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Mike Hoeflich

Prolonging the Patriot Act
Wednesday, May 11, 2005
In the next few months, a number of provisions in the Patriot Act, passed in the aftermath of the 9-11 terrorist attack, will come before Congress for reauthorization. Without reauthorization, the provisions, which have "sunset provisions" attached, will cease to be law. Thus, over the next weeks and months, the American people and their duly elected representatives in Congress will need to study these provisions and decide whether they have been effective in preventing further terror attacks in the United States.

Scientists point of KU pride
Wednesday, April 13, 2005
This past Monday, Kansas University held a news conference to announce that the National Science Foundation had awarded $19 million to the university to establish a new research center to study the polar icecaps. This was the second NSF center to be established at KU within the past three years. The earlier center was established in 2003 to do research in catalysis. The establishment of the two centers at one university is a remarkable achievement. There are only 25 of these centers funded by the NSF. Thus, KU accounts for 5 percent of the centers nationwide.

Outside money fuels debate
Wednesday, March 30, 2005
There is an old cliché that history repeats itself. Or, as Yogi Berra once said, it seems like deja vu all over again. Well, I've begun to feel the same way recently. In the 1850s, Kansas Territory became a battleground for the national fight over slavery. Both sides flooded Kansas with money and people to ensure that their side would ultimately prevail. The end result was certainly the right one: Kansas became a free state. But during the years in which the two sides struggled here there was great turmoil and loss of life and property.

Amendment a cruel mistake
Wednesday, March 16, 2005
This past Sunday, The New York Times ran an article pointing out that Kansas had been in the national news more than usual during the past several weeks. There was Steve Fossett's round-the-world flight from Salina, the capture of the BTK killer, the attorney general's attempt to get abortion patient records and the upcoming vote on the anti-gay marriage amendment.

Recent AG actions troubling
Wednesday, March 2, 2005
Atty. Gen. Phill Kline has been in the news a good bit recently. I have to confess that I've been rather disappointed in his actions, at least those that have been reported.

Senate oversight a bad idea
Wednesday, February 16, 2005
In the past several weeks, a bill has been introduced into the Kansas Legislature to require that all nominations to the Kansas Supreme Court be confirmed by the Kansas Senate. While I have nothing against such a confirmation process in general, I find myself opposed to the current proposal nonetheless. My opposition to the proposed confirmation process rests on several bases.

A bundle of biographies
Wednesday, February 2, 2005
I love to read biographies. When I'm tired of reading law texts, and don't feel like reading a mystery, I almost always turn to a biography. Part of it is simple voyeurism; I find reading about other people's lives to be fascinating. Part of it is curiosity; I am always interested in how other people handle the same problems that I must. Part of it is hero worship; even in my 50s I still have heroes.

A story of trial, triumph
Wednesday, January 19, 2005
Every year the Kansas University law school admits about 170 first-year students. They're a pretty diverse group from a variety of backgrounds and places. But they all have at least one thing in common. When they first enter the building you can see it in their eyes: hope and determination to succeed.

Law takes step into space
Wednesday, January 5, 2005
Just before Christmas, President Bush signed into law a bill that future generations may regard as one of the most important steps in humanity's quest to expand beyond our planet. This act attracted very little news coverage because there were far more pressing events of current interest, such as the tragic loss of life in Asia's tsunami, but it would be a great shame to let this new piece of legislation go unnoticed.

Death penalty not practical
Wednesday, December 22, 2004
The recent decision of the Kansas Supreme Court invalidating the Kansas death penalty statute presents the Kansas Legislature an opportunity and a choice. Although the attorney general will appeal this ruling to the U.S. Supreme Court, there is no reason the Legislature cannot revisit the statute on its own.

Legislative proposal troubling
Wednesday, December 8, 2004
Every year, the holiday season not only brings tales of reindeer and sugar plums but also of potential initiatives that occupy the minds of legislators as they prepare for the beginning of the new session in January. In recent days, two such proposals have come to light. The first is a move to authorize covenant marriage in Kansas; the second is to adopt a "Taxpayer Bill of Rights" (TABOR) modeled on the Colorado law.

DNA evidence raises issues
Wednesday, November 24, 2004
Last week, a young lawyer lectured on the growing use of DNA evidence at the law school. I found her lecture simply fascinating and thought-provoking. The whole science of forensics has gained popular attention in recent years, both through its use in cases like the Peterson murder trial and because of the increasing popularity of television shows like CSI.

