Episode 6: The Insular Cases with Marlee Sonico
Marlee Sonico is an attorney in private practice. Before earning her J.D. from Georgetown University Law Center, she worked as a staff assistant and voter protection assistant for the Democratic Senatorial Campaign Committee and as an operations associate for the Democratic National Committee.
Douglass Collective is a community of lawyers and activists working to promote a more inclusive vision of the Constitution. We believe that the abolition of slavery and the Reconstruction Amendments provide a powerful blueprint for a world where we are all more free. By raising awareness of the Constitution’s abolitionist roots, and building community and power around that vision, we will chart a more free and equal future.
Transcript
Taonga Leslie (00:01)
Did you know that more than 3.6 million people are living under the rule of the United States but without full constitutional rights? Now, 3.6 million, to put that in perspective, that's more than the population of Wyoming, Vermont, both the Dakotas, and Alaska combined. And that's the reality that people are living in in the US unincorporated territories. To this day, in Puerto Rico, Guam,
American Samoa, the US Virgin Islands, and the Northern Mariana Islands, the US Constitution does not completely apply. People are living under taxation without representation. And if that sounds like colonialism to you, then you have come to the right place.
Taonga Leslie (00:47)
Welcome to Reconstructed, a podcast where we talk about the Constitution, how it shapes our lives, and how we can reclaim it as a force for good.
I'm your host, Taonga Leslie and today we're discussing self-determination in the U.S. territories. To help us unpack why residents of the territories do not yet enjoy full equal rights and how the Supreme Court has played a role in that, we're joined today by Marlee Sonico. She's the recent author of Abolition Democracy and Abolition Constitutionalism, a constitutional framework for overruling the Insular Cases, which recently appeared in the Georgetown Law Review.
Welcome Marlee and thanks for joining us.
Marlee Sonico (01:26)
Thanks so much for having me. Happy to be here.
Taonga Leslie (01:29)
before we dive into the article, I wanted to know what brought you to take up the subject and what made you want to study it and write about it.
Marlee Sonico (01:37)
So, I am Filipino and Chamorro. My mom's family is indigenous to Guam and my family on both my mom and my dad's side have
Experienced the firsthand effects of American colonialism, Philippines being a former US territory and Guam being a current US territory. My mom was born in Guam, moved to California around elementary school, and she is a citizen, but not through the Constitution, but through an act of Congress. And that is due to a series of cases, the insular cases, which I think we'll go.
Into a bit further. but by nature of the insular cases, the US territories are treated differently than residents of the 50 states, and I was really interested in writing about this because of my ethnic background and seeing the ways that my family has been impacted by
the disparate treatment of the US territories. for example, if my family were located Guam, they would not be able to vote for president
They would not have access to meaningful representation and the right to vote. when they moved over to the United States and lived in the mainland, they do have that right. seeing that growing up and seeing the way it played out with my direct family members is what really made me interested in interrogating the history behind why that is.
Taonga Leslie (03:07)
can you say just a little bit more about how in the current day situations and the rights of people in Guam and similar territories are unequal to what we have on the mainland?
Marlee Sonico (03:17)
Yeah, absolutely. So the Supreme Court determines on a case-by-case basis which rights are, quote, fundamental and thus extended to the U.S. territories. So for example, the birthright citizenship clause, which today was upheld by the Supreme Court, does not apply to the US territories. So citizenship in the US territories is determined by Congress. So individuals who are born in the US territories.
With
the exception of American Samoa, they are US citizens through acts of Congress and not the Constitution. citizenship status is determined by the terms of the treaty between that respective country and any congressional legislation that Congress has passed. And in addition to
not having a uniform citizenship structure or a uniform right to citizenship, residents of the territories experience taxation without representation.
The territories have non-voting members of Congress, which is similar to the District of Columbia, where these members of Congress can introduce legislation or vote in their assigned house committees, they don't have a right to vote on ultimately passing legislation,
So despite that lack of meaningful access to electoral participation and congressional representation, the residents are still subject to most federal laws. So while residents of the territories don't pay federal income tax, they're still responsible for other federal taxes like Social Security and Medicare.
