Julia Tétrault-Provencher welcomes Kerri Froc from the National Association of Women and the Law to discuss Abortion in Canada in the wake of the U.S. Supreme Court's reversal of Roe v Wade.
The Every Lawyer podcast takes a look at Abortion Rights and Restrictions in Canada and how the right to abortion is or isn’t protected by the Canadian constitution. We get a refresher course on Roe v Wade and take a closer look at the SCOTUS decision reversing it. We find out about how the right to choose is already adequately protected in Canada and why any further legislation on the matter could do more harm than good. We also get some sound advice on how to approach this emotionally laden topic with friends, family and colleagues who have contradicting viewpoints.
No Legislation: What we really need to do in Canada to improve abortion access | National Association of Women and the Law (nawl.ca)
Abortion in Canada
[Start of recorded material 00:00:00]
Interviewer: So this is Kerri Froc from the National Association of Women and the Law, chair of the steering committee and also a member of the Reproductive Rights Committee for the feminist law reform of NAWL. So hi Kerry, thank you very much for being here with us today. How are you?
Respondent: Hi Julia. Nice to be here.
Interviewer: Thank you. So just for our listeners I'm also with Kerry on the NAWL that's why I know her pretty well. And also I'm the chair of the Reproductive Rights Committee so I'm very glad to have you here at this podcast to talk about this very quiet I would say frustrating decision that we had last Friday. So the decision from this [unintelligible 00:00:43] Supreme Court of the United States that it was reversing Roe versus Wade. So today the Every Lawyer podcast we take a look at the abortion rights and restrictions in Canada, and how the right to abortion is or is not protected by the Canadian Constitution.
Announcer: This is the Every Lawyer, presented by the Canadian Bar Association.
Interviewer: So before we jump into the Canadian case and we talk about the situation in Canada, could you please give us a quick refresh course on Roe versus Wade, and please walk us through the US Supreme Court's arguments for reversing it.
Respondent: Sure. So, I won't talk a whole lot about Roe versus Wade because it's old news now, almost literally. But it struck down abortion restrictions in Texas using an anonymous plaintive Jane Roe, and the Supreme Court in the 1973 Roe decision developed a framework for states to regulate abortion. And that was based on the different trimesters.
In a subsequent case called Casey it revised that framework and essentially said that we're doing away with these kind of more detailed rules. We're just going to say that states can't put undue – I think they used the words undue impediments or barriers in front of women that are seeking abortion. Now the Dobbs decision is the most recent one, and I believe that one was on very drastic abortion restrictions in Mississippi.
So Justice Alito wrote the decision. We got a sneak peak of it last – at the beginning of May this year, and really the draft doesn't really contain any surprises from – or the final version doesn't contain any surprises from the draft version. It pretty much follows lock-step with that opinion. We just know the breakdown now. So Alito was joined by four Roberts – Justice Roberts concurred in the result and there was three dissenters. So I'm going to focus on Justice Alito's opinion. And you know there is some very detailed explanations given based on American law as to on what basis can you overturn precedent. I don't really think that most lands would be super interested in that. So [what? 00:03:44] I'm going to focus on is constitutional interpretation. And you know, I'm kind of projecting here because that's what I'm interested so I'm like, well certainly everyone else has to be interested in that too. So.
So I will do a little bit on my – you know, what I took from that. And there was a few things that I took from that. The first main argument was a textual one that Alito was making saying that, well first of all, right to abortion can't be found in the text of the Constitution, therefore, in order for it to be inferred under the right to liberty in the 14th amendment, which subsequent cases have kind of folded in the right to privacy as part of that, it has to be, quote unquote, equally rooted in the nation's history and really part of the foundation of liberty.
So essentially the court goes back, the majority goes back to the 13th century to show how it was criminalized under the common-law, and then goes to 1868, the time that the 14th amendment was made to talk about what legislative restrictions were on abortion at that time. It gives, you know – I haven't delved into a huge amount of detail on that, but that part of the judgement is particularly controversial because many historians are saying that in fact abortion was as American as apple pie at that time. And indeed from what I know of the Canadian history, it's very, very similar in terms of women having access to abortive [unintelligible 00:05:39] and it being kind of contemplated or considered at that time as just an ordinary part of regulation of women's menstrual period. So it wasn't until the beginning of the 20th century that that really became controversial.