Social Security's shaky future
Wednesday, November 10, 2004
The election is over; there are winners and there are losers. But our country goes on. And the business of government at all levels must go on as well.

Flu-shot line renews faith
Wednesday, October 27, 2004
I usually sleep late on Saturdays, but this week I was up quite early and out of the house by 6. Because I have diabetes, my doctor told me that I needed to have a flu shot. Under normal conditions this would be a minor annoyance, a trip to his office and a shot. But this year, because of the national shortage, he had no vaccine so I needed to go to the mass vaccination clinic at Free State High School.

In praise of modesty...
Wednesday, October 13, 2004
When I was growing up, my grandfather, who was a very wise man as most grandfathers are, used to tell me that it was improper to praise oneself and broadcast one's achievements to the world. If praise were to come from others, one should accept it gracefully, but one should never, as he put it, "toot one's own horn."

More information needed
Wednesday, September 29, 2004
Normally, I write this column on Sunday evening. It is now 4:30 a.m. Monday. It has been a long night. I have spent the past few hours and the past few days trying to figure out what I want to say about the current furor over Judge Paula Martin's decision in a controversial case this year involving the statutory rape of a 13-year-old girl by a group of men. The case is controversial for several reasons.

U.S. should be for everyone
Wednesday, September 15, 2004
Last week I was interviewed by Jim Baker, a reporter for this newspaper, for an article he was writing on the growing movement among some Christians to have the United States formally declare itself to be a "Christian nation." When the article appeared, it included quotations from some local pastors strongly supporting such an idea. Upon reading the article I found myself profoundly disturbed on a very fundamental and personal level.

Campaign has fictional feel
Wednesday, September 1, 2004
When I was a young man I used to play mental games with myself. One of my favorites was to take a situation, one in which I was involved or one which I had observed, and try to imagine what author might have conceived and written it. Thus, when I had a particularly bad day, laden with irony, I would often imagine that Kurt Vonnegut or Woody Allen had been scripting my life. Other days, I might have opted for Alfred Hitchcock or Ray Bradbury.

Can celebrities get justice?
Wednesday, August 18, 2004
Americans' hunger for celebrity trials seems to grow each year, and the media seem more eager than ever to provide such stuff. But I think it is reaching a point at which we must begin to ask whether celebrities are any longer able to have a fair trial.

Tapping U.S. imaginations
Wednesday, August 4, 2004
The release of the final report of the 9-11 commission held few surprises for those who had been following its hearings over the past few months. Its catalogue of intelligence failures and bureaucratic misadventures is one that can only horrify most Americans. Its suggestions for a radical reorganization of American intelligence services are long overdue. It has been obvious for several years that the American military and intelligence services are having a difficult time in escaping from a half century's focus on fighting the Cold War to a new focus on fighting a war against terror.

Marriage 'tradition' varied
Wednesday, July 21, 2004
Over the past year I have followed the debate over gay marriage with interest. Like Sen. John McCain I don't believe that the majority of American people favor a constitutional ban on such marriages and I doubt that they ever will. But I have been fascinated not only by the passion the subject has generated but also by the arguments which have been set forth. Recently I had lunch with a friend, a historian, who talked about the problem of trying to define "traditional marriage" and the "traditional family" and to use these definitions in arguments to ban new forms of relationships like gay marriage.

We 'may' not do all we 'can'
Wednesday, July 7, 2004
In the ninth grade I had an English teacher named Mrs. Astle. She was a formidable woman, actually from England, who frightened me to death. She was a stickler for proper word usage. One of the points she insisted upon was the difference between "can" and "may." I will never forget that "can" is used when one has the ability to do something; "may" is used when it is permissible to do something.

Cutting history is a mistake
Wednesday, June 23, 2004
The recent proposal to reduce the amount of non-U.S. history taught in Kansas schools shocked me. Perhaps, it is because I am both a lawyer and a historian. Perhaps, it is because I cannot imagine reducing instruction in a field that is increasingly important to all Americans, or, perhaps, it is because I saw one comment that the reason for doing so was to enable Kansas schools to do the "patriotic" thing and teach more U.S. and Kansas history. This proposal is simply wrong-headed.

