commitment to treatment and care: The History of New Hampshire's Mental Health Commitment Law By Dr. Alexander de Nesnera and Hannah Baldwin New Hampshire law allows for the commitment (known in legal terminology as a non-emergency involuntary admission) of individu‑ als deemed a danger to themselves or to others as a result of mental illness to the New Hampshire Hospital for a maximum of five years.1 The benefits of this law have been described,2, 3 but there is no literature on the historical development of New Hampshire’s commitment law. Here, we illustrate the changes that have occurred over time, provid‑ ing a richer understanding and appreciation of the law’s genesis and evolution. The Early Years: 1714-1841 No facility existed in New Hampshire to care for people suffering from mental illness until 1842. People suffering from symptoms of mental illness were cared for by families in private homes or in alms‑ houses, if they did not have family or financial resources. In 1714, an act was passed in the province of New Hampshire pro‑ viding selectmen or overseers of the poor in a particular town with the power to provide for the care of individuals that become “non compos mentis” (not of sound mind) at the charge of the town. A justice of the peace could order the disposal of the estate of the person found non compos mentis (except housing and lands) to provide for the relief and safety of that person, and a New Hampshire Superior Court justice could license the sale of the person’s house or land to provide for his support, relief, and safety, “as long as the person shall live, or until he or she be restored to sound mind.”4 In 1767, the province allowed a judge of probate to assign a guardian for a person deemed “an ideot or non compos,” directing the guardian to take care of the person’s estate, both personal and real. Specific guardian duties were delineated in this act,5 and expanded upon in laws passed in 1776 6 and 1791.7 In 1822, a new law gave authority to the superior court to commit a person who was acquitted of a crime by reason of insanity or mental 24 derangement to prison, “to be detained till he or she be restored to his or her right mind,” if the court believed the person was a danger to citizens or the peace of the state. The superior court could discharge the person if the court believed he or she was no longer dangerous. Finally, this act gave the superior court, upon application of friends of a lunatic person, authority to commit to the custody and safe keeping of such friends the lunatic person, provided the friends give bonds with sufficient surety for payment of all damages, which any person may sustain by reason of the acts and doings of the lunatic person.8 During the early 19th century, states began building asylums for the care of the mentally ill. New Hampshire was no exception, and in 1832 Governor Samuel Dinsmoor asked the New Hampshire Legislature to look into the number and condition of the insane in the state. The deplorable conditions under which these individuals were cared for led to a movement to build a facility to care for them. Two towns, Concord and Portsmouth, vied for the opportunity to have the asylum built in their town. Concord was chosen, mostly due to its contribution of a 123-acre parcel of land. A number of legislative initiatives establishing funding for an asylum were undertaken from 1832 to 1841, setting the stage for its development. Establishment and Centralization: 1842-1908 The New Hampshire Asylum for the Insane was officially estab‑ lished by the state legislature in 1842. Twelve trustees were appointed by the governor. They were instructed to plan necessary buildings, establish costs for the management of the asylum, and make regula‑ tions pertaining to the admission and care of patients. If a person was deemed a danger to the public, the probate court could (if there was a petitioner) order the person to the asylum. Either the selectmen of the town where the person resided or his or her guardian needed to be notified if the person was admitted to the asylum. Any insane person confined in jail could be sent to the asylum by the court of common pleas, and any person could be sent to the asylum by family, guardian, or friends, with the consent of the trustees. Thus, from the very start, two ways of commitment were established: one via court commitment, if a person was deemed dangerous due to mental illness, and another New Hampshire Bar Journal Fall/ 2013/Winter 2014 Captioned, “Ward in Thayer Building, 1920-1930.” The New Hampshire State Hospital was established in 1842, the 17th such hospital in the United States and the seventh in New England. At the time, creating a separate campus for the mentally ill represented more humane treatment than the living conditions these patients had faced. The number of buildings at the campus of the New Hampshire Hospital greatly expanded during the next 100 years. The Thayer building, for medical/surgery purposes, opened in 1907 and was later expanded to a u-shaped building. Photos from New Hampshire Hospital. by consent of the