Taonga Leslie (04:55)
I am curious, when you were growing up, were you aware of this status of the territory where you were living? Like did you see yourself as like part of the US? Or do you feel like okay, we're we're actually part of Guam,
Marlee Sonico (05:10)
not at all until my first year of law school. so it was pretty unique because my mom grew up in Guam and I grew up in California
So my mom had 14 other siblings. And when they were in Guam, the varying ages in which they moved to the mainland, you can see the different effects of American colonialism. So for example, the language being stripped from indigenous Chamorros. Like my mom, because she moved
to the mainland to California in early elementary school, she learned English first, as do the residents, other residents of Guam before learning or getting access to the indigenous language. Versus her older sisters who were a lot older when moving over to California.
Had the opportunity to learn both English and Chamorro. I think if I were to ask my mom, my aunties, like, do you know that the Constitution is not why you're a US citizen? They would have no idea what I'm talking about,
Or there are different factors that determine the rights that they have. I think my older aunties would have more of an understanding of, like, I can vote for president while living in California, but I couldn't vote for president when I was living in Guam.
Beyond those stark differences, I don't think it is very well known, even by a ton of residents in the territories, exactly how and why they are deprived of certain civil rights and protections.
Taonga Leslie (06:46)
I wanna get to that then, because you've talked about the insular cases. can you just lay out first of all, what were these? When did the Supreme Court start to take up these questions about what rights would apply in the territories and sort of what do these cases stand for?
Marlee Sonico (07:00)
Yeah, so the insular cases were a series of early 1900s cases after the Spanish American War. And these cases established what's called as the doctrine of incorporation, in which the United States Constitution and the Bill of Rights do not automatically extend to unincorporated territories. So what that means is Congress has unlimited authority to determine.
what territories are deemed incorporated and thus protected by the full rights of the constitution or territories that stay unincorporated and are kind of in this permanent limbo status in which some rights are deemed fundamental and others are not.
The doctrine of incorporation stems from Congress's plenary power. So the plenary power doctrine was established in the immigration context. And the earliest case is the Chinese exclusion case, in which the Supreme Court granted unfettered authority to Congress over immigration without being subject to judicial review.
So essentially what the insular cases did they extended this vast plenary power authority beyond its initial application in immigration to the United States territories.
Through that, Congress really has a say the rights and protections that the US territories do or do not have. an example of the doctrine of incorporation and how
Some rights are quote fundamental and others are not. The Supreme Court in a 1904 case called DOR v. United States, the court held that Congress is not required to extend the right to a jury trial to the territories.
residents of the United States territories do not have an inherent right to a jury trial. it is this unfettered plenary power doctrine that.
was initially applied in the immigration context and applied now to the territories through the territory clause of the constitution in which Congress and the Supreme Court can determine on a case-by-case basis what they deem fundamental and what is not.
The key, I guess, holdings of the insular cases were that
The civil rights of the inhabitants of Philippines, Puerto Rico, and Guam was determined by the Treaty of Paris and not the Constitution. The insular cases also held that the territory clause is the source of Congress's plenary power over the U.S. territories. And the Constitution thus does not fully apply to those unincorporated territories. only fundamental rights apply, determined by the Supreme Court on a case by case basis.
basis and all of the territories that were acquired before the Spanish American War, like Alaska, were incorporated and subject to the full application of the Constitution. And those after the Spanish American War were unincorporated, and it was up to Congress for when to deem these former Spanish islands incorporated.
Taonga Leslie (10:05)
it is truly wild to think about. you bring this out and I would love to hear you expand on it further, that there are also racial implications in the way that the Supreme Court even talked about and reached this decision.
Marlee Sonico (10:20)
Absolutely. So the that
The insular cases reference territorial residents, really mirrored the racist sentiment of the time as seen in the Chinese exclusion cases. the insular cases refer to territorial residents as quote, alien races and quote, savage tribes, and the text of these cases engages an othering determining who is insider.
And who is a foreign outsider. Professor Sherali Munshie, she's a professor at Georgetown Law. Her scholarship also interrogates system of the United States legal system creating and determining who is an insider and who is going to be deemed a foreign outsider.
So Justice Joseph McKenna in one of the insular cases wrote that because of the doctrine of incorporation and Congress's ability to determine who is deemed or which territory is deemed incorporated, because of that, the danger of the nationalization of savage tribes cannot arise.
Taonga Leslie (11:30)
This was in the Supreme Court decision.