Chautauqua tradition relived
Wednesday, June 9, 2004
The other day a friend and colleague called me and asked me to write a column about the various Lawrence sesquicentennial events taking place in June and, especially, the Chautauqua, which will take place in South Park from June 24 through 29. So here goes.

Early judges deserve respect
Wednesday, May 26, 2004
When I opened this newspaper Monday morning and read the article about the County Commission's plans to remove the portraits of nine of Douglas County's founding district judges, I was overcome by a sense of irony. Just as Lawrence enters into the celebrations of its sesquicentennial, our county commissioners have decided that the portraits of our ancestors are no longer worthy of display in the old courthouse, and one commissioner believes that these men (yes, they are all men) were "just a ‘bunch of old white guys.'"

KU research benefits state
Wednesday, April 28, 2004
This past Saturday night I attended a celebration of the 30th anniversary of the Tertiary Oil Recovery Project (TORP) here at KU. I have to confess I wasn't expecting to have a very exciting evening, but the project is affiliated with my wife's department and the two directors, Paul Wilhite and Don Green, are friends.

Scalia actions damage court
Wednesday, March 31, 2004
The controversy over Supreme Court Justice Antonin Scalia's hunting trips, especially the one he shared with Vice President Dick Cheney, has upset and saddened many lawyers and others concerned with the continuing legitimacy of the U.S. Supreme Court. In a number of ways, however, the public debate has been somewhat misplaced.

Schools must guide athletes
Wednesday, March 17, 2004
Recently the media has been filled with reports of the scandal at the University of Colorado involving a series of charges filed by women who said they had been sexually assaulted by athletes over the past several years. The seriousness of these charges was compounded by extremely unfortunate remarks made to the press by the football coach, remarks that led to disciplinary action being taken against him. The president of the university has convened an investigation into both the specific charges and into the program as a whole, and even the Colorado Legislature has now begun to look into the matter.

Path to Brown v. Board
Wednesday, March 3, 2004
This past week I gave a lecture in a course taught by Prof. Norm Yetman of the Kansas University American Studies Department. The course is a new one designed to help familiarize students with the background and details of Brown v. Board of Education, whose 50th anniversary is being celebrated this year. My particular assignment was to lecture on an earlier case from the late 19th century, Plessy v. Ferguson.

Old-fashioned reliability
Wednesday, February 4, 2004
A number of years ago my wife, Karen, and I spent a few days in San Francisco at a conference. We found that we had a morning free from professional obligations so we decided to walk to the waterfront. When we got there we discovered that a United States Navy missile cruiser was in port there and that the public was invited to have a look around.

Judges making headlines
Wednesday, January 21, 2004
I have been thinking about judges recently. This isn't all that surprising since I am a law professor. But recently judges have been in the news for a variety of reasons. Indeed, if one looks at the newspapers or watches the news on television it is quickly apparent that judges make frequent appearances because they are so central to our lives. I thought that it might be appropriate to comment on several recent judicial developments in this column.

'Sack' shocked Lawrence
Wednesday, January 7, 2004
As the new year begins, so does the celebration of the sesquicentennial of the Kansas territory and the founding of Lawrence. Throughout 2004, there will be various events and activities to bring to the fore the history of the past century and a half here in our home city and state. Many people have been busy during the past several years preparing to mark this important anniversary. In the next 12 months I hope to contribute in a small way to these efforts by devoting a number of columns to the subject of Kansas -- and Lawrence -- history. I believe that a good way to start is to remember back to the turbulent beginnings of our city and state.

Ryun criticism misses mark
Wednesday, December 10, 2003
Congressman Jim Ryun is a great athlete and a great Kansan. Last week, it was reported that he was sponsoring a congressional resolution expressing disapproval of recent cases decided by the Supreme Court of the United States. His disapproval is not limited to the findings in these cases. Instead, Congressman Ryun disapproves of the way the Supreme Court decided those cases.

Who owns ‘liberated' items?
Wednesday, November 26, 2003
During the past several months, a rather extraordinary legal drama has been playing itself out in the exclusive world of high-end antiques and rare books. The players in this drama range from a well known dealer once featured on Antiques Roadshow to a private investor to the state of North Carolina. The story has its origins in the very birth process of our nation.