hospital trustees. Towns were mandated to support an insane pauper brought to the asylum in the same manner as the town supported the pauper when they were living in the town. Finally, a person could be discharged from the asylum by any three of the trustees or by a superior court judge “whenever the cause of commitment ceases or a further residence at the asylum is in their opinion not necessary.”9 In 1845, the Legislature granted authority to the Governor and Council “to remove to the NH Asylum for the Insane, to be kept there at the expense of the state, any person confined to the state prison who is now or may hereafter become insane” and if such person is “restored to his right mind before the expiration of his term,” he was to be sent back to the state prison.10 The Legislature also placed responsibility on town selectmen to examine claims of any indigent insane person and pay his expenses if he were sent to the asylum.11 In 1854 an attempt was made to involve the federal government in providing federal lands to individual states via federal legislation that would have set aside 10 million acres of land for the building and maintaining of asylums for indigent insane persons.12 Spearheaded by Dorothea Dix, a strong advocate for the humane treatment of mentally ill people, this legislation passed both houses of Congress, but was vetoed by President Franklin Pierce in 1854.13 President Pierce felt that social welfare issues were the domain of individual states, not of the federal government. His veto set the precedent for New Hampshire and other states to proceed with independent, state-funded initiatives to care for their mentally ill citizens. Fall/ 2013/Winter 2014 In 1881, a New Hampshire commission was established by the Legislature to examine how mentally ill paupers were treated through‑ out the state. Almshouses and county asylums that purportedly cared for insane paupers were not seen as providing any remedial treatment, which led to legislation establishing a Board of Lunacy. The act granted authority to this board to inspect almshouses and county asylums without prior notice, to take people from these establishments and place them in the NH Asylum for the Insane for remedial treatment, and to discharge patients when treatment at the asylum was no longer needed. The Board of Lunacy did not have authority to fix problems it found with local almshouses and county asylums, despite being granted authority to inspect them. Finally, this legislation stated that only “insane paupers” could be admitted to a county asylum and that the Board of Lunacy had to be notified of admissions.14 The first description of physician involvement in the commitment process occurred in legislation adopted in 1901. During the probate court commitment process, no person could be committed without a certificate of two reputable physicians attesting that the person was insane. A personal examination needed to be done by the physicians within one week of the committal. The law also required that the cer‑ tificate of the physicians be accompanied by a certificate from a judge of the New Hampshire Supreme Court, or the probate court, mayor, or a selectman, certifying to the genuineness and respectability of the physicians. This legislation also specified that only insane paupers could be admitted to county asylums and required that all other insane persons New Hampshire Bar Journal 25 be admitted to the NH Asylum for the Insane. It did, however, allow the Supreme Court or other judge the authority to commit an insane pauper to the state asylum if deemed necessary. Any person could be discharged from the asylum by any three of the trustees, by the Board of Lunacy, or by a justice of the Supreme Court whenever further deten‑ tion at the asylum was no longer necessary. Anyone under sentence of imprisonment, whose term had not expired, would be sent back to the prison to complete their sentence.15 A seminal event occurred in 1893 that ultimately led to a signifi‑ cant expansion of the state asylum’s population. The Strafford County Asylum in Dover burned to the ground, and more than 40 patients died. An investigation showed a number of deficiencies in the care of patients16, 17 and led to legislation in 1903 that initiated the transfer of all indigent insane persons from county asylums and other county institutions housing the indigent insane to the (recently re-named in 1902) New Hampshire State Hospital. The name change from the NH Asylum for the Insane to the NH State Hospital identified it as a state institution and hospital, rather than a mere custodial establishment.18 The 1903 legislation mandated the removal of all persons deemed insane from county almshouses and placement in the state hospital, and the closing of all county asylums by Jan. 1, 1909.19 After that date, the state hospital was the only institution caring for individuals deemed insane. The Middle Years: 1909-1969 The consequent admission of increasing numbers of individuals to the state hospital led to a significant expansion of services for New Hampshire citizens. Legislation