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April 30, 2018

Changing the politics of housing in California

by Christopher S. Elmendorf, Richard Frank and Darien Shanske

[Cross-posted from the San Francisco Chronicle]

The recent defeat of Senate Bill 827, state Sen. Scott Wiener’s bill allowing 5-story buildings near transit hubs, was an enormous setback for California’s efforts to make housing more affordable while reducing greenhouse gas emissions.

Our state is now in a serious bind.

The only way to make California housing widely affordable is to build a lot more of it. We could do this with Texas-style suburban sprawl — Houston has boomed while remaining affordable — but that would sacrifice the environment. The alternative is to add residential density to existing neighborhoods, near job centers and mass transit.

California picked density over sprawl a decade ago, when it enacted SB375, a commendable law that requires local governments to plan for energy-efficient, transit-oriented development. Yet most city and county planners report that this planning mandate has had “little to no impact on actions by their city.”

The defeat of Wiener’s bill and the so far meager impact of SB375 speak to a deeper truth: California is not going to achieve large-scale, high-density development near transit unless it can change the local politics of housing.

In theory, the state might induce pro-housing political realignments with taxes and subsidies — for example, reallocating property tax revenue to cities that allow dense housing near transit and starving those that don’t. But the quick demise of SB827 suggests that serious penalties are not yet enactable, and subsidies would have to compete with many other General Fund priorities.

We think California can bolster pro-housing forces at the local level without bringing down the hammer or breaking the bank. Consider these alternatives:

1. Leverage “cap and trade” to make the climate consequences of density more transparent — and more tangible. The linchpin of California’s climate change regime is the state’s cap-and-trade program, which puts a statewide ceiling on greenhouse gas emissions from industrial sources and requires emitters to buy allowances for their releases. California could strengthen pro-housing forces in city politics by folding local governments into the cap-and-trade program.

The state would issue a formula estimating the per-dwelling climate impact of new developments, taking account of proximity to transit, size, materials and parking. When a local government permits new housing that’s more climate-efficient than the typical new unit statewide, it would be rewarded with credits to sell in the cap-and-trade market.

This would give pro-housing “YIMBY” activists a green cudgel to wield in local fights over development. Using the state’s formula, proponents could quantify the environmental benefits of each project near transit. Meanwhile, budget-minded city officials would have a fiscal incentive to upzone land near transit. The more transit-friendly development the city permits, the more allowances it would earn to sell in the greenhouse-gas market.

2. Reframe local debates with state reporting of “housing potential” along transit lines. Guardians of the status quo point out that San Francisco has increased its housing production in recent years. But the picture would look quite different if we compared current production to the city’s potential for transit-friendly housing, rather than to the city’s very modest output over the past few decades.

3. Let cities recapture the value they can create by upzoning and streamlined permitting. Opponents of Wiener’s bill called it a giveaway to developers. They had a point. Rezoning a lot from single-family use to five-story apartments increases its value tremendously. Why should the landowner keep all that profit? When local governments control rezoning, they can demand ancillary benefits such as affordable-housing units, infrastructure investments, and more. All this is standard fare — and not just for major rezonings, but for individual projects under the highly discretionary permitting rules that prevail at the local level today.

Yet project-by-project bargaining has major downsides. The uncertainties and delays, and the inefficient medium of exchange (in-kind benefits rather than money), contribute to the result we see all around us: an inadequate supply of new housing. Local officials surely understand this, but right now they have no way to profit from clear, nondiscretionary rules for development.

To encourage development on lands near transit, California should allow cities to share directly in the property value created by upzoning and permitting reforms. Cities could be authorized to impose “special assessments” for upzoning or permit-streamlining on lands within a half-mile of transit — recouping, say, 50 percent to 75 percent of the value added. The state law authorizing such value-recapture assessments would probably need to be approved by referendum vote. But once it is enacted, cities would have a fiscal incentive to supplant project-specific haggling with transparent, value-enhancing and development-enabling rules.

Our state’s housing-affordability crisis was decades in the making, and these solutions won’t work miracles overnight. But if state-mandated upzoning is off the table, and state-mandated planning is ineffectual, we had better start thinking about ways the state might intervene at the root, targeting the local politics of housing.

