Why Do the Innocent Plead Guilty?

Several years ago, Judge Jed Rakoff began writing articles for the New York Review of Books.  The revised essays are the basis for his recent book, Why the Innocent Plead Guilty and the Guilty Go Free, where he concisely shares his views on problems with the current legal system. 

It seems counter intuitive for someone who knows he is innocent to agree to a plea, but Judge Rakoff lays out a pretty clear and compelling reason why this happens so often.  It starts off with good intentions.  Judge Rakoff explains that our desire to crack down on crime and be consistent with sentencing led to the creation of the Sentencing Guidelines, which mandate a specific amount of jail time for a conviction.  However, that change inadvertently led to prosecutors gaining quite a bit of leverage for plea negotiations.  It is common for an unrepresented defendant to feel that the best option is to plead guilty to a lesser crime and receive only a short prison sentence so as to avoid being convicted of a more serious crime, which carries a much longer prison sentence. 

Good intentions seem to play a part in explaining how those responsible for some of the more egregious crimes, such as the people who worked for the banks and perpetuated mortgage fraud in the early 2000s, never got near a courtroom, much less a prison cell.  The DOJ, tasked with investigating and prosecuting this large-scale fraud, decided that it would be too difficult to prove that the high-level executives intended to commit these criminal acts.  Moreover, the DOJ also believed that even if they were successful at prosecuting these large banking institutions, the disruption to the business would have a detrimental effect on the economy, an effect worse than the crimes allegedly done.

The result was that the very largest institutions, banks and corporations, were fined and tasked with self-policing to prevent future criminal acts (rehabilitation as it were), all with the hope that the criminal activity would stop.  The hope was that a better, more ethical culture within the corporation could grow and replace one that was corrupt.  Meanwhile, the individuals responsible for the fraud were never punished.

Other chapters in the books discuss the procedures and processes we have implemented to be better: to rely on scientific methods, even if they might be faulty; to find ways to be more efficient; to focus on catching and prosecuting terrorists.  The unexpected result is that we have slowly eroded away the protections for defendants so carefully laid out in the Constitution. 

The last chapter of the book, ominously titled, “You won’t get your day in court,” outlines the many ways low and middle-income people are frozen out of a fair judicial resolution of their case.  The biggest cause is the expense of a hiring a lawyer. The average person can’t pay for an attorney. Many attorneys won’t take cases on contingency because the payout would be too low to be worthwhile.  Other examples include forced arbitration clauses, or settlement agreements.  The result is that for citizens, “the courts are not an institution to which they can turn for justice, but simply a remote and expensive luxury reserved for the rich and powerful.”

The judge’s frustration is clearly displayed throughout the book, and he concludes that change should come from the legislature. He speculated that might be difficult to do, since most legislators are reluctant to make changes that are seen as “soft on crime.”  Nevertheless, he remains hopeful.  Recently, Congress was pressed by voters to pass the First Step Act, which lowered mandatory minimum sentences on some drug crimes.  He remains cautiously optimistic that American voters will once again rise to the challenge and make other fixes to our legal system.

Jed S. Rakoff, Why the Innocent Plead Guilty and the Guilty Go Free and Other Paradoxes of Our Broken Legal System. New York: Farrar, Strauss and Giroux, 2021.


Here’s an update about a couple of core legal resources that all attorneys used in law school.  They are the Restatements of the Law and the Uniform System of Citation, (the Bluebook). These long-established titles have undergone some changes in the past few years.  Regarding the Restatements, the new publishing plan has caused the law library to rethink where the materials should be placed in the collection.

Published by the American Law Institute (ALI), the Restatements of the Law include many titles and their respective supplements, appendices, and numbered new versions.  Various titles cover major areas of law such as contracts, torts, property, judgments, conflict of laws, and others.  ALI began the system in 1923 to issue “restatements” that would promulgate one highly authoritative source stating the common law, with rule-like content and explanatory material.  In recent years, they devised a new numbering system in 2014, and they converted their more specialized “Principles of the Law” series to Restatements in 2015.  The narrower topics appear in more recent restatement titles which reflect ALI’s decision to publish new titles without any numbers.