over the ensuing years focused on clari‑ fying the criteria for commitment. In 1909, legislation mandated that if an individual was undergoing potential commitment by a probate judge, physicians making an examination needed to be registered to practice medicine and have practiced medicine for at least three years; they could not be a relative of the person being committed; and, any violation of these terms could lead to a fine for the physicians.20 The Board of Lunacy in 1915 received authority to work with other outof-state boards to transfer indigent insane persons from one state to another (although the specifics of how these transfers would occur were not described). Probate courts were instructed to inform the Board of Lunacy if any insane person had been appointed a guardian.21 Legislation in 1917 delineated circumstances under which a person could admit themselves voluntarily for treatment to the NH State Hospital. The superintendent could accept the application, and could not detain the individual for more than seven days after receiv‑ ing written notice from the voluntary patient that he or she desired to leave the hospital22. In ensuing years, legislation expanded the list of individuals who could commit an individual with the consent of the trustees to include (in addition to parents, guardians, or friends) boards of selectmen, chiefs of police or deputies, and the boards of county commissioners.23, 24 Discharging patients from the hospital still depended on the opinion of either the courts, trustees of the hospital, or the Board of Lunacy that further hospitalization was unnecessary. The hospital population continued to expand until it reached a peak 26 of 2,700 patients in the mid 1950’s. A variety of treatments were used to alleviate psychiatric symp‑ toms (sleep potions, electroconvulsive therapy, insulin shock therapy, psychosurgery, water cures), but a major change occurred in 1950, with the development of the first antipsychotic (chlorpromazine). Its use led to the significant alleviation of psychotic symptoms, with the potential placement of patients back to the community, setting the stage for deinstitutionalization. The Mental Retardation and Community Mental Health Centers Construction Act of 1963,25 passed as part of President Kennedy’s New Frontier initiative, intended to develop com‑ munity mental health care alternatives to continuing hospitalization of mentally ill patients. In 1961, the New Hampshire Legislature officially defined a mental illness as “a mental disease to such extent that a person so afflicted requires care and treatment for his own welfare, or the welfare of others, or of the community”26 and dissolved the hospital’s board of trustees, replacing them with the director of the New Hampshire Division of Mental Health.27 The Legislature that year also dissolved the Board of Lunacy, replacing it with the superintendent of the New Hampshire State Hospital.28 These changes allowed any person to be committed to the hospital with the consent of the director of the Division of Mental Health (not trustees), and to be discharged by the superintendent (not the Board of Lunacy or the trustees), or a justice of the superior court, whenever further detention was in their opinion unnecessary. Legisla‑ tors also clarified the emergency admission process. A person could be admitted to the state hospital emergently for 24 hours, based on the evaluation of one examining physician, but if that person was to be detained longer than 24 hours, an examination by a second physician was required. An emergency was defined as the person being “a threat to his own life and/or a danger to his family or the community.”29 The New Hampshire State Hospital’s name was officially changed to New Hampshire Hospital in 1963.30 In 1969, further changes were made to the voluntary hospital‑ ization process. Voluntary admission was for a minimum of 60 days. The individual could petition for discharge, and was required to be discharged within 15 days of filing the petition, but not before staying at least 60 days. An additional “Informal Admission” process was also added, allowing New Hampshire Hospital to temporarily detain indi‑ viduals (without going through the involuntary commitment process) upon approval of the admitting physician. The patient admitted in this manner was free to leave the hospital “at any reasonable time, but can’t be detained for more than 12 hours after petitioning to leave.”31 Many subsequent changes to the law followed, as options for treatment of mentally ill patients progressed at a rapid pace and many advocacy, legal, and medical groups looked to ensure that patients were provided the best psychiatric care while preserving their civil liberties. Focus on Due Process and Civil Liberties: 1970-2013 Major changes to the New Hampshire commitment law were adopted in 1973. Chapter 135-B initiated sweeping changes to the way patients were admitted and discharged at New Hampshire Hospital. New Hampshire Bar Journal Fall/ 2013/Winter 2014 An undated image, captioned, “A corner of central work room on