Marlee Sonico (11:32)
So in De Lima v. Bidwell, this case held that the Constitution confers power to make treaties upon U.S. government and that the government has the power to acquire territories by conquest or by treaty. And Puerto Rico became a territory of the United States upon ratification of the Treaty of Paris, although not
an organized territory in the technical sense of the word. by establishing permanent sovereignty of the United States government over Puerto Rico, Puerto Rico no longer existed as a foreign country and became a domestic territory.
In in that case, they don't explicitly accept the doctrine of incorporation. But in the dissenting opinion, Justice Joseph McKenna argued that Puerto Rico was not incorporated into the United States because of the treaty with Spain. quote, instead of providing for incorporating the ceded territory into the United States,
The treaty expressly declares that the status of the ceded territory is to be determined by Congress. And because of that, he says, quote, the danger of the nationalization of savage tribes cannot arise.
Justice McKenna, in this opinion, though a dissenting opinion, ultimately becomes the foundation for the contemporary doctrine of incorporation through the series of insular cases. It shows that
The Supreme Court was very much interested and making sure there was this legal system that guarantees white insiders and who is deemed other and foreign outsiders.
Taonga Leslie (13:07)
one thing that was interesting about your scholarship is that you'd picked up threads of people in their arguments, you know.
basically making the argument that this is colonialism and this is wrong and that there is another way.
Marlee Sonico (13:17)
Yeah, and and in my note, I reference Justice Harlan, who also dissented in Plessy, that the insular cases allow Congress to exercise this extra constitutional power that's akin to monarchies and despotism. And that's kind of his characterization of the insular cases
How can you have a government power not subject to the constitution, which is the supposed supreme law of the land? for Harlan, his critique shows how this colonial logic and reasoning was imported, integrated, and kind of signed off by the Supreme Court and incorporated into the law.
That now governs the United States relationship with its territories. by importing this colonial logic, it has established this second-class citizenship or second-class governance of the territories that persist today.
Taonga Leslie (14:18)
the main thrust of your argument is so how are we gonna get through this overturn these cases? and so you make two arguments in there. One is under existing originalism and one is this broader abolition approach to constitutionalism. I wanna start with the strict originalism because it's
Honestly surprising given the makeup of the court and what we're seeing, to see even some members of the current majority talking about a need to revisit this case. Can you walk us through what some of the arguments and concerns that have been bubbled up from the originalist point of view are?
Marlee Sonico (14:52)
Justice Gorsuch is a strong proponent of revisiting and overruling the insular cases and has emphasized that under a textualist and originalist approach to a reading of the Constitution, nowhere in the Constitution does it
make a distinction between incorporated and unincorporated and making any sort of distinction between the territories in that way. And in Justice Gorsuch's 2022 concurrence in United States Vivao Madero, he makes the case for a constitutional interpretation that supports overruling the insular cases. And he criticizes that logic inherent in the insular cases.
and he poses these questions. And this is a quote.
What provision of the Constitution could any judge rightly declare less than fundamental? On what basis could any judge profess the right to draw distinctions between incorporated and unincorporated territories, terms nowhere mentioned in the Constitution and which in the past have turned on bigotry? There are no good answers to these bad questions. quote. That I found was so powerful
the whole point of abolition is, you know, rethinking the political possibilities and questioning the status quo. But even under the originalist and textualist approach, there really is nowhere in the constitution that provides for distinction where judges have this.
authority to say that some rights are fundamental and some are not. even looking at the text of the constitution under the dominant conservative lens with the current makeup of the Supreme Court it just doesn't make sense to create this sort of extra constitutional limbo where an entire
territory can be in this sort of permanent
limbo period where some rights apply and some do not and there's no basis in the constitution and I think Justice Gorsuch has really emphasized that. Unfortunately the other conservative justices on the Supreme Court have not expressed a willingness to revisit the insular cases and kind of rule on
whether that logic makes sense, but I think the language that Justice Gorsuch has used in his previous opinions are very helpful in furthering the cause for overruling the Insular cases.
Taonga Leslie (17:26)
is the main counter argument at this point just this is what we have now, let's not rock the boat?
Marlee Sonico (17:35)
There are some counter-arguments for preserving the insular cases and I mentioned this in my note where some proponents of keeping the insular cases say that
It allows the territories to retain their distinct culture while also being subject to the protections of the United States and the constitution, which doesn't really make sense because if the purpose is to preserve a distinct culture and people
you would think that you would just grant independence. It it doesn't
make much sense to say we are allowing these people to be full-fledged parts of the United States while also allowing them to retain their distinct culture because the territories are not full-fledged parts of the United States.