April 30, 2018

Native American Treaties, Declining Salmon Populations, Broken Promises & Environmental Justice

by Richard Frank

[Cross-posted from Legal Planet]

Pending Washington v. U.S. Supreme Court Decision Offers Hope & Vindication for Tribes, Coastal Fisheries

Truth be told, the U.S. Supreme Court’s 2017-18 Term has been an unsually quiet one for environmental and natural resources law.  Until now.

This week the Supreme Court heard oral arguments in a last-minute addition to the Court’s current docket.  Washington v. United States, No. 17-269, a case the justices only accepted for review in January, looms as the most consequential environmental Supreme Court decision of 2018.  It’s also a fascinating mix of Western American history, Native American law and policy, fisheries protection and environmental justice.

The Washington case has its historical and legal roots in a 164-year old treaty in which the federal government granted Native American tribes in Western Washington permanent fishing rights.  The 1854-55 “Stevens Treaties” (named for the Governor of the then-Washington Territory and Superintendent of Indian Affairs who negotiated the pacts with the tribes on behalf of the federal government) guaranteed the tribes “the right of taking fish, at all usual and accustomed grounds and stations…in common with all citizens of the Territory” in exchange for the tribes’ relinquishment of their claims to 64 million acres of land in Washington in favor of relocation to tribal reservations.

The Washington tribes’ principal concern–both in the mid-nineteenth century and today–has been preserving their access to regional salmon fisheries that have played such a vital role as a tribal food source, means of commercial exchange and for cultural and religious purposes.  As was the case with most nineteenth century government-tribal treaties, the Stevens Treaties turned out to be a bad deal for the Washington tribes.  The fishing rights they’d negotiated were quickly trampled, both by white settlers who relocated in the region and often blocked Native American fishers’ access to the waters of northwest Washington, and by white commercial fishermen who by the end of the 19th century were catching enormous quantities of salmon in the region, leaving precious little fish for tribal members using their more traditional fishing methods and gear.

After Washington was admitted to the Union in 1889, state officials overtly and repeatedly acted to frustrate the tribes’ exercise of their on- and off-reservation fishing rights granted under the Stevens Treaties.  This state of affairs prompted numerous political and legal conflicts in the late 19th and early 20th centuries, including two cases ultimately decided by the Supreme Court–both interpreting the Stevens Treaties in the tribes’ favor.

Fast forward to the late 20th century: the United States, both on its own behalf and as trustee for the Pacific Northwest tribes, sued Washington State in 1970 to address the state-federal/tribal political conflicts and enforce the Stevens Treaties’ fishing clause.  By that time, however, the single greatest threat to tribal fishing rights had become modern technology–specifically, the extensive system of road culverts that the state and its political subdivisions had built to channel rivers and streams underneath the state’s road and highway system.  It’s essentially undisputed that Washington’s road culvert system substantially impedes the migration of salmon both upstream and downstream.  That, in turn, has led to the substantial diminution of salmon populations in western Washington, to the detriment of Native American and white fishers alike.  (It’s also undisputed that technology currently exists by which state and local road builders can avoid this adverse environmental impact by designing road culverts that allow unobstructed fish passage.)

In an earlier phase of this longstanding litigation, a federal district court held–and the Supreme Court ultimately confirmed–that under the Stevens Treaties the tribes have the right to up to 50% of the harvestable fish in the affected region in western Washington.

The latest chapter in this protracted legal saga began in 2001, when the tribes and federal government asked the district court “to enforce a duty upon the State of Washington to refrain from constructing and maintaining culverts under State roads that degrade fish habitat so that adult fish production is reduced.”  Washington State’s legal response to this claim was straightforward: “there is no treaty-based right or duty of fish habitat protection” as asserted by the federal government and tribes.

The district court ruled in favor of the tribes and U.S., concluding that the fishing clause of the Stevens Treaties imposes a duty on Washington State to refrain from building or operating culverts under state roads that hinder fish passage and thereby substantially diminish the number of fish that would otherwise be available for tribal harvest.  The district judge thereafter held a trial to determine an appropriate remedy, eventually issuing a detailed injunction requiring state officials to inventory all state-owned barrier culverts; take immediate steps to retrofit some of the most damaging culverts; and mandating that the remainder be retrofitted at the end of their useful lives.