Drugs just tip of care costs
Wednesday, November 12, 2003
The recent decision by a federal court upholding the ban on the importation of prescription drugs by individuals into the United States from Canada was a setback to many elder advocacy groups. Increasingly, many elder Americans are finding that the cost of prescription drugs is beyond their means. It is frustrating for them that the same drugs which they cannot afford here in the United States are available at significantly lower cost just north of the border in Canada.

Vision of institute's future should guide director search
Wednesday, October 29, 2003
The departure of Richard Norton Smith from the Dole Institute later this year means that a search will be undertaken for a permanent successor. Smith did a remarkable job during his short tenure. He built a building for the Institute, organized a marvelous inaugural program last summer and initiated and oversaw visiting lectures that enriched both the university and the community. But now, as he moves on to Illinois and the Lincoln library, we must find someone to carry on the work.

Instinct demands fair play
Wednesday, October 8, 2003
Two scientists at Emory University recently published a study of "fair play" in capuchin monkeys. The study was quite ingenious. The scientists wanted to discover whether the monkeys had an inherent sense of fairness and whether they instinctively understood what lawyers and economists refer to as distributive justice.

Is sports spending too high?
Wednesday, September 24, 2003
Over the past several years, Kansas University has seen a good deal of controversy about its intercollegiate sports programs. There have been staff changes, some sports programs have been dropped while others have seen substantially increased resources, ticket prices have been raised for some events, the stadium has undergone renovation, and salaries of athletic administrators have risen. Not all of these changes have been accompanied by approval of staff, faculty, alumni and students. Many on campus and off are not happy with what has been happening, and many question the need for these changes.

Column makes connection
Wednesday, September 10, 2003
By my calculation, this column marks the beginning of my 10th year writing for the Journal-World. During the past few days I've been thinking about all the changes that the world and I have undergone over the years I've been privileged to share my thoughts with you, and I've even gone back to look at some of the columns I've written. Of course, there are some I wish I'd gone over one more time, and there are several with which I no longer agree. But, by and large, I have to say that writing this column has been a wonderful experience and one that I hope I can continue for a long time to come.

Ashcroft's order out of line
Wednesday, August 13, 2003
Of the many political battles under way in the United States today, one of the most fascinating, and somewhat strange, is that between the attorney general of the United States, John Ashcroft, and the whole of the federal judiciary. That battle took on a new intensity last week as both sides raised the rhetoric to an unprecedented pitch.

KU raises spur hard feelings
Wednesday, July 30, 2003
This has been a rather disheartening year for most folks who work at KU. Indeed, it has not been a particularly good year for most state employees and for many who work in the private sector. The fact of the matter is that the national and state economies are in bad shape and there seems to be little hope that things are going to get much better in the near future. But, after speaking to number of faculty and staff at the university, I have also come to believe that some of the unhappiness now felt on the Hill might have been avoided.

Justice's departure could hurt Bush
Wednesday, July 9, 2003
One of the favorite activities of Supreme Court watchers over the past few years has been to speculate as to when sitting members of the court will resign. This speculation was raised to fever pitch a while back after the media reported that Justice Sandra Day O'Connor's husband was said to have suggested on the eve of President Bush's election that she might retire if Bush were elected. Since then, Justice O'Connor has yet to announce her retirement. Similar rumors have circulated about Chief Justice William Rehnquist's plans. Such rumors and speculations have died down recently, however, as no justice announced such plans before the end of the last term and because O'Connor, in a television interview, suggested that, in fact, she had no plans to retire before the next term of the court.

Mediating civic disputes
Wednesday, June 25, 2003
During the past few weeks I have been reading Craig Miner's new history of Kansas. Professor Minor, of Wichita State, is now the pre-eminent state historian, and his lifelong study of our state is reflected in his new book. What I have found particularly interesting is his first chapter in which he speculates upon the nature of Kansas and Kansans.

Let's put fear in perspective
Wednesday, May 28, 2003
As spring segues into summer, school lets out for the season, graduates begin to seek employment, and the pace of life in Lawrence slows a bit, the time is also ripe for reflection and, on occasion, relaxation.

Wagle's actions insult to fairness
Wednesday, May 14, 2003
For weeks now, state Sen. Susan Wagle, R-Wichita, has carried on a crusade against Kansas University professor Dennis Dailey reminiscent of those of the late, unlamented U.S. Sen. Joseph McCarthy and his House of Un-American Activities Committee.

