equal
elections. But what's unfree about a deadline? And if state judges can rewrite the election code like
this, where does it end? We have great respect for federalism and the right of states to write
their own constitutions, which is why Moore v. Harper isn't an easy case, they said. But the
Elections Clause is an exception because its delegation of federal authority to state legislatures
is explicit. This is what Chief Justice William Rehnquist, joined by Justices Antonin Scalia
and Clarence Thomas, was getting at when he wrote in a 2000 concurrence to Bush v. Gore
that the Constitution limits the power of state judges over federal elections.
The panicked reaction to Moore v. Harper is unconvincing. A legislature is the most democratic
branch of government.
How is it vital for democracy to let a state court rewrite a voting law passed by elected legislators? No matter the outcome in this state, there are federal guardrails because
the state election laws must follow the U.S. Constitution and acts of Congress.
In The Federalist, John Yoo and Robert Delahunty argue that the writing of the Constitution is
clear. As critics of the North Carolina legislature repeat in their arguments and more, apparently,
the Constitution's use of the word legislature means the people of a state, who are then free
to delegate their power to draw districts anywhere they please, they said. They would have to concede
that a state could transfer the power to draw districts not just from the legislature to an
independent commission, and not even just to a court, but even to a single individual who might or might not be a government official. The problem
with allowing a state to allow anybody to exercise authority over redistricting is that it reads the
word legislature out of the constitution. If Article I, Section 4 had declared that the time,
places, and manner of holding elections for Congress were to be governed by the state rather
than the legislature of the state between states and state legislatures,
governors, and even courts. In some places, such as defending a state from invasion or sudden attack,
a state itself bears responsibility. But only state
legislatures can call for a constitutional convention, ratify proposed amendments,
consent to their state's division, and declare the manner of selecting presidential electors.
Before the 17th Amendment, they could also appoint a state's U.S. senators.
Based on Charles Yu's award-winning book, Interior Chinatown follows the story of Willis Wu,
a background character trapped in a police procedural who dreams about a world beyond
Chinatown. When he inadvertently becomes a witness to a crime, Willis begins to unravel
a criminal web, his family's buried history, and what it feels like to be in the spotlight.
Interior Chinatown is streaming November 19th, only on Disney+.
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Some conservatives criticized the idea. In The Atlantic, former federal judge Michael Ludig said
there is absolutely nothing
to support the independent state legislature theory. That as many as six justices on the
Supreme Court have flirted with the independent state legislature theory over the past 20 years
is baffling. There is literally no support in the Constitution, the pre-ratification debates,
or the history from our time of our nation's founding or the Constitution's framing for a
theory of an independent state legislature that would foreclose state judicial review
of state legislators' redistricting decisions. Indeed, there is overwhelming evidence that the
Constitution contemplates and provides for such judicial review, he said. Proponents of the
independent state legislature theory argue that because the Elections Clause does not assign this
legislative role to the state governors and courts, the burden is on those who argue against
the theory to come forward with compelling evidence that the framers intended state courts
to review state legislative election laws. But that's to reverse the burden of proof. Because
there is no evidence support at all for the theory, the burden instead is on those who argue for the
theory to come
forward with compelling evidence from the text, structure, or design of the Constitution,
or from the history at the time of the framing or founding that confirms that the Constitution
conferred on the state legislatures, but that's to reverse the burden of proof, because there's
no evidence support at all for the theory. The burden instead is on those who argue for the
theory to come forward
with compelling evidence from the text, structure, or design of the Constitution, or from the history
at the time of the framing or founding that confirms that the Constitution conferred on the
state legislature's judicially unreviewable authority to redraw congressional districts,
Ludig said. The proponents of the theory have not carried this heavy burden to date,
and they cannot possibly carry this The proponents of the theory have not carried this heavy burden to date,
and they cannot possibly carry this burden in more of the heartburn.
All right, that is it for the left and the right are saying, which brings us to my take.
In the last few months, we've covered a number of Supreme Court cases.
Yesterday, we covered the same-sex wedding case from Colorado, where I argued that the rights hypothetical case was a winner, but the actual case should be thrown out since
there was no live conflict.
Last week, we covered the Indian Child Welfare Act, which I said was the hardest Supreme
Court case I've ever written about and essentially punted on my own opinion,
but rooted for a narrow ruling in the right's favor. In early November, we covered race-conscious admissions, and I argued that while I wasn't a fan of race-conscious admissions, the case wouldn't
fix universities no matter how it went, and the left had precedent and the law on their side.