It's not accurate to describe the territories as full-fledged parts of the United States. I each territory has a very different view whether they want statehood, whether they want independence, whether they want something else altogether. And
I think the insular cases really hold back all of the territories from exploring any other political status because they have been kind of forced into this limbo extraconstitutional area where the courts really don't have judicial review over this plenary power that Congress has over the territories.
Taonga Leslie (19:09)
thought that was an interesting and nuanced part of what I understood to be your argument. Like it wasn't so much about what these territories end up being, it's them having the say to be able to decide that, which seems like the biggest right that's off the table with how the insular cases are set up.
Marlee Sonico (19:26)
there are scholars who study the territories who are very in support of statehood and automatically granting birthright citizenship, for example.
I don't think that's the best approach because you're essentially forcing a people against their own will to now be citizens, even if they don't want to. I think what I want to argue with the reason insular cases should be overruled is because the territory should have a say in exactly what they want their political status to be. And right now.
the United States thousands of miles away, people that the residents of the territories have really no say in electing get to make all of the decisions on their behalf. it was a discussion I had with professors when I was in law school the main question that
I've had professors and colleagues ask, is
why overrule the insular cases? Like, what's the point if you are not advocating for just extending citizenship? And I think there are so many other political statuses, and the status quo is citizenship or not
An abolitionist lens as one that I kind of lay out in my note is one that thinks of different political possibilities that are outside of what we see as inherent and the status quo in this country. That's to say,
I don't think I'm the appropriate person. And I don't think legal scholars are the appropriate people to determine for all of the territories whether the solution is statehood. our role, the role of legal scholars should be creating these frameworks and lenses for interpreting.
the law and the constitution to provide opportunities for political action and then kind of turning it over and giving the reins to the territories who are actually impacted by this doctrine.
Taonga Leslie (21:29)
let's go there because I was very curious and excited to see your approach of abolition constitutionalism you draw on Frederick Douglass, you draw on Dorothy Roberts. if you could lay out like what threads you are pulling on and what argument comes out of that.
Marlee Sonico (21:44)
So my note is engaging ideas of intersectional solidarity, concept that Angela Davis and other scholars have explored.
My note is engaged in intersectional solidarity to unite abolitionist struggles of the Reconstruction era, the civil rights movement, together with the struggle against colonial rule of the territories to create that legal environment where the territories can demand political action from political branches. And
Draw upon abolitionist scholars to support my argument that the constitution itself can be used to overrule the insular cases and viewing the constitution as an anti-colonial document, even if that's not the current dominant reading of the document today.
That can still be used in the same way that Frederick Douglass used the Constitution itself to justify principles of liberty and freedom, which was in contrast to the Garrisonian strategy of arguing that slavery couldn't be reconciled.
with the Constitution and there was kind of a duty to not engage the Constitution, if that makes I draw upon Frederick Douglass's approach in creatively using Constitution against the people who wield the Constitution as like a tool against marginalized communities. And I
also engage with Dorothy Roberts' abolition constitutionalism. And Roberts acknowledges that the dominant reading of the Constitution and the Reconstruction Amendment has been anti-abolitionist, but there's still good reason for contemporary abolitionists to engage in abolition constitutionalism. I mean abolition constitutionalism and drawing upon the constitution itself set the framework
for extending birthright citizenship to African Americans and the later adopted 14th amendments explicit provision. And Dorothy Roberts also draws upon abolitionists like Frederick Douglass, who use the Constitution as an instrument to achieve higher principle of justice.
Dorothy Roberts, you know, continues the use of the Constitution as a tool of abolition today to further these higher notions of liberty and justice. the purpose of my note is kind of building upon these frameworks from the civil rights movement and the Reconstruction era and
Using that same constitutional philosophy to overrule the insular cases and use the constitution itself as it has
Been used prior to further abolitionist goals and ideals. in doing so, and using constitution abolition framework, my note argues that this higher principle of justice that Roberts draws upon, that Frederick Douglass kind of theorizes, this higher principle of justice requires the United States to view the territories as its equals rather than its.
Yeah.