But in any event, the court says that you have to kind of find it either in you know, the early 13th, 14th, 16th century or at the time of 1868, and guess what? There is no right to abortion that was recognized in that part of history, therefore we can't recognize it as part of the history in 2022 in the United States today. And the court distinguishes a number of cases that were decided under liberty and privacy that you've probably heard about, even Canadians, Lawrence versus Texas. Obergefell, Griswold, those cases are dealing with essentially gay sexual acts, sodomy, same sex marriage and contraception, and laws restricting that and saying, you know, you need not worry about that, people that are reading, because those are totally different issues because we're dealing with foetal life here and this whole moral question, therefore, you know, that's – abortion is way, way different than those things. It kind of begs the question though, because things like those cases were seen as questions of morality rather than human rights in times past. So, in any event that's its rationale.
The second thing that it says is, well, let's go from liberty to equal protection, what Canadians would know as our equality rights. And Alito says that abortion [isn't? 00:07:45] sex-based classification, therefore it receives the lowest level of scrutiny. If you think that this sounds a lot like Bliss versus Canada, and the idea that pregnancy discrimination isn't sex discrimination but discrimination against pregnant people you'd be right. Because that strain of rationale is, you know, alive and well in Canadian – or American Constitutional law.
So third point is that the court says this is really a potential question, the court is overstepping, separation of powers, and it calls Roe versus Wade an exercise of raw judicial power. And really these are questions that are best left to the states to decide.
And lastly, and I'm going to – you know, I said before I'm going to touch – I'm not going to touch the issue of the rationale under American law for overturning precedent but I will say one thing because it just particularly annoyed me, there's a strain of doctrine in the United States that talks about detrimental reliance. People that have organized their lives around judicial precedent and what is it going to do if we upheave the precedent. And the court there said that, well, it's hard for anyone, and in particular a court, to assess the effect of abortion rights on society and in particular the lives of women. And so basically, we don't know what impact it's going to have on women not to have control over their own bodies. And that was particularly outraging for me, and I wrote in an op-ed, you know, has he actually talked to any women? Because it seems self-evident to anyone that has the capacity to get pregnant, and indeed even people that once possessed the capacity to get pregnant, what impact that would have to not have that autonomy anymore.
So that's my little Cole's Notes version on Dobbs. So you know, I'm not a US Constitutional scholar per se, but there's lots that I could pick apart from the perspective of just good constitutional interpretation. I often categorize myself as an originalist, a feminist originalist, and this is – you know, if this was an attempt to be originalist they failed miserably. It's a really sloppy decision as far as how one uses history to interpret constitutional interpretation. But that being said, I think you have many more questions that you want to talk to me about so I'll leave it at that.
Interviewer: Oh no [unintelligible 00:10:51] thank you very much. I mean I do have a lot of questions even just from what you said, actually. Even adding up to the ones I already have. But actually just going back to what you said about Justice Alito saying that nothing in this opinion should be understood to cast doubt on precedents that do not concern abortion, but then you read in his concurring opinion Justice Thomas saying actually the legal rationale could be applied to overturn other major cases including, for instance, those that legalize gay marriage or barred the criminalization of consensual homosexual conduct.
So I mean what should be expect from this? Does it happen often that concurring opinion just say exactly the opposite from the main opinion or – yeah.
Respondent: Well, it's – I think what Justice Thomas's opinion is doing is kind of pulling open the curtain and letting us look at what the more conservative members of the bench have in mind. I mean people like Kavanaugh gave some assurances to some senators that they wouldn't be overturning Roe versus Wade and then they turned around and did exactly that. So, I think we – I take more stock in what Thomas says versus Alito. I don't know if they would dare touch these other aspects. It seems like oftentimes there's more tolerance for infringing on women's rights versus the rights of, for instance, Black Americans or you know, at this particular point in history, members of the LGBTQ community have done a fine job at advancing their rights.
So we'll have to see whether or not they push the envelope. But it definitely is a risk because if you think about the rationale used in Dobbs about you know, if you want to find a right recognized you have to find it firmly entrenched in the nation's history. If it's not explicitly set out, well, same sex marriage, contraception, you'd be hard pressed to find a lot of evidence, not only that it was being practiced but people regarded it as a right.
