WHY IT MATTERS

A now-viral official video released on Tax Day features Mayor Zohran Mamdani energetically announcing that he has followed through on his Orwellian campaign promise to “tax the rich.” The video, filmed outside a penthouse owned by Ken Griffin, CEO of Citadel Advisors, specifically references him as a target of the new tax scheme. Understandably, the targeted threat in the video sparked a response. Griffin soon announced that he was exploring shifting his company’s primary presence to Florida, a state that “embraces personal freedom and liberty…and the opportunity for people to live the American dream…of earned success.”

Zohran Mamdani’s father, Mahmood Mamdani, is a radical leftist academic who was born in India and raised in Uganda as part of a small, yet wealthy and powerful South Asian minority. This community traced its presence in Africa to the 1890s and controlled 90% of the nation’s wealth by the time Idi Amin seized power via a military coup in 1971. The next year Amin expelled Ugandans of South Asian descent. He gave them 90 days to leave the country and forced them to leave their wealth behind.

The future mayor of New York City was born in Uganda after his father was able to return for several years to teach at a university. The family ultimately settled in New York City. By this time, it was clear that the anti-elite policies of Amin had wreaked economic and social destruction. The expelled families left behind everything:homes, cars, bank accounts, businesses, and farms. The economy collapsed, inflation soared, and Uganda became an international pariah. The elder Mamdani spent several months living in a refugee camp in the United Kingdom.

Zohran Mamdani’s economic policies may be more polite and refined than the brutish and shocking forced expulsion commanded by Amin. But at the heart of each policy is a fundamental similarity. Both leaders targeted the wealthy as a class that is thriving off the oppression of ordinary people. Mamdani has promised that “global elites” who “store their wealth in New York City real estate” are now going to “pay their fare share.” Amin, meanwhile, announced a “deliberate policy…to transfer the economic control of Uganda into the hands of Ugandans.”

The mainstream media is praising Mamdani for “solving the New York City’s budget crisis.” And it may be that the patchwork of a New York state infusion of cash along with exorbitant tax penalties for New York’s wealthy have bridged a $12 billion deficit for a budget that allocates more than $80,000 annually for each homeless person in the city. But Mamdani’s extremist policies will only make New York less hospitable to those seeking economic opportunities that can and do benefit all New Yorkers without the need to fan the flames of class warfare and envy.

THE BOTTOM LINE

Zohran Mamdani’s family experienced firsthand the results of government policies that deliberately target the very people and companies creating jobs, expanding a city’s tax base, and philanthropically contributing to civic life. How ironic and tragic that he failed to learn the lesson that these policies always lead to disaster—and will for New York, too.

The Constitution mandates that congressional seats be apportioned on the basis of population “in such manner as [the states] shall by law direct.” This typically happens every ten years following the census, but President Trump encouraged Texas to redistrict this year to shore up GOP control of several House seats. Other states followed suit. A legal challenge in Louisiana changed the landscape around the country, and another in Virginia rejected a Democrat-friendly electoral map.

1. The number, size, and shape of House districts has evolved since the Founding.

The Constitution was adopted when the population was significantly smaller, and it envisioned one representative for no more than 30,000 people. Congress passed various Apportionment Acts providing guidance for how districts should be drawn as the country grew. Currently, the size of the House is capped at 435 by the Permanent Apportionment Act of 1929. Today, each member of the House represents about 775,000 citizens.

2. Federal law dictates the criteria for how states should draw congressional district lines.

Since the Founding, various court decisions and acts of Congress have set guidelines that states must follow while redistricting. Generally, district lines must be contiguous, compact, and equally populated. These requirements seek to limit gerrymandering, which involves drawing district lines primarily to achieve a political advantage or to disenfranchise particular groups. Generally, claims of gerrymandering are not reviewable in federal court, but states cannot use discriminatory or other unconstitutional criteria to draw district lines.

3. There is no single scheme that states use for redistricting.

For six states with single at-large House districts, redistricting is not an issue. Twenty-five states assign responsibility to their legislatures. Thirteen other states have bipartisan, independent commissions that redraw the district lines. The remaining states have similar commissions that propose new district maps to the legislature. Most states allow redistricting at any time, but several states specifically tie it to a specific year related to the national census when a state may lose or gain seats on the basis of population shifts.

4. Scott v. McDougle, which overturned a new Virginia district map, protected the rights of Virginia voters.

Last month, Virginia voters narrowly approved a referendum adopting a congressional map that would have given Democrats ten of the state’s eleven congressional seats. Last week, the Virginia Supreme Court invalidated the new law because the amendment process had been violated. The legislature must pass an amendment twice, with an intervening election, but the the first vote occurred after ballots had been cast. The court determined that Virginia voters were deprived of considering the referendum when casting their votes. Critics called the decision political and undemocratic, but it preserves the democratic process of amending the Virginia constitution.

5. “Mid-decade” redistricting is controversial for a reason.