It’s possible that only a law librarian would savor delving into the details about the changes.  However, our users should know that we’ve departed from our customary scheme of placing all the Restatements in one section of the library.  Our new scheme involves keeping the older Restatements, with their broad subject coverage, in the north reading room where they’ve always been.  The newer, more specialized, topical restatements are dispersed into the collection where similar subject matter is located.  That way, users who are browsing an area (i.e. employment law) will find that a restatement was published for the topic.  The law library continues to acquire the Restatements in print, and they are also available on our Westlaw service.

A new edition of the Uniform System of Citation (aka the Bluebook) is published about every five years.  The library has the current and several previous print editions.  The Bluebook is a combined effort of law review editors at four law schools–Yale, Columbia, University of Pennsylvania, and Harvard.  The 21st edition came out in 2020 and is noticeably smaller than its recent predecessors.  The decrease in size is due the elimination of Table T2, which accompanies Rule 20 on “Foreign Materials,” from the print version.  Table T2 is now online only.

The Bluebook not only describes how to cite to various electronic resources, but it is itself available in electronic format and includes access on mobile devices.  There is a cost for the online version.  The Bluebook editors would like feedback from attorneys and judges and comments can be sent to editor@legalbluebook.com.

For those who would like a very condensed overview of the new Bluebook, the law library also has the User’s Guide to the Bluebook: Revised for the twenty-first edition, by Alan L. Dworsky.


Are We More than the Sum of Our Parts?

Heather McGhee’s recent book, The Sum of Us: What Racism Costs Everyone and How We Can Prosper Together, dispels the myth that righting the wrongs caused by institutional racism and discrimination is a zero-sum game, that is, what is good for someone else, is bad for me.  Instead, she illustrates many times over how discriminatory policies not only hurt and diminish the target group, but she also writes how these bad policies and practices hurt the community as a whole. 

The book covers many historical and current instances of laws that are aimed at Black people or other minorities.  Each event was followed by how other people, usually poor, White people, are also adversely affected.  For example, just after the Civil War, a critic of slavery named Hinton Rowan Helper wrote a book that asserted that slavery impeded the economic growth of non-slaveholders in the South.  Slavery, which enriched a few, politically powerful landowners, meant that there was little investment in public benefits like schools, libraries, and similar institutions.  His research found that states in the North, such as Maine, had 236 public libraries, while Georgia in the South, had only 38 public libraries.  Similarly, the small state of New Hampshire had over 2300 public schools; Mississippi had only 782.  The net result was that economy in the North was growing, but in the South, the economy was stagnant.  The lack of investment in these public amenities not only hurt the suddenly free but extremely poor ex-slaves but also poor White people as well.

In more recent times, McGhee recalls a case from 1971, Palmer v. Thompson, where the U.S. Supreme Court decided that closing the public swimming pool rather than operating a racially integrated pool did not deprive Black citizens equal protection under the law.  The Court’s reasoning was that Black residents did not suffer any discrimination because they were not singled out by not having access to public pools – White residents were equally deprived.  No pools for anyone. 

There was much resistance in trying to rectify these inequities, because opponents persuaded the public that reforms that gave benefits and resources to one group meant that there were fewer resources for everyone else – that is, they would suffer while others would prosper.  And that did not seem fair.

So how does McGhee propose we move forward?  Her theory is that solidarity is the answer.  In the chapter where she talks about unions, she describes the history of one of the first labor unions, the Knights of Labor.  Their working theory was to include everyone, no matter one’s race, ethnicity, or gender.  All were welcome to join.  They believed that if everyone united behind a single cause, say, an eight-hour workday, or limits on child labor, then management could not use one group of people against the other.  And for a while, that worked.  Many benefits workers receive today are due to the work on unions. 

But as union membership decreased, so did their power.  To illustrate this point, McGhee describes the attempt at starting a union at a Nissan plant in Mississippi that failed.  While many workers wanted the protections from a union, enough people in management, people with longevity with the company, or people who had a chance at upward mobility at the company viewed the start of a union as a threat, and they managed to thwart the creation of the union. 

In the last chapter of the book, she describes the revival of a town in Maine, which was in danger of withering away after the textile industry slowly closed down.  In the late 1990s an influx of Somali immigrants helped revive the economy.  Despite some ugly protesting by White Supremacists, the community, a mixture of long-time White residents and newer immigrants, thrived.  In fact, the combined African immigrant population in the state added over $190 million in state revenue through taxes in 2018.