You know, I do want to comment a little bit on what is going to be the American landscape because I think all is not lost there because the Americans have a really interesting structure. They have, of course, the US Constitution, but every state has its own constitution as well. And a lot of the fights are going to be at the state level now. Like the US Constitution is lost so they're not going to have a uniform right to abortion recognized any time soon, but Massachusetts, for instance, just passed a law saying that we recognize that reproductive rights are part of our constitution. California has something that's going to be on their November ballot to amend their state constitution. And there's some – and there's also equal rights amendments. They didn't get one in the US Constitution but they got one in very many state constitutions. So that's something to watch out for too.
And there's injunctions that have already been issued, as I understand it, in Louisiana and Utah against these bans of abortion and trigger laws. So, it doesn't mean that litigation is over. It's just going to be taking place at the lower level in these state courts. And there's also issues of statutory interpretations. So where abortion isn't completely banned, but it's restricted to where life or health is at issue, as we saw before 1988 in Morgentaler, that is subject to interpretation what exactly that means.
So from what I understand activists are saying is they're saying, well the courts were not even – we've totally lost faith that the courts are going to save us. We're going to engage in activism. For instance there's a number of state district attorneys that said that our abortion rights are solid. People can come into our states and – from outside and get abortions. It's possible that prosecutors will just refuse to prosecute, etcetera. So it's going to be those kinds of more regional trench warfare that's happening on the activist and the legal level.
Interviewer: Well states will be free to ban abortions for any reason and we already saw that with Mississippi this week. So, that brings us a bit to Canada, because I mean this is our neighbours to the south. So are Canadian laws safe from the impact of antiabortion rhetoric like the one that we had in the US.
Respondent: There's kind of two issues there. There's a social and a cultural issue, and there's a legal issue. So if you looked at Morgentaler, our main case on abortion rights – there's other cases but that was the big one that struck down section 251 of the criminal code. And if you look at the treatment of Morgentaler versus the treatment of Roe and Wade in the United States it couldn't be more different. I would suggest that Morgentaler has only grown in stature, and in respect, since the time it was made, if you look at the jurisprudence, you know, of course the majority decision in that case was that these very labyrinthine rules that a woman had to follow if she wanted to get a legal abortion violated women's personal security on both their physical integrity because delays in getting an abortion means more risk, and their psychological integrity in terms of the stress and – that is caused when a woman is kind of in limbo in terms of whether she's going to be able to get an abortion or not.
But, Justice Wilson wrote a concurring decision that said that the first question you have to ask is not about procedure. She said, the first question is, can the state regulate women's rights over their own body at all? And she said that because of women's right to liberty, it can't. So hers was a broader decision. It wasn't just about, well, maybe if we fix the process it will be OK, we can restrict abortion. She said that the prior question is whether we can do it at all. And she said no because that is trying to take away a decision that is of fundamental importance to the individual and she said that men can't even contemplate the gravity of that decision even imaginatively.
And so the reason I say that our law is pretty solid is that although Wilson's opinion was a concurring, it was cited by a number of majority opinions by the court subsequently. So – and that's – so security of the person, liberty, and we haven't even talked about equality. Why is that? Well Morgentaler was 1988, our first Supreme Court decision on the section 15 equality right, 1989. So, you can see why you know, that wasn't something that was advanced. We didn't really know how strong the equality right was going to be. And you know, especially in the early 2000s, the bad old days as equality scholars call it, we were in a pretty bad situation as far as whether or not equality rights were really going to be something that would be able to eliminate discrimination and advance equality. With some more recent decisions of the court we can see that this is a more robust right, and scholars like Emmett Macfarlane have really pressed the idea that section 15 and equality means that there can't be any barriers to women accessing reproductive services.
So that's the third grounding that – and certainly in the New Brunswick litigation that is challenging the lack of funding for clinic abortions, that is something that is going to be strenuously pressed for the court to make a decision based on equality.
Interviewer: So can we say, like, from I understand of what you're saying that Morgentaler in Canada is as rock solid as Roe versus Wade they didn't turn out to be in the US because mainly of Wilson's opinion that was concurring that was then reused later and that we can still base ourselves on?