Only a few states forbid redistricting at any time other than in immediate response to the national census. Most states have no similar limitations. The current spate of redistricting battles began in Texas and spread to California and beyond with a clear view of controlling power in the House of Representatives. This political maneuvering, however, will probably spark regular battles over mid-decade redistricting that will only destabilize our political system and erode civic trust further.

THE BOTTOM LINE

The race to redistrict ahead of the midterm elections will not only impact the balance of power in the next Congress, but has opened an unnecessary new front in this nation’s bitter political battles. Battles over redistricting can easily become contests to guarantee the outcomes of elections, which will significantly erode the power of voters to select those who represent them in Washington.

RTW’s read: Voting rights in a democracy are sacrosanct, and the U.S. admittedly has a spotty track record on this issue—but gerrymandering voting districts to favor historically disenfranchised groups is not the answer.

THE CASE AT A GLANCE

Case Name: Louisiana v. Callais (consolidated with Press Robinson v. Callais)

Docket No.: No. 24-109, No. 24-110

Status: Decided

Decision Date: April 29, 2026

Vote: 6–3, affirmed and remanded

Author: Alito, writing for the Court

Lower Court: U.S. District Court for the Western District of Louisiana, affirmed

Question Presented: These [consolidated] cases here concern whether Louisiana’s new congressional map is an unconstitutional racial gerrymander.”

VOTE BREAKDOWN

MAJORITY: Alito, Roberts, Thomas, Gorsuch, Kavanaugh, Barrett

CONCURRENCE: Thomas, joined by Gorsuch

DISENT: Kagan, joined by Sotomayor, Jackson

BACKGROUND

After the 2020 U.S. Census, Louisiana’s legislature redrew the state’s six congressional districts. The result was one majority-African American district and five minority-African American districts. Lower courts found this unconstitutional. The legislature redrew the lines a second time, creating two majority-African American districts and prompting fresh litigation by a group of “non-African-American voters” claiming that the new map was racially gerrymandered and violated the 14^th and 15^th Amendments of the Constitution. This time, a panel of judges agreed and ruled that the new configuration violated the Constitution.

WHY THE COURT TOOK THIS CASE

When the Louisiana legislature redrew the map a second time, it intentionally used race as a factor because the lower court had ordered it to redraw the lines in order to create a second majority African-American district. The constitutionally valid use of race in any government determination is vanishingly rare, and the question of whether the Voting Rights Act (VRA) would ever justify the intentional use of race to redraw districts had never been determined by the Supreme Court.

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WHY IT MATTERS

Morris Dees once worked on the gubernatorial campaign of segregationist George Wallace and, as a Montgomery attorney, represented a defendant accused of assaulting the civil rights activists known as the Freedom Riders. Dees’ fee was reportedly paid by the Ku Klux Klan and the White Citizens’ Council. These early endeavors did not foreshadow his 1971 pivot to racial justice champion when he co-founded the Southern Poverty Law Center. Under his leadership, the SPLC earned the moniker “Poverty Palace.”

From the early 1980s, the Southern Poverty Law Center began pursuing litigation against the Ku Klux Klan. These aims were, on their face, laudable. By that time, however, the Klan had declined significantly. Its peak membership was roughly one million but had dwindled to about ten thousand scattered, uneducated members. It was still the hooded face of Civil Rights Movement-era terror in the minds of wealthy donors. As one of Dees’ associates noted, “The only thing easier than beating the Klan in court … was raising money off Klan-fighting from liberals up north.” The Klan’s notoriety, despite its impotence, made it the perfect adversary to drive fundraising.

The SPLC’s most visible project is likely its list of groups and individuals the organization defines as advancing “hate”. The majority legitimately belong on such a list. Others, however, earn their spots merely because they transgress the accepted progressive dogma. Examples include Ayaan Hirsi Ali, founder and executive editor of Restoring the West; the Clarion Project, an anti-Islamist group with Muslim advisory board members; and the Family Research Council, a mainstream Christian organization. This list, like its anti-Klan litigation, is a significant driver of fundraising. And now SPLC appears to be on to its next grift by funding the very hate groups it claims to combat.

On April 21, the U.S. Department of Justice announced that a federal grand jury indicted the SPLC, Dees’ now former organization. (He was fired in 2019 following several allegations of sexual harassment.) The indictment alleges that the organization funneled funds to hate groups through fraudulently created bank accounts. Over $270,000 was reportedly sent to a group integral to the infamous Unite the Right rally in Charlottesville, Virginia, where one person died and 35 others were sent to the hospital after a car rammed into a crowd. The return on this meager investment was more than $80 million. Fundraising soared from $51 million to $133 million year over year after the SPLC-underwritten rally.

The SPLC’s leaders appear to have had a greater interest in the fundraising potential of their mission than actually realizing the organization’s stated goals of decreased hate. They have exposed innocent organizations and individuals to unjustified scrutiny and manipulated donors into supporting their efforts to fight fires they set themselves. This indictment is not likely to destroy the SPLC, but hopefully it will force an end to its worst practices.