I recap all of these in hopes of reminding you that while I'm generally all over the place on
our daily debates, I'm especially torn when it comes to Supreme Court litigation with its high
degree of nuanced specificity and strong competing arguments for each side. And I do that hoping that
what I'm about to say comes with a higher degree of credibility. The independent state legislator
theory is bonkers. It isn't just totally divorced from
the historical record, centuries of precedent, and common sense. It is an intentional redefinition
of language that has been clear to every generation of Americans before us all the
way back to the founders. The theory supports a transparently partisan end using the means
of redefining an election system that would, in the most plausible scenarios,
cause a high degree of chaos, make our elections much more difficult to administer, and take a
tremendous amount of power away from voters. It would make us less democratic and less able to
fix everything about our election system that is already poisonous and broken. The obvious
common sense part of this is that nobody in their right minds really believes
that a state court has no jurisdiction over the state legislature's lawmaking in any manner,
including elections.
The state Supreme Court of North Carolina ruled that North Carolina's map violated the
state constitution because it quite obviously did.
And they prevented a highly gerrymandered map that is part of the scourge of gerrymandering
Democrats and Republicans are participating in across the country. Without that check in place, we'd have more and worse
gerrymandering than we already do. This outcome of an independent state legislature is obvious.
Legislatures have a strong incentive to create election laws that benefit them politically.
Our entire system is based on a premise of checks and balances, so it makes sense that we would not
hand over election lawmaking exclusively to the legislature, who could and already do than make
laws that benefit their odds of staying in power. That is why state courts do and should be able to
intervene. The historical element of this is almost as clear. The petitioner's main argument
involves a historical document called the Pickney Plan, which purportedly refers to each state and its role in administering elections,
but note that this clause was changed in the final draft of the Constitution.
This, they argue, is proof that the framers once considered involving the state in administering
elections, but ultimately decided to specifically and exclusively give that power entirely to the legislature.
There's just one problem. The Pinckney Plan is fake history. I know that sounds hyperbolic,
but I really don't know how else to say it accurately. Historians from across the political spectrum describe it as an entirely discredited document that was put in the historical record
not at the time of the Constitution, but some 30 years later.
The story of how a fake document became a key element to a case that is now being lent credence in front of the Supreme Court is a frustrating story, but if you have time, there is a link to
read about it in today's episode description. All you really need to know is that it's a product
of one man wanting to take credit for the Constitution's ideas, and that the framers
had a deep distrust of state legislatures explicitly voted to limit their power over state elections and never, ever would have
supported the idea of allowing them to act without judicial review. The potential consequences of all
of this is frightening. Many of the commentators you just heard have already explained how embracing
such a theory would allow partisan legislators to undermine our elections even more
than they already have with gerrymandered or illegal maps which could only be restrained by
federal courts. This alone would create chaos, as it would mean the Supreme Court and federal courts
would then be the venues for election challenges specific to individual states. And that's not even
the worst practical implication. As North Carolina's lawyers argued, advancing this argument would mean state
constitutions could not impose limits on laws that govern federal elections. In practice, this means
the state could strike down a state law, but not a federal one. What happens if a state court
invalidates a law for state elections, but not federal elections? States would have to run two
separate elections with two separate sets of rules.
No longer would you go to vote for your senator, a federal office, your governor, a state office,
and city council member, your local office, all on the same ballot.
Even more infuriating is that this case shouldn't even matter in the first place since North Carolina's legislator has already clarified that state courts have this power.
Even if you took the ISL hook, line, and sinker,
which you should not, North Carolina's General Assembly passed a law explicitly authorizing some
state courts to hear redistricting lawsuits. In other words, even if the court were to accept
the ISL argument, Morris should still lose the case because the state court was simply exercising
the power the state legislator already gave them. The good news is that Moore's challenge is likely to fail. While I find it deeply concerning that there are conservative
justices on this court, even considering this argument, there is plenty of dissent. Leaders of
the conservative federalist society have lambasted the idea. Benjamin Ginsburg, a longtime Republican
idol and one of the top Republican election lawyers in the country, said the theory would
create untenable legal uncertainty around elections. Judge Ludig, cited above, is another conservative legal giant
who has totally discredited this lawsuit. And even better, the court itself looks unlikely to
embrace any broad version of the independent state legislature theory. That's all great news,
not just for North Carolinians, voters, and democracy, but for a court that is in desperate
need of restoring its credibility with the American public.
All right, that is it for my take, which brings us to your questions answered.
This one is from Nick in Edmond, Oklahoma.
Nick said, I wanted to get your thoughts on Elon Musk and his relationship with free speech.
I can't seem to gauge where he stands on the issue. On one hand, he exited Jim Baker from
Twitter for his possible role in suppression of information, important to the public dialogue,
whatever that means. On the other hand, he has refused to reinstate Alex Jones' Twitter account,
saying he has no mercy for anyone who would use the deaths of children for gain, politics, or fame.
Not saying I agree or disagree with either of these decisions, but it appears inconsistent.
Do you have a gauge on Musk's true relationship with free speech?
Is what is deemed important to the public dialogue completely up to his own personal
opinions and feelings?
So look, Nick, I think that content moderation is extremely difficult and should not be conflated
with free speech.