Respondent: Well, people have been throwing at Roe versus Wade almost from the get-go. You don't really see that in relation to Morgentaler. Some people have said, well it just shows how far the court went in departing from what section 7 was supposed to be all about. But if you look at the genius of the majority decision is it's quite conservative as far as section 7. It doesn't talk about substantive fundamental justice in section 7. It only is based on procedural fundamental justice for the majority. So it's a very doctrinally conservative decision. But the problem is, it doesn't go far enough because as Justice Wilson points out, basically the majority is just saying, the process is bad. If you fix the process, maybe it would pass muster next time.
The concurring decision goes further and says, it's not just about process, it's about the state interfering in the autonomy of women. So the two of them together makes for a pretty significant precedent. So yeah. I would say that we're in a much different position. That being said, laws change. We've seen that with medical assistance in dying, with sex work. So it seems like there's more appetite by our courts to overturn precedent. But I'm just not envisioning that in relation to reproductive rights and abortion. We don't have the same pollicisation of the courts. We don't have the politicization in society where you have antis and people that are pro-choice kind of fighting this battle on – you know, in a very visible way. So because obviously society and culture influences the courts, even our courts, but I just don't see the dynamics playing out in a way that would be any way comparable.
Interviewer: So we know we have New Brunswick, for instance, limiting access to abortion.
Respondent: The black sheep of the federation, yeah that's what we want.
Respondent: [Cross talking 00:23:03].
Interviewer: And we also know that in other provinces some patients must pay administrative fees (I'm sorry for my French accent here, that's a hard word to say). So yeah, patients much pay administrative fees, which should usually be covered by the Canada Health Act. But so what I'm trying to say here is that we know we have some limitation in Canada, and well now that we see what happened in the US, should Canadian women have any reason to fear that their right to abortion might be [unintelligible 00:23:41] if it's not from a reversal of a Supreme Court decision, then just from the application of the law.
Respondent: Yeah, so I think Canadians are complacent, and indeed when I did my op-ed that I referenced I saw a lot of comments online like, quit trying to import a fight from the United States into Canada. No one's fighting about this here. We have no problems here. And that really isn't the case. As I mentioned in New Brunswick we have this restriction that essentially meant that women in Fredericton had to pay out of pocket for abortion services because we didn't have a hospital here that was willing to provide them. We only have three hospitals. Two in Moncton, one in Bathurst. And our stand-alone abortion clinic essentially went under, it was sold because the province was unwilling to extend Medicare funding for abortion services in that clinic. They had to charge women about $700, but they didn't turn anyone away either. So what that meant is that they were constantly behind the 8-ball as far as trying to keep the doors open.
So the problems as far as access here, women from Fredericton, from north of the province, northwest for instance, have real access issues. For a woman in Fredericton, stats show that most people seeking abortions actually have other children. So it means arranging child care, it means arranging time off from a job. It either means paying for a hotel because you can't drive after receiving a surgical procedure like that. So it either means breaching your privacy and getting a friend or a relative to drive you. Or paying out of pocket for a hotel in Moncton. And that's assuming that you can get an abortion there. Which I understand that accessibility is fairly good now but that might change. And accessibility might be good because no one can afford to do all of those things to get to Moncton.
So that's definitely part of the problem. So that's why there's litigation her. I know of past issues with user fees, in fact there was a class action in Quebec where women litigated about user fees and user clinics and there was a settlement, I believe, in that class action. There was other litigation in Manitoba that I haven't heard about it in a long time, it might have settled. There was no access in PEI. They started a litigation before the new government – the new Liberal government capitulated. So there's all of these kind of regional skirmishes, and really access is not 100 percent guaranteed.
So Canadians can't be complacent and women can't be complacent where they might think, well my rights are secure in Canada. Should I need, it'll be there for me. It's a much more complicated landscape than that.
Interviewer: Definitely. About the case in Quebec actually, it was – the one you're talking about was around 2006, and I believe it ended up with the Quebec government having to pay around more than $10 million to women who have to pay from their pocket for their abortion.
So now talking a bit about the brief that was prepared with Action Canada and the National Association of Women and the Law, where it was argued that we do not need an abortion now in Canada, because we hear now, of course, since last week, we've heard the people from the – experts from the two sides saying that yes we do need one, or no we do not. And could you please actually share with our listeners why exactly you do not think this is a good solution.
Respondent: This is something where I kind of went – underwent some learning myself because I was kind of a bit agnostic. I'm like, well, I don't think it'll really help, but why would it hurt? And it's really, you know, the National Association of Women and the Law, their experts plus Action Canada that really convinced me of that, and apparently not just me, because this brief was cited in the Globe and Mail recently as well.