Taonga Leslie (24:39)
even in the anti-slavery debate, there was this debate of like, okay, do we use the constitution, do we not? Does this make sense? And I think we see those tensions even now in movements, like, know, does it make sense to try to use the constitution to use these arguments for this struggle? Or like, do we need something, know, completely different or something new? I'm curious, like, as you
you know, as you were sitting down to write this, what made you feel like, okay, it's worthwhile to like invest some time and to do this analysis and try to build this argument?
Marlee Sonico (25:09)
I actually was wrestling with this throughout law school and when I was kind of writing this note of this internal struggle of thinking like, are we so far gone that the constitution, like we just need to scrap it and not try to use it as a tool and kind of we need to just scrap it and come up with something brand new. the reason why I took this approach is because
I view overruling the insular cases and this sort of work for self-determination of the territories by using the constitution. I view that as a non-reformist reform. So legal scholar Amna Akbar, their scholarship defines a non-reformist reform as aiming to undermine the prevailing political, economic, social order, and all these social constructs to
theorize a different one and build democratic power toward emancipatory horizons. my view of overruling the insular cases as a non-reformist reform is
The constitution itself is not going to save us, but I think it is one of many different ways to further abolitionist goals and ideals that is still within or using the existing system as a tool, but acknowledging that.
That's not the end all be all. the one step. There are so many other steps that need to be taken.
Also drawing upon Emna Akbar's work and viewing overruling the insular cases as a non-reformist reform helps legal scholars, abolitionist scholars, theorize abolitionist struggles as matters of global justice. this
Use of the constitution, and I think you know, drawing upon anti-slavery abolition work, it is meant to draw the connections between various different movements to show that they're actually not different movements, they're different manifestations of systems of inequality.
I cite Audrey Lorde, who said, and this is the quote: there is no such thing as a single-issue struggle because we do not live single-issue lives. Our struggles are particular, but we are not alone. Black people have been here before us and survived. We can read their lives like signposts on the road and find that each one of us is here because somebody before us did something to make it possible.
I thought that was so powerful and helped me think through why using the constitution as one of various tools was worthwhile because drawing upon what anti-slavery abolitionists have already done, what
activists during the civil rights movement have done that being one strategy and an example of the different things that can be done I thought it was powerful to build that connection
The struggle of the United States territories is particular to the territories. think there's a lot of similarity in theorizing this higher principle of justice that other abolitionists have kind of read the constitution to support.
Taonga Leslie (28:24)
One of the things that I perceived was that there was a some education that you were doing. Like I didn't know as in nearly as much about the territories. I didn't know about the indigenous peoples of Guam. you put in some untranslated inscriptions. You brought in some folks who are maybe not traditional sources of legal authority. you just talk a little bit about the why and the how you thought about that on how you wanted to write this piece?
Yeah.
Marlee Sonico (28:47)
how the piece happened, I guess, was I was taking an abolition in the law class. And the the class was really focused on anti-slavery abolition and a lot of the work, a lot of the assigned readings, for example, were very
focused on like a history of anti slavery, abolition and
manifestations of slavery in its afterlives today. And as I was reading these abolitionist scholars, like Emma Akbar was one of the assigned readings for the seminar, as well as Allegra McLeod, another abolitionist scholar and also one of my professors in law school, I started building these connections of the issues and struggles of
Black people in the country and these abolitionist ideals were very similar to the abolitionist goals and anti-colonial struggle of the United States territories. And I felt like I haven't seen scholarship that directly puts
the anti-colonial struggle in the territories in direct conversation with the Reconstruction era, anti-slavery abolitionists and the civil rights movement. And I really wanted to
interrogate the legal system and think of ways of furthering abolition but in an area that I have first hand experience in. So being indigenous to Guam and having family who are indigenous Chamoros, it felt very personal.
But also a way that I could think creatively in applying abolitionist theories to in a way that's not as frequently discussed. for example, when I was editing this piece, some feedback I got things that
Some of the editorial staff on the journal wanted me to kind of spell out more is abolition is something that is most frequently discussed with like prison abolition or criminal justice reform. And why did I think to apply it to the territories?
Like there are no single issue struggles. Like I think these are all different manifestations of underlying systems that are inequitable and target marginalized communities. And I thought applying these principles.