McGhee concludes her book with these inspirational words:

Since this country’s founding, we have not allowed our diversity to be our superpower, and the result is that the United States is not more than the sum of its disparate parts.  But it could be.  And if it were, all of us would prosper.  In short, we must emerge from this crisis in our republic with a new birth of freedom, rooted in the knowledge that we are so much more when the “We” in the “We the People” is not some of us, but all of us.  We are greater than, and greater for, the sum of us. 


The biography of an extraordinary woman

Nellie Francis

Regular readers of our blog will remember the announcement last fall regarding a CLE about Nellie Francis, a local civil rights activist who was instrumental in passing an anti-lynching law in Minnesota and who also worked to bring the right to vote to women.  We are happy to report that the biography of Nellie Francis, written by Dr. William D. Green, Professor of History at Augsburg University, has been published and is available at the Ramsey County Law Library.  This extensively researched book chronicles Nellie’s story, telling us about her family, her friends, her activism, and historical context of the events in her life that influenced her. 

Of particular interest is the information written about her family.  Her grandmother, Nellie Allen Seay, for whom she was named, was a strong influence in her life – so much so that after her husband died of yellow fever, she moved back to Tennessee to live with her.  Dr. Green also detailed information about other family members that were influential in her life, such as her mother, sister, and of course, her husband Billy Francis.  Billy, like Nellie, was heavily involved with the local community, and was friends with Fredrick McGhee, a prominent St. Paul attorney.  Billy eventually took over McGhee’s law practice when McGhee died in 1912.

In addition to telling Nellie’s story through the lives of her family, Dr. Green also writes about the people in her community.  Nellie was a member of many organizations, such as the Everywoman Suffrage Club, the Red Cross Suffrage Group, the Booklover’s Club and Social and Literacy Society of Pilgrim Church, and the National Association of Colored Women’s Clubs, to name a few.  But Professor Green also tells the reader about other prominent people she worked with in these groups.   Not only did Nellie meet and work with both Booker T. Washington and W.E.B. DuBois, she met several U.S. presidents, including President Taft and President Harding.  But she also worked with other women, like Clara Ueland and Mary Church Terrell, on civil rights issues and the women’s suffrage movement.

Nellie’s story is also told in the context of major events in Minnesota, the most infamous being the lynching of three Black men in Duluth in 1920.  The next year, she helped to enact the state’s anti-lynching legislation, which was passed on April 20, 1921.  This well-researched book also describes the start of the restrictive covenants that were cropping up in Minneapolis and St. Paul and how it impacted Nellie and her husband when they tried to buy a house in a White neighborhood.  (Neighbors offered them a thousand dollars to not move in.  They did anyway.)  

To learn about a remarkable woman and learn more about Minnesota history, as well as the history of important African Americans in Minnesota, please do read this new book, Nellie Francis:  Fighting for racial justice and women’s equality in Minnesota by Dr. William D. Green.  This book is available at the Ramsey County Law Library.


For the next generation

Antiracist Baby by Ibram X. Kendi.

Antiracist Baby by Ibram X. Kendi.



The last book that we’ll review
Is called Antiracist Baby.
This book, like the others in our series,
Is available at the Law Library.

Although this is a children’s book
The lessons also apply to adults
Kendi has written nine suggestions
For readers to review and consult.

The illustrations are colorful
Reflective of our universe
The lessons within gently explain how
To appreciate cultures that are diverse.

We pass these lessons on to our children
So that they can help transform
Our society to one where antiracism
Is not unexpected or rare, but the norm.

Kendi explains that we all make choices
Some are bad, while some are good
We can learn from our mistakes, and make
Better choices in adulthood.

The final pages pose questions for parents
To start the conversation,
To teach their children to be antiracist
And to practice antiracism.

Ibram X. Kendi has some excellent advice
For raising the next generation.
Let’s help build a world that is antiracist
With this book as our inspiration.

Ibram X. Kendi, Antiracist Baby, New York: Penguin Random House, 2020.  Illustrations by Ashley Lukashevsky.


A Woman’s Voice

Her Voice in Law, now available at the Ramsey County Law Library

Her Voice in Law, now available at the Ramsey County Law Library

Her Voice in Law:  Vocal Power and Situational Command for the Female Attorney, by Rena Cook and Laurie Koller, Chicago, IL: ABA Publishing, 2020.