And essentially it's – it's something that would pretty much only be symptomatic because of course most of the jurisdiction for health care in Canada is at the provincial level. So there's noises that the feds would pass some sort of law recognizing abortion rights, probably would not have that much of an impact. And frankly, you know, as NAWL has also argued with respect to the recent bill on extreme intoxication, C28, passing ineffective laws just because you want to be seen to do something, is not good public policy.
So for here, we don't need a law. The criminal law has been struck down and we don't have any official criminal law or any official across Canada law concerning abortion. But we do have other laws. So of course, like I was saying, we have funding laws, which is at issue at the New Brunswick litigation. There are gestational limits and hospital policies and hospital regulations. We have ethical rules for service providers and for doctors. For instance the College of Physicians and Surgeons of Ontario has made a rule of effective referral. So if you have a doctor that refuses to provide abortion health care they have to make an effective referral to someone who will. And that was constitutionally challenged and upheld.
So we need more provincial regulatory bodies to put that in their own ethical rules. So it's not that we don't have any laws, we just don't have a criminal law and we treat abortion as the health care service that it is. So that's that.
The other issue is when you have a law on the books you're just inciting other governments that might not be so friendly to abortion rights to go and amend it and perhaps impose more restrictions. And it's been a while since I've looked at private members' bills. But they were in the dozens in terms of private members' bills since Morgentaler seeking restrictions on abortion. Whether that is through so-called foetal protection laws, which the American experience has told us has been mainly used to punish women who maybe have addiction issues, or punish women who miscarry. You have sex selective abortion restrictions that have been attempted. You have attempts to define person in the criminal code as including foetuses. And the list goes on and on and on.
So we have many test balloons that are being floated notionally but backed by backbenchers. But potentially by governments that want to test the resolve of Canadians with respect to women's reproductive rights. Therefore having a law is potentially going to reenergize those efforts. And that was particularly persuasive to me just because of the research I've done, and I know that these backbenchers and groups are waiting in the wings to just get their hands on something like that.
Interviewer: Well you know, I didn't know about that actually the private members, so that's very interesting input. Scary at the same time. So I hear you, we have laws, we already have some policies, hospital policies but what can we do to make sure that abortion rights are strengthened and fully respected in Canada?
Respondent: I think it's really important that we not just tell the federal government in particular to do something, quote unquote. But tell them to do something that's effective. So NAWL and Action Canada have come up with a number of things that, you know, personally some of these I've pushed for, enforcement of the Canada Health Act of course, because the Canada Health Act in particular indicates that there has to be accessible health care services, and governments cannot impede or preclude, either directly or indirectly – I'm quoting from section 12 of the Canada Health Act – whether by charges or otherwise reasonable access to those services by insured people.
So it doesn't matter that, for instance, New Brunswick isn't straight up saying no abortion services shall be offered if they're putting impediments up like geographic barriers, financial barriers, that is a violation of the Canada Health Act. The federal government has already recognized that and fined New Brunswick to the tune of something like $140,000. Which quite frankly is a drop in the bucket. And also because of COVID, they gave back to them. So there's been zero enforcement effectively of the Canada Health Act violation in New Brunswick. So – and we don't necessarily even need amendments to the Canada Health Act. I think the Canada Health Act is perfectly fine. I think what there has to be is enforcement.
So enforcement is a big issue. Putting strings on federal health care transfers would be another one. The constitutional law is quite clear that if you, as the federal government are providing money, it's kind of like when you've got money, you know, from your grandma or whatever, if grandma says, "You can – you know, go and use this and you know, go buy yourself a new pair of pants or whatever." Grandma can do that, the federal government can do that. And the feds can tell you, you're getting this money only if you provide – you become compliant with the Canada Health Act by doing X, Y and Z. So that is an option as well.
And there's other things. I mean it's a great brief and people should go and read it. As I said, it's getting some attention but, you know, federal government can put access on its own websites about sexual and reproductive health. It's really important that people get accurate information. We have pregnancy centers across Canada. We have one right next door to what was Clinic 554 that aren't necessarily providing people with accurate information about abortion, for instance.