The Ninth Circuit Court of Appeals affirmed in a lengthy, unanimous opinion authored by Judge William Fletcher.  The Court of Appeals concluded that by building and maintaining a system of barrier culverts, “Washington has violated, and is continuing to violate, its obligation to the Tribes under the Treaties.”  Rejecting the state’s argument that the government’s treaty obligations do not extend to fisheries habitat protection, Judge Fletcher concluded:

"The Indians did no understand the Treaties to promise that they would have access to their usual and accustomed fishing places, but with a qualification that would allow the government to diminish or destroy the fish runs.  Governor Stevens did not make, and the Indians did not understand him to make, such a cynical and disingenuous argument.”

In its successful petition for certiorari, Washington State argues that its obligations under the Treaties do not extend to providing fish-friendly culverts and road projects; that the federal government is equitably estopped from arguing to the contrary by virtue of having approved some of the offending culverts; and that the injunctive relief granted by the lower courts offends federalism principles and imposes an undue financial burden on the state.

The respective legal arguments advanced in the Washington case have a decidedly through-the-looking-glass quality to them: on the one hand, Washington–normally a progressive and environmentally-conscious state–is taking a quite conservative legal and political position usually embraced by the reddest of red states.  Conversely, the Trump Administration and Justice Department have maintained the same aggressive advocacy in favor of the tribes’ fishing rights and fisheries protection that previous administrations have advanced in the Washington litigation.  (The latter comes as a pleasant and most welcome surprise.)

One other interesting jurisprudential footnote to the case: Justice Anthony Kennedy announced he would recuse himself from the Court’s deliberations in the Washington case after he belatedly discovered that in 1985 he’d participated in an earlier phase of the same litigation while serving as a judge on the Ninth Circuit Court of Appeals.  (Kennedy’s recusal would be more consequential if Washington were a “normal” Supreme Court case in which his vote would likely be decisive; however, the justices’ votes in Native American law cases generally don’t track their normal progressive/conservative voting patterns.)

Early press reports indicate that the Supreme Court’s April 18th arguments did not go particularly well for Washington State.  That’s both unsurprising and a very good thing.  The federal government and the tribes have the better of the legal argument in Washington.  The lower federal courts were quite right to reject Washington State’s argument that its construction of environmentally-damaging infrastructure, responsible for devastating fisheries on which the tribal nations depend, is somehow consistent with its longstanding obligations under the Stevens Treaties.  As Ninth Circuit Judge Fletcher aptly noted, that’s a cynical and disingenuous argument indeed, and one that the Supreme Court should reject.

Ultimately, Washington v. United States is a case about environmental justice, and the obligation of government to live up to both the letter and spirit of its fiduciary duty to Native American tribes under longstanding treaties.  For centuries, government has failed to do so.  Hopefully, the Supreme Court’s decision in Washington–due by the end of June–will follow a different and more just legal path.

April 30, 2018

Jesner v. Arab Bank: The Supreme Court Preserves the Possibility of Human Rights Suits Against U.S. Corporations

by William S. Dodge

[Cross-posted from Just Security]

On April 24, the U.S. Supreme Court decided Jesner v. Arab Bank, a case raising the question whether corporations can be sued for human rights violations, including acts of terrorism, under the Alien Tort Statute (ATS). For a preview of the arguments in the case, see here.

Justice Kennedy delivered the judgment of the Court, writing a broad and rambling opinion that might have foreclosed ATS liability for all corporations. But only Chief Justice Roberts and Justice Thomas joined Kennedy’s opinion in full. Justice Alito and Justice Gorsuch joined only those parts of the opinion that were limited to foreign corporations, and their separate concurring opinions emphasized the differences between ATS suits against foreign defendants and those against U.S. defendants. The four other Justices would have permitted ATS suits against both U.S. and foreign corporations, with Justice Sotomayor writing a devastating dissent on their behalf. So while the Supreme Court dismissed the plaintiffs’ claims against Arab Bank, the question of corporate liability in suits against U.S. corporations remains to be decided.