Old prevention still useful
Wednesday, April 30, 2003
As health officials wait to see whether the SARS virus has peaked or whether it will continue to spread around the world, they are attacking the disease on several fronts. First, of course, are the efforts to identify its cause and find a preventive vaccine and cure. Second, are the efforts to slow, if not stop, the spread of the virus.

Lawyers uphold rules of war
Wednesday, April 2, 2003
This week, I was forcefully reminded that not all soldiers are, as the Marines call them "shooters," and that not all lawyers spend their times in offices and courtrooms.

Get criminal defamation off books
Wednesday, March 19, 2003
When I was a law student, I spent a great deal of time in the law library, especially during my first year. I would take breaks to eat and sleep and, every few hours, I would put down my textbooks for 10 minutes just to escape the tedium of the assigned cases.

Time to negotiate on tunes
Wednesday, February 19, 2003
For the past several years the music industry has waged an increasingly intense war against individuals who illegally download copyrighted music from the Internet.

Is it time to free Mickey?
Wednesday, January 22, 2003
Let us all rejoice! Mickey, Donald, and Minnie are safe! But they are not free.

U.S. values worth fighting for
Wednesday, January 8, 2003
As the new year begins and the world seems inexorably to be marching towards renewed conflict in Iraq and a nuclear crisis in North Korea, it is sad, in a way, to think back only a few years to the break-up of the Soviet Union and the widespread belief in the 1990s that a new era of peace and security was dawning.

Paths to university diversity
Wednesday, December 11, 2002
The Supreme Court of the United States has decided to hear arguments in a Michigan case that will provide it an opportunity to revisit the legality of affirmative action in university admissions.

Freedom and responsibility
Wednesday, November 27, 2002
There was a time in my life when I loved fast food. Put a burger and fries or a hot roast beef sandwich in front of me, and you couldn’t hold me back.

Budget buck must stop here
Wednesday, November 13, 2002
Last Friday, the board of directors of the Kansas Historical Society had its fall meeting in Topeka. They heard a report on finances from the executive director in which she outlined the fairly drastic cuts the Society had suffered in the past few months because of the state’s fiscal crisis.

9-11 response disappointing
Wednesday, October 23, 2002
I have been writing this column for slightly more than eight years. That translates to a bit more than 200 columns or about 350 typed pages, the length of a typical scholarly book.

Courts take election lead
Wednesday, October 9, 2002
I was again reminded last week as I read about the political mess in New Jersey of something my old law school teacher, Grant Gilmore, said in a series of lectures he gave at Yale.

Rankings don't tell story
Wednesday, September 25, 2002
Last week the juxtaposition of two events caused me to spend some time thinking about just what a good education is and how it ought to be measured.

State services being strangled
Wednesday, August 28, 2002
Generally, I try to avoid writing about current university issues because it is difficult to remain sufficiently objective, as I try to be in my commentary. After all, I have been at KU for eight years and have invested a good deal of myself in the place.

Attorneys defend system
Wednesday, July 31, 2002
By Mike Hoeflich
Kansas University School of Law

In recent weeks, the news media have reported a number of stories about the kidnapping and slaying of children, including Samantha Runnion, a 5-year-old California girl.

Atlas inspires reflections
Wednesday, July 17, 2002
By Mike Hoeflich

Summer means many things to many people. For me summer is a time to combine two of my favorite activities: attending auctions and researching Kansas history. In the past few months I've managed to have what, in my terms, were some fabulous successes.

Andersen verdict sets tone
Wednesday, June 19, 2002
By Mike Hoeflich
Kansas University School of Law

After 10 days of discussion, the jury in the Arthur Andersen case found the once-giant accounting firm guilty of obstruction of justice last week. The verdict came as something of a surprise to both sides.

TV creates news celebrities
Wednesday, June 5, 2002
By Mike Hoeflich
Kansas University School of Law

I have been reading a fascinating recent book written by Judge Richard Posner, "Public Intellectuals: A Study of Decline." Judge Posner, a former law professor at the University of Chicago Law School and now a federal judge on the Seventh Circuit Court of Appeals, has played an important role in the development of legal theory in the past few decades.