This very interesting and practical book is about a woman’s voice and how it resonates during trial.  An attorney’s voice is a powerful tool – it is how she connects with the audience, tells the client’s story, and convinces the jury to favor her client.  The book walks through the techniques women attorneys can use to improve their vocal skills, use these skills to be better advocates in court, and then apply these skills when communicating with clients and colleagues.

In the five chapters of this books, each one addresses a different aspect of how a woman can improve the quality of voice and subsequently, improve her presentation in court.  The first chapter address the physical aspects of speaking and projecting.  The following chapters discuss emotions and tone in her voice that can be used to capture and hold the interest of the audience.  One chapter discusses body movement and body language to supplement what her voice, words, and emotions are trying to convey.  Finally, the authors point out that these techniques are applicable to non-work situations as well.

The premise of this book is that it isn’t just the content of the spoken word that is important – her speaking voice is important, too.  The book presents so many practical strategies for improving one’s voice – this book is highly recommended to everyone who is interested in improving their oral communication skills.

This book was recently added to the Ramsey County Law Library and is available for check out.









Where there is racial indifference, racism thrives

Locking Up Our Own and the New Jim Crow are available at the Ramsey County Law Library.

Locking Up Our Own and the New Jim Crow are available at the Ramsey County Law Library.

Locking Up Our Own: Crime and Punishment in Black America by James Forman, Jr. (Farrar, Straus and Giroux, 2017)

This Pulitzer Prize winning book closely examines race relations in Washington, D.C. from the sixties through the nineties and describes parallel stories from locations outside of D.C.  The stories explain how Black America supported schemes that resulted in high incarceration among Black people.  The reasons include early Black opposition to the decriminalization of marijuana and surging gun possession due to Black views that guns were needed for collective self-defense. These, and other factors described by the author, laid the foundation for how drug addiction and crime have assailed Black America.

In the second half of the book author Forman describes the consequences of decades-old systems that result in mass incarceration of Black people.  Drug sentences and mandatory minimums, the crack epidemic, the War on Drugs, aggressive police strategies (and pretext policing), and the disparate social and economic impacts of incarceration all factor into the disparagement of Black men.

In his epilogue, Forman describes a decline in crime after 2014 in Washington, D.C., but it leaves in its stead a devastating impact on the Black community.  He concludes that mass incarceration is a system that was “constructed incrementally, and it may have to be dismantled the same way.” (p. 238)

The New Jim Crow: Mass Incarceration in the Age of Colorblindness by Michelle Alexander (Tenth Anniversary Edition, The New Press, 2020)

If Forman’s book describes the history of mass incarceration, Michelle Alexander’s book provides an incisive and rigorous study of the criminal justice system’s impact on current Black America.  In fact, in Locking Up Our Own, Forman references Alexander’s book and states it “played a crucial role in providing advocates with a framework for understanding, and a rhetoric for criticizing, the War on Drugs.” (p. 220)   Alexander explains how and why a disproportionate number of Black men versus White men are incarcerated.

In her introduction to the tenth anniversary edition, she states that the 2010 work (the original edition) is even more relevant today due to the passage of time and predictability of patterns that she identified earlier including: the establishment of a caste system derived from mass incarceration; its collateral consequences; and economic and social exclusion.  Alexander states that this system is “invisible to the naked eye but functions nearly as effectively as Jim Crow laws once did.” (page xxvii)  For change to occur, society must address mass incarceration. Alexander also notes Martin Luther King, Jr.’s warning that racial indifference fosters a culture in which racism thrives.

You can find these books, as well as the other books in our summer reading series at the Ramsey County Law Library.


Systemic racism: It isn’t just one system

The Condemnation of Blackness and The Color of Law.

The Condemnation of Blackness and The Color of Law.


The Condemnation of Blackness by Khalil Gibran Muhammad is a scrupulously researched book that documents statistics, “scholarly papers”, and discourse through American history to try and answer the question: How did we come to think of race, and specifically African Americans, as synonymous with crime?