The ATS gives federal district courts jurisdiction over “any civil action by an alien for a tort only, in violation of the law of nations or a treaty of the United States.” The First Congress passed the ATS in 1789 with the eighteenth century law of nations in mind. But in Sosa v. Alvarez-Machain (2004), the Supreme Court held that federal courts could recognize causes of action under the ATS for violations of modern human rights law that are as generally accepted and specifically defined as the eighteenth century paradigms (infringement of the rights of ambassadors, violations of safe-conducts, and piracy). In Kiobel v. Royal Dutch Petroleum Co. (2013), the Supreme Court applied the presumption against extraterritoriality to ATS causes of action, holding that plaintiffs could only bring suits that “touch and concern” the United States. The plaintiffs in Jesner alleged that Arab Bank, a foreign corporation, had financed terrorist attacks in Israel by funneling money through its New York branch. The Second Circuit dismissed the claims under circuit precedent holding that only natural persons and not corporations can be sued under the ATS.

Framing the International Law Question

Writing only for three in Part II.A, Justice Kennedy seemed to accept the Second Circuit’s framing of the corporate liability question as whether there was a “norm of corporate liability under currently prevailing international law” that would meet the Sosa standard (p. 15). As Justice Sotomayor pointed out in dissent, however, this framing of the question “fundamentally misconceives how international law works” (p. 2). (I should disclose that I wrote the amicus brief of International Law Scholars in Jesner, on which Justice Sotomayor relied in this part of her opinion.)

The dissent correctly observed: “Although international law determines what substantive conduct violates the law of nations, it leaves the specific rules of how to enforce international-law norms and remedy their violations to states, which may act to impose liability collectively through treaties or independently via their domestic legal systems” (p. 3). Thus, Sosa’s requirement of a generally accepted and specifically defined norm of international law refers to norms of “substantive conduct,” not “forms of liability” (pp. 3-4). Because of this distinction, the plurality’s reliance on jurisdictional limits found in the charters of international criminal tribunals (pp. 14-15) was also misplaced, the dissent explained, because it “confuses the substance of international law with how it has been enforced in particular contexts” (p. 8). In other words, limits on jurisdiction are not limits on substantive law. Assuming that the international law prohibition against terrorist financing met the Sosa standard—a question the dissent would have remanded to the Second Circuit to resolve in the first instance—“nothing in international law suggests a corporation may not violate it” (p. 7).

Perhaps because of the power of the dissent, Justices Alito and Gorsuch did not join the part of Justice Kennedy’s opinion claiming that “there is a distinction in international law between corporations and natural persons” (p. 17). And even Justice Kennedy seemed to back away from his own argument in the end, concluding that “the Court need not resolve . . . whether international law imposes liability on corporations” (p. 17-18). This makes Justice Kennedy’s mistaken approach to international law nothing more than dictum in a plurality opinion.

Limiting the Holding to Foreign Corporations

The only analytical parts of Justice Kennedy’s opinion that commanded a majority of the Supreme Court were those invoking separation of powers concerns against creating new causes of action (pp. 18-19) and foreign relations difficulties (pp. 25-27). Significantly each of these parts was expressly limited to suits against foreign corporations. The first concluded with the observation that “absent further action from Congress it would be inappropriate for courts to extend ATS liability to foreign corporations” (p. 19). The second said even more explicitly: “the Court holds that foreign corporations may not be defendants in suits brought under the ATS” (p. 27).

The reasons for this limitation to foreign corporations may be found in the concurring opinions written by Justices Alito and Gorsuch. Justice Alito emphasized the foreign relations implications of suits against foreign corporations: “Creating causes of action under the Alien Tort Statute against foreign corporate defendants would precipitate exactly the sort of diplomatic strife that the law was enacted to prevent” (p. 1). In a footnote, Justice Alito expressly stated, “Because this case involves a foreign corporation, we have no need to reach the question whether an alien may sue a United States corporation under the ATS” (p. 3). He could not have been clearer.

As he telegraphed at oral argument that he might, Justice Gorsuch interpreted the ATS “to require a domestic defendant” (p. 6). Here, Justice Gorsuch largely followed the approach of A.J. Bellia and Brad Clark, which I have previously criticized. But of course, this approach to the ATS does not preclude suits against U.S. corporations for violating the law of nations. Justice Gorsuch explained: “It is one thing for courts to assume the task of creating new causes of action to ensure our citizens abide by the law of nations and avoid reprisals against this country. It is altogether another thing for courts to punish foreign parties for conduct that could not be attributed to the United States and thereby risk reprisals against this country” (p. 13). ATS suits against U.S. corporations clearly fall into the former category.