Education for a complex age
Wednesday, May 22, 2002
By Mike Hoeflich
Kansas University School of Law

It was with some sense of irony that I read two seemingly unconnected news stories last week. The first concerned the serious funding problems that face education throughout the United States because of the weak economy and the decisions by many legislative bodies, including our own here in Kansas, not to raise taxes in support of maintaining budgets.

Web sites offer legal insight
Wednesday, May 8, 2002
By Mike Hoeflich

I am fond of telling my first-year students that one of the most important things they will learn in law school, in addition to the law itself, is how to find relevant law. Ten years ago this meant mastering the intricacies of legal literature and becoming able to work with the hundreds of thousands of books that one can find in a major law library.

Drawing lines against porn
Wednesday, April 24, 2002
By Mike Hoeflich
Kansas University School of Law

Last week the United States Supreme Court, by a vote of 6-3 in Ashcroft v. The Free Speech Coalition, maintained that a law banning computer generated pornographic images of children was a violation of constitutionally guaranteed rights of freedom of speech.

Ending the Mideast feud
Wednesday, April 10, 2002
By Mike Hoeflich
Kansas University School of Law.

Several years ago, in the course of doing some research on the history of criminal law, I became fascinated by the concept of feud. Feud is a social phenomenon which has been with us probably since men and women first walked upright. It is tied to vengeance and to concepts of family, kin, tribe and nation.

House takes puzzling action
Wednesday, March 27, 2002
By Mike Hoeflich
Kansas University School of Law

This is a year in which one issue, the budget, has attracted most legislative and public attention. But the Kansas House has not limited itself only to considering how to deal with the state's large deficit.

Age, news loses value
Wednesday, March 13, 2002
By Mike Hoeflich

The debate between ABC and CBS about whether Ted Koppel and his news show, "Nightline," should be replaced by David Letterman has brought out some most puzzling aspects of television executives' views of American society.

U.S. rail is at crossroads
Wednesday, February 27, 2002
By Mike Hoeflich
Kansas University School of Law

This year, the U.S. Congress must deal with an issue that could have a lasting effect on the United States economy and on the world's environment. A recent report to Congress by a special commission has made it clear that Amtrak is not economically viable and that something must be done.

Drug cases call for restraint
Wednesday, August 29, 2001
By Mike Hoeflich
Kansas University School of Law

In the last month, the pharmaceuticals industry has suffered two major blows. The first was the recall in the United States of one of the statin drugs produced by Bayer under the name Baycol.

Staff vital to KU's mission
Wednesday, January 17, 2001
By Mike Hoeflich

Gov. Graves' renewed interest and emphasis on education in his State of the State Address and in his budgetary plans for the current year is laudable. However, there is one part of these plans which is both morally and pragmatically wrong-headed.

Court picks face challenge
Wednesday, December 6, 2000
By Mike Hoeflich
Kansas University School of Law

Eventually we will have a new president and when public attentions shift to new things, one major effect of the general election of 2000 will still be very much with us. The next president of the United States will, in all probability, nominate several individuals for seats on the United States Supreme Court.

U.S. can survive controversy
Wednesday, November 22, 2000
By Mike Hoeflich
Contributing columnist

I have no doubt that there is little need for another commentary on Election 2000, but, on the other hand, I am struck rather forcibly by a number of things that have not been given a great deal of attention by the general media. Thus, let me begin this week's column with a few assorted thoughts on the election and its aftermath.

Art not just simple property
Wednesday, October 25, 2000
By Mike Hoeflich
Kansas University School of Law

This semester I am teaching a course at the law school on "Law & the Visual Arts," which explores the legal aspects of representing artists, collectors, and museums. It is a course I am particularly fond of because it permits me to combine my interest in art with my legal expertise.

Book shops a rarer pleasure
Wednesday, October 4, 2000
By Mike Hoeflich, professor in the Kansas University School of Law

When I was an undergraduate I was fortunate enough to have a history professor who was also a bibliophile. He was the sort of professor for whom teaching did not stop at the classroom door. He took pains to get to know his students and he invited us to his house.

Reading university rankings
Wednesday, September 20, 2000
By Mike Hoeflich
Kansas University law school

Although I usually devote this column to legal matters, occasionally I am so moved by some academic issue that I feel it is important to speak out. Recently, there have been several articles about where KU stands in the "national rankings" of universities and where it should be. In particular, there has been a good deal of concern expressed that KU may have "slipped" in one such ranking.