His book examines decades of effort by researchers and social scientists who influenced popular thinking to conclude that the troubles associated with African Americans – poverty, crime, reduced lifespan, were the result of the inherent inferiority of Blacks to their White counterparts. This research became widely accepted because it appeared to be based on neutral and unbiased statistics. However, while the statistics themselves might have been neutral, the specific selection, interpretation, and subsequent conclusions certainly were not. Fredrick Hoffman, one of the first researchers to publish such a biased report linking excessive criminal behavior to Blacks, expressed this idea by stating that crime would increase “until the negro learns to respect life, property, and chastity, until he learns to believe in the value of personal morality in his daily life…”

Hoffman’s book and those by other social scientists pushed the narrative that increased policing was necessary to deal with the “criminal activity” of Blacks. And while these original reports were written more than a century ago, the attitudes and inherent biases that were fostered are still evident today. In 2015, the U.S. Department of Justice investigated the Ferguson Police Department for the killing of Michael Brown. In defending itself, the department claimed that the community problems were not the fault of the police department, but rather “reflect a pervasive lack of ‘personal responsibility’ among ‘certain segments’ of the community.”

Similarly, Richard Rothstein explains in The Color of Law, that local governments, as well as state and federal government agencies used flimsy excuses (that Black families wanted to live in Black neighborhoods, that they couldn’t afford to live in pricier areas, segregation was a way to limit criminal behavior) to create segregated neighborhoods in cities. These methods to create segregated neighborhoods varied. In cities where new construction created new neighborhoods, contractors received subsidies and tax relief for building White-only neighborhoods. Public housing was built to intentionally segregate mixed neighborhoods. Real estate agents worked with cities to redline neighborhoods that restricted who could purchase houses. Banks refused to fund loans to African Americans.  And so on.  Unfortunately, the result perpetuated a system that actively promoted separation of the races supported at all levels of government.

An area that may be of particular interest to readers is in the very last section of the book.  Here, the author answers frequently asked questions about his research and conclusions.  Many questions were about his research and the historical context (“Why did leaders whom we consider liberal promote segregationist policies?” and “How can I remove a restrictive covenant from my deed?”), but other questions are more provocative, and unfortunately, very familiar: “Don’t Black people have to take responsibilities for their own lives? Isn’t the real reason why [they] can’t escape the ghetto is that so many are single mothers who can’t or don’t raise their children properly?” His answers to these questions are thoughtful and well-reasoned, and one of the many reasons why you should read this book.

If you are interested in seeing how these restrictive covenants have been applied closer to home, the University of Minnesota project, Mapping Prejudice is an interactive map of Minneapolis that displays properties with racially restrictive language in the property deeds. The time-lapse map shows the gradual increase of properties with restrictive covenants from 1910-1955, and an interactive map allows the user to zoom in on specific lots and see the actual language included on the deed. The project is the first-ever comprehensive visualization of racial covenants for an American city.

Both of these books can be borrowed from the Ramsey County Law Library.  Hope to see you soon!

Khalil Gibran Muhammad, The Condemnation of Blackness: Race, crime, and the making of modern urban America, Cambridge: Harvard University Press, 2019.

Richard Rothstein, The Color of Law: A forgotten history of how our government segregated America, New York: Liveright Publishing Corporation, 2017.




It Takes Moral Courage to Do the Work

So you want to talk about race by Ijeoma Oluo  and The Myth of Race: The Reality of Racism:  Critical Essays by Mahmoud El-Kati

So you want to talk about race by Ijeoma Oluo and The Myth of Race: The Reality of Racism: Critical Essays by Mahmoud El-Kati


So You Want to Talk about Race, by Ijeoma Oluo (Seal Press, 2019)

Ijeoma Oluo directly challenges white people in this commendable book about racism.  She offers a clear discussion of race from a Black perspective.  She also looks beyond race and the factors that contribute to inequality—what race looks like in the context of dominant white society and how we are all products of a racialized society.  This, states Uluo, “affects everything we bring to our interactions.”  She describes how ineffectively white people perceive how Black people are impacted personally, economically, and politically by a racist society.  Oluo personalizes her experience with examples that offer clear understanding of racist behavior.  With a specific chapter for white people entitled “I Just Got Called a Racist, What Do I do Now?” Oluo’s simple response is “do the work.”  At the same time, she offers concise explanations that foster change and understanding.

The Myth of Race: The Reality of Racism:  Critical Essays, by Mahmoud El-Kati (Papyrus Publishing, 2014)

In his short book of essays, author Mahmoud El-Kati, a former history professor at Macalester College, states that “racism is prejudice plus power.”  This definition offers a platform for action, dialog and the ability to change power relationships.  El-Kati embellishes the definition with historical context (including the origins of white supremacy), theories that explain the deconstruction of “race,” and the idea that “race” is actually a false concept that is legitimized by power.  The power of “race,” under this scenario, sanctions the right of exploitation of one group over another.  El-Kati states that to get rid of “race,” the myth of racism should be a critical part of our educational curricula and a part of teacher training.  He also emphasizes that the myth of race cannot be solved “unless there is a healthy dose of the scarcest commodity in America — moral courage.”