After the Supreme Court’s 2013 decision in Kiobel, my colleague Anupam Chander observed that the impact of that decision would be to free foreign corporations, but not U.S. corporations, from the risk of being sued under the ATS. In a sense, Jesner simply makes this point explicit.

I do not want to be overly sanguine about the prospects for corporate liability in ATS suits against U.S. corporations. Justice Gorsuch wrote that Sosa’s decision to give the ATS continuing relevance by permitting a limited class of human rights claims to proceed was a mistake (pp. 2-5). Justice Alito agreed (p. 3). And even Justice Kennedy strangely suggested that “there is an argument that a proper application of Sosa would preclude courts from ever recognizing any new causes of action under the ATS” (p. 19)—a position that the majority in Sosa (including Justice Kennedy) expressly rejected. ATS suits against U.S. corporations also face a host of other obstacles, from the fact that such corporations often operate abroad through foreign subsidiaries to the standard for aiding and abetting liability. My point is simply that Jesner does not settle the question of corporate liability for U.S. corporations, and such cases constitute the bulk of litigation against corporations under the ATS. 

April 30, 2018

Opinion analysis: Crime-based removal provision is unconstitutionally vague

by Kevin R. Johnson

[Cross-posted from SCOTUSblog]

In the last few years, the Supreme Court has decided a steady number of criminal-removal cases. In light of the Trump administration’s emphasis on the removal of “criminal aliens,” we will likely see even more criminal-removal cases in the future.

Most of the removal cases that have recently come before the court, including Esquivel-Quintana v. Sessions, which was decided last term, have involved ordinary issues of statutory interpretation and deference to administrative agencies. Sessions v. Dimaya, which the court decided today in a 5-4 ruling, is different. The case began as a constitutional challenge to a criminal-removal provision in the immigration laws, which historically have been almost wholly immune from judicial review. It was originally argued last term, when the court was short-handed after the death of Justice Antonin Scalia, and the justices ordered reargument, suggesting that they were divided on the merits.

An immigrant convicted of an “aggravated felony” under 8 U.S.C. §1101(a)(43) is subject to mandatory removal and is ineligible for most forms of relief from removal. The definition of “aggravated felony” incorporates by reference 18 U.S.C. §16(b). Section 16(b) defines a “crime of violence” to encompass “any … offense that is a felony and that, by its nature, involves a substantial risk that physical force against the person or property of another may be used in the course of committing the offense.”

A lawful immigrant from the Philippines, James Garcia Dimaya has lived in the United States since 1992. He has two residential burglary convictions, neither of which involved violence. Based on the convictions, the immigration court and the Board of Immigration Appeals ordered Dimaya removed from the United States. The U.S. Court of Appeals for the 9th Circuit overturned the BIA’s order, finding that Section 16(b) was unconstitutionally vague. To reach that conclusion, the court relied on Johnson v. United States, in which the Supreme Court, in a 2015 opinion by Scalia, found that the Armed Career Criminal Act’s similarly worded definition of “violent felony” was so vague as to violate the due process clause.

At oral argument last October, the justices appeared to be divided as to whether this case was distinguishable from Johnson. In the end, that question was at the heart of the disagreement between the majority and dissenting justices.

Relying on Johnson, the court, in an opinion by Justice Elena Kagan, joined by Justices Ruth Bader Ginsburg, Stephen Breyer, Sonia Sotomayor and, in large part, Neil Gorsuch, affirmed the 9th Circuit’s ruling that Section 16(b) is unconstitutionally vague. The court began by noting that to determine whether a person’s conduct falls within the ambit of Section 16(b), “courts use a distinctive form of what we have called the categorical approach.” Rather than assessing whether the particular facts of someone’s conduct pose the substantial risk required under the statute, courts consider the overall nature of the offense, and ask “whether ‘the ordinary case’ of an offense poses the requisite risk.” The court went on to conclude that defining the “ordinary case” under the “crime of violence” provision poses the same vagueness and due process problems, including unpredictability and arbitrariness, as those identified in Johnson. As the court summed it up, “Johnson tells us how to resolve this case.  … [N]one of the minor linguistic disparities in the statutes makes any real difference.”

In a section of the opinion not joined by Gorsuch, a plurality of the court rejected the government’s argument that “a less searching form of the void-for-vagueness doctrine applies here than in Johnson because this is not a criminal case.” Citing the 1951 case Jordan v. DeGeorge, the court noted that “we long ago held that the most exacting vagueness standard should apply to removal cases,” because the penalty of deportation is so severe.