To me, subscribing to free speech principles is the idea that people are permitted to express themselves absent of coercion or limitations from the government.
Free speech also means everyone gets to participate in the public square, people are free not to speak, and people are free to live absent of certain kinds of harassment and abuse that prevent them from participating in speech. Two of my favorite interviews about free speech I've ever done are
with Grace Lavery and Jacob Amchangma. These are chats that are published in our podcast archives.
I'll get Trevor to link them in today's episode description. And in these conversations, we talk
about the history of free speech, but also about the difference between government regulating speech
and private platforms regulating speech. To me, Musk is good for Twitter because he adds
ideological diversity to an overwhelmingly liberal institution. But there are thousands
of other thought leaders I'd point to that embody free speech worldviews much better than he does.
The inconsistencies you view are real. I think he is much more selfishly motivated than
ideologically driven.
Rather than follow a Free Speech North star, he's on a path to make previous Twitter ownership look
bad, hyper-woke progressives upset, and criticisms of himself disappear. I mean, he's the guy who
promised he'd bring comedy back to Twitter, then weeks later impose permanent bans on satirical
accounts on the platform. I like Musk, for a lot of reasons,
and I'm still holding out hope that my original prediction that he would be good for Twitter
long-term holds up, though things are looking pretty chaotic and broken right now. But when
I think of people who embody consistent free speech ethics, he is not one of them.
Alright, that is it for your questions answered, which brings us to our under the radar section.
Iran's has carried out the first known execution of a prisoner arrested during the protests that
have swept across the country over the last few months. The protester was identified as
Moshe Shikari and was accused of attacking a paramilitary guard with a knife. He was also
accused of blocking a thoroughfare in Iran's capital and disturbing public order. The execution marks an escalation in the Iranian regime's
crackdown on the protest movement, which started after the death of Masa Amini at the hands of the
state's so-called Morality Police. The execution comes as some state officials have said they will
bring an end to the Morality Police, whose overly strict enforcement of laws on women helped spark
the protests in the first place. The Washington Post has a story and there's a
link to it in today's episode description. All right, next up is our numbers section.
The number of Tangle readers who submitted their names to be interviewed in our forthcoming podcast
series was 980. The number of those readers who
will be chosen for the series is five. The number of votes Raphael Warnock defeated Herschel Walker
by among 3.5 million voters, according to the latest tallies, is 96,613. The number of days
until a partial government shutdown unless Democrats and Republicans agree to a new deal
to fund the government is nine. The amount of money both parties have already agreed to spend on the defense budget in the next year
is $858 billion. The increase in defense spending that budget represents is 10%.
All right, and last but not least, your have a nice day section. How about a little unanimous bill voting in the Senate?
The U.S. Senate has unanimously passed a bill that will restrict the private ownership of
big cats like lions and tigers.
The Big Cat Public Safety Act will stop people from keeping the animals as pets and prevent
them from being exposed to public petting and photo opportunities, BBC News reports.
The efforts to curb such practices came on the heels of the Netflix special Tiger King, in hopes to address the estimated 7,000
tigers living in the U.S. in zoos or private homes. If President Biden signs the bill, ownership of
lions, tigers, leopards, and other big cat species will be limited to wildlife sanctuaries, universities,
and certified zoos. BBC News has the story, and there's a link to it in today's episode description.
All right, everybody, that is it for our podcast today.
Like I mentioned at the top, we're going to be back here,
at least in your inbox tomorrow, with a special edition on Brittany Griner.
If you want to get that edition, you need to be a subscriber, a Tangle member.
Go to readtangle.com slash membership to do that.
We'll be right back here on Monday either way, and we'll see Bailey Saul. Shout out to our interns, Audrey Moorhead and Watkins Kelly,
and our social media manager, Magdalena Bokova,
who designed our logo.
Music for the podcast was produced by Diet75.
For more from Tangle, subscribe to our newsletter
or check out our website at www.readtangle.com. We'll see you next time. It was the season of chaos and all through the house, not one person was stressing.
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Based on Charles Yu's award-winning book, Interior Chinatown follows the story of Willis Wu,
a background character trapped in a police procedural who dreams about a world beyond Chinatown. When he inadvertently becomes a witness to a crime, Willis begins to unravel
a criminal web, his family's buried history, and what it feels like to be in the spotlight.
Interior Chinatown is streaming November 19th, only on Disney+.
The flu remains a serious disease. Last season, over 102,000 influenza cases have been reported
across Canada, which is nearly double the historic average of 52,000 influenza cases have been reported across Canada,
which is nearly double the historic average of 52,000 cases. What can you do this flu season?
Talk to your pharmacist or doctor about getting a flu shot. Consider FluCellVax Quad and help
protect yourself from the flu. It's the first cell-based flu vaccine authorized in Canada for
ages six months and older, and it may be available for free in your province. Side effects and
allergic reactions can occur, and 100% protection is not guaranteed.
Learn more at flucellvax.ca.