So those are some of the things that if you're concerned about women's reproductive rights talk to your MP. I was a staff lawyer at CBA for many years and lobbied, and know from that experience that MPs are quite responsive to people that live in their riding. So go and give them a call, or write them an email. They listen. You know, because their future depends on being responsive to constituents. So that's one very, very good thing that everyone can do. And question your MPs and question your provincial government on access.
Interviewer: Definitely. And if you need some inspiration on what to put on your question or in your letter to the MP we will be putting the brief that you are referring to, the brief from Action Canada and NAWL in our description of this podcast so you can have a look at it and maybe have some inspiration yourself.
Respondent: Yeah, and send – you know, cut and paste and put into your letter. Because you know, MPs are busy and they need – we need to get this before their eyeballs to read.
Interviewer: Yeah, and some concrete actions as well so that they really have it. They just need to – they don't need to think about it, they just need to see it and to see what they can do.
Respondent: I have a funny little anecdote where in a past election there was an MP that came over to our house and I was digging around in our front yard garden, and he was talking about getting re-elected and wanted my vote, and I started talking to him about the feds and abortion access. And his comment was, well, you know, health care services are provincial. What do you want us to do?
Interviewer: Oh. He didn't know who he was talking to.
Respondent: And so [cross talking 00:37:47] open the door and he just, like, sit back and watch the show because I schooled him a little bit, and he didn't get re-elected, funny that.
Interviewer: You never know to whom you're talking to either.
Respondent: I don't think he did.
Interviewer: No I'm sure he didn't. He regrets it still today. So one question and I know is a difficult one, but you probably already had to face some people and we all have to when we discuss about this decision, even before the decision from the Supreme Court of the US. So we always meet people, friends, family, colleagues, who are against choice. So I hate the word pro-life. The word is just against choice. So yeah, when you need to face, when you discuss with some people who have different views, so how can you just discuss with them and how can you – you know, to have an open discussion what arguments can you give? What do you do?
Respondent: Well I think it's more a question of approach and posture and I really kind of despair sometimes that especially on social media things become so personal and so polarized that we can't have conversations about difficult issues. So, you know, this is tough for me because you know, this is about, you know, my rights, my autonomy. I have difficulty kind of talking in an abstract kind of calm, rational way when there's people that want to see me have lesser rights. But at the same time I've talked to people about it. I'll talk to anyone about it. And I think we do have to have those hard conversations. And kind of assume good faith on both sides, although I feel like you know, people on the other side are misguided because restricting abortion doesn't have – [unintelligible 00:39:58] institute just had a study saying that restricting abortion doesn't have – or it has very little impact on live births in that rate. So, and it also has an impact on maternal death. For instance before the 1969 amendments to our laws to allow some legal abortions, the highest of, you know, cause of death for women in Ontario of childbearing age was illegal abortion, which was just shocking to me.
But, so those things besides, I do think we have to approach it as people of goodwill that are coming at it from a position of them doing what's right just how I am trying to do what's right. And – because I think whacking people over the head or telling them that they are not good people or etcetera, etcetera, is not the way to win hearts and minds. The way to do it is through an approach that hears them out and hopefully they'll respond in kind. And you know, as you know, the saying goes from Martin Luther King, you know, the arc of justice is long, but it eventually curves towards what is just. So – I'm you know, messing that up but basically that's it. That I have faith that as we progress in society that we will come to the right decisions and we don't do that by villainizing the other side, for sure. That's not what we do in Canada.
Interviewer: Totally, and I think that's the perfect quote even if it's [unintelligible 00:41:59] perfectly said, I think a perfect quote to end this podcast because definitely the point is to discuss with each other about those issues. And I think you already gave to our members who are listening good advice on what they can do right now to make sure that abortion rights are respected and are fully promoted in Canada, [unintelligible 00:42:23] to write to our own MPs, and to keep an eye on what's happening. So they very much Kerry [cross talking 00:42:31] –
Respondent: And just if I can add.
Interviewer: Of course.
Respondent: You know, plead at our premiere. [Lay the eggs? 00:42:35]. You know, not only do I, you know, like to, you know, poke at him, you know, [cross talking 00:42:44] that you know, the rest of Canada is watching him. I don't know to what extent it's effective, but you know, if you're sending an email, copy him.
Interviewer: Definitely always. Copy him everywhere. We will copy him in – we will send him an email from this podcast for sure.
Respondent: That would be awesome.
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