a sale day.” The number of patients at New Hampshire Hospital eventually peaked at more than 2,700 in the 1950s. Advancement in mental health treatment, and concerns about the “warehousing” of mentally ill patients began to led the state to shrink the inpatient population and develop more community treatment alternatives. A new, smaller and more modern New Hampshire Hospital opened in 1989. The original hospital buildings, on the Pleasant Street campus, have been gradually renovated for state office space. Voluntary patients could leave within 24 hours of petitioning for dis‑ charge, unless a new process called “Emergency Diagnostic Detention” was initiated. Voluntary patients could only be admitted for up to two years, unless the patient applied for continuing voluntary treatment after the initial two-year period. The discharge of a voluntary patient was granted by the hospital superintendent upon a report of the attend‑ ing physician that the patient no longer benefitted from treatment.32 The emergency diagnostic detention allowed involuntary deten‑ tion for a maximum of 15 days, unless a petition for a longer admis‑ sion was filed in the probate court. A signed physician certificate was required within five days of the initiation of this detention. The physician was required to describe his personal observations and how these satisfied the detention criteria, defined as the individual being in such mental condition as a result of mental illness as to create a strong likelihood of danger to himself or others. Under this process, law enforcement officers could take a person involuntarily for a physi‑ cian evaluation, if the person refused to consent to such an evaluation, and could take the person to a mental health facility for emergency diagnostic detention. The superintendent could discharge the person if he or she did not meet emergency diagnostic detention criteria and did not require treatment. Prior to discharging the person, however, the superintendent had to try to consult the physician who signed the individual in under the emergency diagnostic detention, and also was required to base the discharge decision on the report of the patient’s attending physician.33 Chapter 135-B extensively revised the involuntary admission process. A person in such a mental condition as a result of mental ill‑ ness as to create a potentially serious likelihood of danger to himself or others became the criterion for an emergency involuntary admis‑ Fall/ 2013/Winter 2014 sion. Any “reasonable person” could petition to have the individual hospitalized, and the petitioner and witnesses needed to include specific acts or actions they felt satisfied the criteria for involuntary admis‑ sion. The petition had to include a certificate from a physician who examined the person within five days of the petition filing. A hearing before the probate court would be held within five days of the filing; a court-appointed psychiatrist would examine the person and report her findings to the probate court; legal counsel was appointed for the person to cross-examine witnesses and present evidence on the person’s behalf, and the hearing was closed. Orders for involuntary admis‑ sion were valid for no longer than two years. A person involuntarily admitted could be absolutely discharged upon the approval of the superintendent and the consent of a psychiatrist who had examined the individual within the last three days. The superintendent had to notify the court when a patient was absolutely discharged from the hospital. The hospital could also conditionally discharge the person under such rules and regulations promulgated by the director of the division of mental health. If the person was conditionally discharged for more than one year without any other hospitalizations, that person was deemed absolutely discharged.34 In 1979, the Emergency Diagnostic Detention portion of the law was amended and renamed Involuntary Emergency Hospitalization (IEH). The jurisdiction over hearings was split: the district court was granted jurisdiction in involuntary emergency hospitalization hear‑ ings, and the probate court was granted jurisdiction over involuntary admission hearings. To be admitted on an IEH, the person needed to be in such a mental condition as a result of mental illness as to pose a strong like‑ lihood of harm to himself or others within 40 days of the completion New Hampshire Bar Journal 27 of the involuntary admission petition. An examination by a physician was required to be performed within three days of the petition filing, and the physician did not have to directly observe the specific acts or actions – they could be reported to the physician by the petitioner. Patients had a right to legal counsel, and involuntary hospitalization could not exceed 10 days, unless extended via a probate process. The burden of proof was on the petitioner to show probable cause for the involuntary emergency admission. The hospital superintendent could discharge the person if he or she no longer needed treatment or were deemed to no longer pose a danger to themselves or