These books are available at the Ramsey County Law Library.



Two views on racism

Kendi-How to be an antiracist

When we say that racism is systemic, it is to say that it is so embedded into our culture that we aren’t aware that it is there.  That is how Ibram X. Kendi starts off his book, How to be an Antiracist.  In the forward, he describes how his self-doubt and confidence was so low that he had only applied to two colleges so he’d only have to deal with two rejection letters.  (He was accepted by both.)  Later, as he looked back at his life, he wondered if he should have taken more history classes and paid more attention when he was growing up.   One moment stands out:  He recalls with chagrin that he was a young, Black, high school student presenting at a Martin Luther King, Jr. speech contest.  The irony of the moment was that he was representing his high school that was named after General Stonewall Jackson, legendary Confederate General.

Kendi combines personal stories, historic events, and snippets from well-known authors to illustrate the point that it isn’t enough to not be a racist:  One must strive to be an anti-racist.  He explains:

What’s the problem with being “not racist”?  It is a claim that signifies neutrality: “I am not a racist, but neither am I aggressively against racism.”  But there is no neutrality in the racism struggle.  The opposite of “racist” isn’t “not racist.”  It is “antiracist.”

As Kendi goes through different chapters of the book, he shows how racism is embedded into all facets of our culture.  Assumptions and judgments about people who are not like ourselves are part of everyone’s identity, he writes, even his own.  In a chapter on sexuality, he confronts his own assumptions he had about gay men when he discovered his best friend’s behavior didn’t match the stereotypical gay male behaviors he had learned and expected.  To save his friendship, he vowed to change.

This book is compelling because of the deft way Kendi weaves his personal stories and revelations with historical references and current events.  Yet, in spite of all the ways racism is discussed in the book, it ends optimistically.  In discovering that he had stage 4 colon cancer, he quickly sees the parallel to systemic racism today:

I have cancer.  The most serious stage.  Cancer is likely to kill me.  I can survive cancer against all odds.

My society has racism.  The most serious stage.  Racism is likely to kill my society.  My society can survive cancer against all odds. 

Aggressive treatment, surgery, chemotherapy, all were used and yes, he did survive.  He had the help and support of surgeons, pathologists, and his family.  He asks, “What if we treated racism like we do cancer?”  The lesson is that there isn’t one method to combat racism.  Ending racism isn’t just one person’s fight; everyone must contribute to the effort.   And if you are going to fight racism, you can’t just not be a racist.  Don’t be neutral, be an antiracist.

Coates-Between the world and me

In contrast, Ta-Nehisi Coates work, Between the World and Me, is a deeply personal letter to his teen-aged son.  In this narrative, Coates addresses the reality of being a Black man in the United States.  This book is grim, as he describes his fear and anger growing up in Baltimore and then going to college at Howard.  Much of the book shares his personal history and experiences, while it also reveals his anger and frustration of current events.  He is particularly angry at the persistent murders of so many Black men at the hands of white police officers and other white men for no reason other than they were wearing a hoodie or playing loud music.

The fear and suspicion that he internalized stayed with him and popped up unexpectedly years later during a trip to Paris.  He was walking down the streets after dinner because a new friend wanted to “show him an old building,” and in the back of his mind, he wasn’t sure if this really was an innocuous walk or if he was being led to an ambush in a quiet alley.  But this friend just showed him the historic building, shook his hand, and said good night.

Coates’ letter to his son has a similar theme to Kendi’s book – racism is embedded into American culture.  But in contrast, Coates’ message is for his son, and for other Black readers:  You might not be able to eliminate the racism of others.  It is their struggle, and ultimately others will have to make the change within themselves.  He tells his son that he needs to remember his history, culture, and experiences:

You are growing into consciousness, and my wish for you is that you feel no need to constrict yourself to make other people comfortable.  … I would have you be a conscious citizen of this terrible and beautiful world.

Both books are available at the Ramsey County Law Library.

Ibram X. Kendi, How to be an Antiracist, New York: One World, 2019.

Ta-Nehisi Coates, Between the World and Me, New York: One World, 2015.