Would also allow me to like raise or to amplify the voices of Indigenous people in the territories who are advocating for this work. So writing the paper, I was given tons of leading abolitionist scholars in the class. I wanted to figure out a way that I could take these readings and apply it to something
I've experienced firsthand. And in doing so, I have been able to amplify the voices of Indigenous organizers. So for example, in independent Guahan is an organization that is dedicated to Guam's self-determination and thinking of a political status beyond unincorporated territory. thought this kind of
built the connections across movements in order to highlight the work of grassroots organizers. I see my role as sort of like making the connections and building the framework and drawing upon the people who are on the ground working to educate the residents of the territories and and you know, working towards self-determination and really letting their work
shine in a format where many people like have never heard of independent Guahan or just different grassroots organizations that are working for self-determination in the territories.
Taonga Leslie (32:34)
curious what you'd like to see happen next. Like now the research is out, how would you like people to engage this piece, engage these ideas
Marlee Sonico (32:44)
I'm hoping that my note inspires legal scholars, people who are law students right now, learning also and being assigned the same sorts of readings that I am, thinking about how they can further intersectional solidarity and unite something like MyNote with something that they experience as a struggle.
intersectional solidarity can mean like drawing connections between colonialism and gender justice, right? Like there there are so many different ways to apply abolition constitutionalism that are not as apparent or as frequently talked about that should be. I hope that by
Thinking of a new way to apply abolition constitutionalism beyond what's frequently talked about now with prison abolition, think it reiterates that all of these struggles should be thought of together and in that coalition building is what I hope that.
people who want to write about abolition in the future kind of get from my note. really hope that there's more traction for self-determination in the territories, despite the Supreme Court not not quite being there.
in revisiting the Unsular cases. I hope that there are more grassroots organizers who organize in the territories for self-determination. I hope that this piece
provides more resources because a lot of law students don't learn about the plenary power doctrine and the insular cases. Like I had to educate some professors on what was going on in the US territories and the status and the sort of history and I hope
Law professors who are also engaged in theorizing racial justice and abolition have another way of teaching and applying abolitionist lenses that are not traditionally included in coursework like that.
Taonga Leslie (34:42)
I'm lastly gonna ask you if there's anything and you did mention independent Guahan, I'd love to look them up, but if there's movements, developments on the ground that give you hope or that inspire you as you think about this work.
Marlee Sonico (34:54)
Neil Weir, I think he was born and raised in Guam. he is one of the founders of Right to Democracy, which is an organization that works to overcome
obstacles faced by the territories and aims to build movements focused on dismantling the colonial framework that governs the United States territories. early this month, I think it was the first week of June, right to democracy along with a bipartisan group of
congressional representatives and territorial advocates. They had a briefing
The June fourth congressional briefing. It was titled, What does quote consent of the governed, end quote, mean in United States Territories? So this was a briefing that was
Hosted by Right to Democracy and provided members of Congress and their staff with the historical background on the relationship between the United States territories and the United States through the lens of the Declaration of Independence and the Insular cases, and focused on
What does consent of the governed mean when we have the United States territories who don't have a right to democracy as we are celebrating the 250th anniversary of this country's independence? Like grappling with how this system still exists, and simultaneously we are also celebrating 250 years of independence and democracy and freedom.
This congressional briefing being
in 2026 and organized with the Congressional Hispanic Caucus and the Congressional Asian Pacific American Caucus shows that people are actively engaged in building these coalitions across groups and understanding that making these connections are incredibly important. And it shows because it was a bipartisan briefing, shows that this is something that spans across the political spectrum. And it is
Is something that people are starting to think about more and kind of question the status quo of why have we had territories who don't
have the fundamental rights and protections of the constitution, which is something in my note, I address both ends of the political spectrum. And I think this briefing being bipartisan, especially in a very tumultuous political environment that we have now, the fact that there was a bipartisan briefing supported by some Republican members of Congress shows the possibilities for continuing this coalition building
informing the public what's going on with the territories, which is lesser known and kind of building that momentum. I think no one knows what needs to be changed until people are
accurately informed of the status of the territories, which I think Neil Weir is doing an incredible job of working to educate the public and advocate for what the territories want and need.
Taonga Leslie (37:54)
Thank you so much for joining us. Extremely educational. appreciate the time.
Marlee Sonico (37:59)
Thank you so much.
Taonga Leslie (38:01)
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