others.35 In 1986, the Legislature repealed Chapter 135-B and replaced it with Chapter 135-C (our current commitment law), establishing a mental health services system that included New Hampshire Hospital and 10 community mental health centers. The Involuntary Emergency Hospitalization was renamed Involuntary Emergency Admission (IEA), because there were designated receiving facilities in the state that were not hospitals. The IEA hearing was held at the district court. The Involuntary Admission was renamed Non-Emergency Involuntary Admission, and that hearing was held at the probate court. Orders for Non-Emergency Involuntary Admissions were valid for up to five years. The potential for longer-term commitments, with the development of community mental health centers, led to the genesis of conditional discharges and greater continuity of care for persons suffering from severe and persistent mental illness.36 Rules were established address‑ ing the conditional discharge of persons and their rights to appeal perceived civil liberty violations.37 Legislation adopted in 1993 allowed peace officers to place a person in protective custody and bring him or her to an emergency room for an evaluation, if the peace officers believed the person may be suffering from a mental illness and posed an immediate danger of bodily injury to themselves or others. The period of protective custody ended when a physician determined whether an IEA should be ordered, or at the end of six hours, whichever event occurred first.38 In 1997, a new category of danger to self was added to the in‑ voluntary emergency admission petition. This new provision allowed emergency involuntary admission for a severely mentally ill person who had one Non-Emergency Involuntary Admission during the past two years, was refusing treatment deemed necessary by a psychiatrist, with the psychiatrist determining that the individual’s refusal to accept necessary treatment would lead to death, serious injury, or serious de‑ bilitation if admission was not ordered.39 Also developed were provisions allowing a person on a conditional discharge to have the conditional discharge terminated by an administrator upon the request of clinical staff treating the person, as long as an examination took place within three days of the request and the person no longer met criteria for a non-emergency involuntary admission.40 In 2001, advanced psychiatric registered nurse practitioners were, in addition to physicians, authorized to conduct examinations to de‑ termine whether a person met criteria for an involuntary emergency admission.41 In 2010, the maximum initial period of time a person could be hospitalized involuntarily, after an involuntary emergency admission, was changed from 10 days to 10 days excluding Saturdays and Sundays.42 Conclusion New Hampshire Hospital has been in existence for 171 years. Extraordinary changes have occurred in the treatment of patients with mental illness. Fortunately, the great majority of psychiatric patients do not need involuntary hospitalization. When such hospitalization is necessary, current New Hampshire laws allow for a careful balance between civil liberties and the need for excellent clinical care. The road to that balance has been a long one, as described, and will inevitably continue as future generations of clinicians, lawyers, judges and leg‑ islators seek to fine tune our civil commitment laws as new challenges arise. The importance, however, of clearly delineating past legislation cannot be underestimated. A thorough understanding of past history helps clarify future decisions. ENDNOTES 1. New Hampshire Revised Statutes Annotated 135-C:46. 2. de Nesnera, A.; Vidaver, R.: New Hampshire’s Commitment Law: Treatment Implications. New Hampshire Bar Journal, Summer 2007; 68-74. 3. Burns, D.: The Civil Commitment Process in New Hampshire: A Primer on the Law and the Process. New Hampshire Bar Journal, December 1997; 10-17. 4. 1714 New Hampshire Province Laws – Administration of Joseph Dudley – Chapter 2: An act for the relief of ideots and distracted persons. Passed May 15, 1714. 5. 28 1767 New Hampshire Province Laws – Administration of John Wentworth – Chapter New Hampshire Bar Journal Fall/ 2013/Winter 2014 8: An act in further addition to an act, intitled an act for the relief of ideots and distracted persons. Passed Sept. 8, 1767. 6. 1776 NH Laws. Chapter 1: An act for the relief of idiots and distracted persons. Passed March 21, 1776. 7. 1791 N.H. Laws. Chapter 50: An act for the relief of idiots and distracted persons. Passed Feb. 9, 1791. 8. 1822 NH Laws. Title LXXXVI: An act extending the powers of the justices of the superior court of judicature in certain cases. Sections 1 and 3. Passed July 2, 1822. 9. 1842 NH Revised Statutes: Chapter 9: An act for the asylum for the insane: Sections 1, 2, 7, 11, 12, 13, 16, 17. Passed Dec. 23, 1842. 10. 1845 NH Laws. Chapter 246: An act authorizing the governor and council to remove any insane prisoner, confined to the state prison, to the NH Asylum for the insane. Approved July 2, 1845. 11. 