Gorsuch concurred in part and concurred in the judgment. He emphasized at the outset that “[v]ague laws invite arbitrary power.” He defended the originalist foundations for vagueness challenges that Justice Clarence Thomas questioned at length in his dissent, tracing the history of those challenges back to Blackstone’s condemnation of vague statutes and the “tradition of courts refusing to apply vague statutes.” He further noted that the concern with vague statutes was not “confined to the most serious offenses like capital crimes.” Addressing the government’s argument that a more lenient standard of review should apply in civil cases, Gorsuch would have gone even further than the plurality. He suggested that provisions of civil laws should be scrutinized closely for vagueness even outside the deportation context: “Why, for example, would due process require Congress to speak more clearly when it seeks to deport a lawfully resident alien than when it wishes to subject a citizen to indefinite civil commitment, strip him of a business license essential to his family’s living, or confiscate his home?”

Chief Justice John Roberts, joined by Justices Anthony Kennedy, Clarence Thomas and Samuel Alito, dissented. Roberts distinguished Johnson, arguing that “the Court too readily dismisses the significant textual distinctions between §16(b) and the ACCA residual clause.” Even under the exacting “standard applicable to criminal laws,” Roberts maintained, “§16(b) is not unconstitutionally vague.” Unlike the ACCA residual clause struck down in Johnson, “[t]he more constrained inquiry required under §16(b)— which asks only whether the offense elements naturally carry with them a risk that the offender will use force in committing the offense—does not itself engender ‘grave uncertainty about how to estimate the risk posed by a crime.’ And the provision’s use of a commonplace substantial risk standard—one not tied to a list of crimes that lack a unifying feature—does not give rise to intolerable ‘uncertainty about how much risk it takes for a crime to qualify.’”

Although he agreed with Roberts’ dissent, Thomas wrote a separate dissent to express “doubt that our practice of striking down statutes as unconstitutionally vague is consistent with the original meaning of the Due Process Clause.” He further questioned the “categorical approach” to review of the crime-based statutes, and he would have found that the statute was not unconstitutionally vague as applied to Dimaya.

In the end, the majority dutifully applied its holding in Johnson to the immigration laws. The court’s holding is consistent with its recent decisions applying routine approaches, including traditional methods of interpretation and doctrines of deference to administrative agencies, to judicial review of the immigration laws. What is different about Sessions v. Dimaya is that it applies the Constitution to the removal grounds of the immigration laws. In that sense, it continues what could be seen as a recent movement by the court toward applying ordinary constitutional norms in the immigration context. At the end of last term, for example, the court in Sessions v. Morales-Santana held that gender distinctions favoring women over men in the derivative citizenship provisions violated the Constitution’s equal protection guarantee. It remains to be seen whether and how far the court will proceed along this path.

An earlier version of this post suggested that Kennedy and Alito joined the part of Thomas’ dissent in which he expresses “doubt that our practice of striking down statutes as unconstitutionally vague is consistent with the original meaning of the Due Process Clause.” Kennedy and Alito joined Thomas’ dissent as to Parts I-C-2, II-A-1 and II-B, but not as to that statement from Thomas’ second paragraph.

April 8, 2018

King Hall Faculty Perform at Annual Aokirama

On Friday, April 6, UC Davis School of Law professors took the stage during the Aokirama (formerly Cardozorama) law school talent show! The student-organized Aokirama, named for the late Professor Keith Aoki, brings together students (and faculty cameos) for a night of skits, talent, and musical performances. One of the biggest hits of the evening was the band Negotiable Instruments, featuring:

  • Professors Angela "Malice Aforethought" Harris, Anupam "Crime Against Humanity" Chander and Madhavi "Patent Infringement"Sunder (faculty vocalists)
  • Professor Rose "Adverse and Hostile" Cuison Villazor (drums)
  • Professor Cappy "Boycott" White (guitar)
  • Professor Carlton "Treason" Larson (piano)   
  • Guest student vocalist, Tyler "So-Not-a-Gunner" Moran (2L)

Professors Lisa Ikemoto and Irene Joe were on stage, as well as Professor Cuison Villazor's daughters.

View the full performance on YouTube

Several King Hall faculty members attended Aokirama 2018