1856 NH Laws. Chapter 1835: An act for the relief of indigent insane persons. Approved July 12, 1856. 12. 1854 US Law. An act making a grant of public lands to the several states for the benefit of indigent insane persons. Passed by Congress Feb. 21, 1854. government. Section 1. Approved June 30, 1961. 28. 1961 NH Laws. Chapter 38: An act relative to commitment, discharge, and temporary absences of the mentally ill. Section 2. Adopted March 23, 1961. 29. 1961 NH Laws. Chapter 37: An act relative to emergency admissions to state hospital. Section 1. Approved March 23, 1961. 30. 1963 NH Laws. Chapter 39: An act changing the name of the New Hampshire State Hospital. Section 2. Approved April 5, 1963. 31. 1969 NH Laws. Chapter 37: An act relative to the voluntary commitment of a person to New Hampshire Hospital. Sections 1, 2. Approved March 18, 1969. 32. 1973 NH Laws. Chapter 556: An act establishing civil procedures relating to the admission and treatment of the mentally ill and making an appropriation therefor. Sections 16, 17, 18. Adopted July 5, 1973. 33. 1973 NH Laws. Chapter 556: Sections 19-25. 34. 1973 NH Laws. Chapter 556: Sections 26-39. 35. 1979 NH Laws. Chapter 442 (HB 378): An act relative to involuntary emergency hospitalization. Sections 2, 6. Adopted June 25, 1979. 13. President Franklin Pierce, Veto Message, May 3, 1854. 36. 1986 NH Laws. Chapter 212 (HB 226): An act consolidating the mental health laws and continuing a study committee. Section 1. Approved June 6, 1986. 14. 1889 NH Laws. Chapter 18: An act to improve the condition of the indigent insane. Approved July 30, 1889. 37. State of New Hampshire Administrative Rules. Chapter He-M 600: New Hampshire Hospital. Section He-M 609 – Conditional Discharge. 15. 1901 Public Statutes and Session Laws of NH: Chapter 10: The Asylum for the Insane and Insane Persons: Sections 16, 18, 19, 27. 38. 1993 NH Laws. Chapter 293 (HB 147): An act establishing a committee to study the future and direction of the New Hampshire State Hospital grounds and making an appropriation therefor and relative to involuntary emergency admissions. Section 8. Approved June 23, 1993. 16. Bangor Daily Whig and Courier, Bangor, ME, Feb. 11, 1893. 17. The Daily Review, Decatur, Ill., Feb. 11, 1893. 18. 1901 Public Statutes and Session Laws of NH: Chapter 30: An act in amendment of section 1, chapter 10 of the public statutes, and to change the name of the New Hampshire Asylum for the Insane. Sections 1, 2. Approved Feb. 27, 1901. 19. 1903 NH Laws. Chapter 61: An act to provide for the care and support of the dependent insane by the state: Sections 1, 2, 3. Approved March 7, 1903. 20. 1909 NH Laws. Chapter 124: An act in addition to and in amendment of chapter 10 of the public statutes relating to the commitment and support of insane persons. Section 1. Approved April 8, 1909. 21. 1915 NH Laws. Chapter 15: An act relating to the insane: Sections 1, 2. Approved Feb. 25, 1915. 22. 1917 NH Laws. Chapter 90: An act amendment of section 18, chapter 10 of the public statutes, as amended by chapter 124 of the laws of 1909, relating to admissions to the state hospital. Section 1. Approved March 20, 1917. 23. 1935 NH Laws. Chapter 63: An act relative to commitment to the state hospital. Section 1. Approved April 26, 1935. 24. 1941 NH Laws. Chapter 4: An act relative to commitment to the state hospital. Section 1. Approved Feb. 20, 1941. 25. US Public Law 88-164. Mental Retardation Facilities and Community Mental Health Centers Construction Act of 1963. Passed Oct. 31, 1963. 26. 1961 NH Laws. Chapter 38: An act relative to the commitment, discharge, and temporary absences of the mentally ill. Section 1. Approved March 23, 1961. 27. 1961 NH Laws. Chapter 222: An act establishing a department of health and welfare and providing for the merger therein of certain departments and agencies within the state Fall/ 2013/Winter 2014 39. 1997 NH Laws. Chapter 150 (HB 488): An act relative to involuntary admission to the state hospital on an emergency basis. Section 1. Approved June 9, 1997. 40. 1997 NH Laws. Chapter 316 (HB 433): An act relative to discharge from New Hampshire Hospital. Section 1. Approved June 21, 1997. 41. 2001 NH Laws. Chapter 184 (HB 573): An act relative to the role of certain advanced registered nurse practitioners in the state mental health services system. Section 3, 4. Approved July 5, 2001. 42. 2010 NH Laws. Chapter 293 (HB 1133): An act relative to the duration of involuntary emergency admissions and relative to persons with mental illness and the corrections system. Sections 1, 2, 3. Approved July 13, 2010. About the Author Dr. Alexander de Nesnera, MD, DFAPA, is associate professor of psychiatry at Dartmouth College’s Geisel School of Medicine, and associate medical director of New Hampshire Hospital. Hannah Baldwin is a third-year law student at the University of New Hampshire School of Law. The authors thank Hon. David D. King, deputy administrative judge of the New Hampshire Circuit Court for his review and input. New Hampshire Bar Journal 29
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