THE BOTTOM LINE

Americans are living in a deeply divided society that the SPLC certainly did not create. If there is any hope, however, of bridging the divides of our fragmented culture, bad actors like the SPLC cannot be given any sanction or support.

1. What is Birthright Citizenship?

A nation that adopts birthright citizenship grants citizenship to a person simply because he or she is born within its territory. For that reason, birthright citizenship is also called jus soli, or “right of the soil.” By contrast, most nations grant citizenship based on the citizenship status of a person’s parents, a system known as jus sanguinis. Currently, only about 30 nations have adopted birthright citizenship, and most are in the Americas.

2. What is the current law in the United States?

U.S. citizenship can be obtained in three ways, the most common of which being birth in U.S. territory. A child born outside the United States may also be a citizen if at least one parent is a U.S. citizen. The third path is naturalization, which is available to individuals who were neither born in the United States nor to U.S. citizens, but who lawfully reside in the country and meet specific requirements. Although each pathway has generated debate, birthright citizenship has become the most controversial because U.S. law does not consider the legal status of a child’s parents at the time of birth.

3. Has the Supreme Court ever considered birthright citizenship in the past?

The issue of birthright citizenship took center stage in United States v. Wong Kim Ark (1898). The Court ruled that Wong Kim Ark, born in California to Chinese parents who were lawfully residing there, was a U.S. citizen under the Fourteenth Amendment. The decision was not unanimous; two of the eight justices dissented. Importantly, the case addressed only children born to parents who were in the country legally. The Supreme Court has never directly ruled on the citizenship status of individuals born in the United States to parents who are present unlawfully.

4. What is the core of the argument for and against birthright citizenship?

Proponents of birthright citizenship point to the plain language of the Fourteenth Amendment, which states that “all persons born…in the United States, and subject to the jurisdiction thereof” as establishing an unrestricted right to citizenship by birth. Since the 1898 decision in Wong Kim Ark, lower federal courts have largely adopted this view. Others argue that the requirement of “permanent domicile” is crucial for birthright citizenship claims, a condition they contend is not satisfied by those in the country illegally. The fundamental question is whether children born to parents in the country illegally are entitled to citizenship.

5. What is the position of the Trump administration?

On January 20, 2025, President Trump signed Executive Order 14160, which directs the federal government to end automatic birthright citizenship for children born in the United States unless at least one parent is a U.S. citizen or lawful permanent resident. This executive order prospectively eliminates citizenship claims for children born to parents who are in the country illegally or are present on visas which are not permanent, like student, work, or tourist visas. Multiple lower courts have blocked E.O. 14160.

THE BOTTOM LINE

Every society must define what it means to be a “citizen,” as well as the rights and responsibilities that accompany that status. The outcome of Trump v. Barbara will provide clarity on this issue, but no matter the ruling, that clarity will have a dramatic impact on U.S. immigration law and enforcement.

WHY IT MATTERS

Chief Justice John Marshall warned, “The power to tax is the power to destroy.” Anyone who has reviewed his or her pay stub or tax return can see how much of their own economic prosperity is lost to high rates and a complex, unfair system. Even calculating and paying taxes is so onerous that the total cost that Americans paid for tax compliance reached nearly $464 billion last year.

We often hear, especially during election season, that nearly half of U.S. households pay no taxes. This claim is misleading. Many of these households still pay payroll taxes for Social Security and Medicare, and virtually all pay sales, use, or property taxes. However, there is a meaningful distinction between these taxes and the federal income tax system. Under the current progressive structure, the top 10% of earners pay about 72% of federal income taxes, while the bottom 50% contribute only 3% at an average income tax rate of less than 4%.

One of the most controversial features of the tax code contributing to this disparity is the Earned Income Tax Credit (EITC). This is a refundable credit, meaning that if a taxpayer’s liability is less than the credit, the IRS pays the difference as a refund. In 2025, total EITC payments were nearly $70 billion. The credit is intended to support low-income families, but it presents such significant challenges that even its supporters acknowledge them. It disincentivizes additional earning and saving, is vulnerable to fraud, and has variable eligibility requirements. Beyond these issues, the EITC raises ethical questions about the fairness and legality of transferring wealth from those deemed able to “afford” it to those considered to “need” it. It effectively divides taxpayers into net contributors and net recipients.

“If Americans are to regain confidence in their government, reforming a tax system that is both overly complex and widely perceived as unfair would be a strong place to begin.”

The most outrageous aspect of the U.S. tax system, however, is its inefficiency and waste. While government waste is difficult to measure precisely, Americans have little confidence in how their tax dollars are spent. Many believe that nearly 60% of tax revenue is wasted. Some go further, arguing that “taxation is theft” because it is imposed without consent. Our social contract, however, almost certainly permits taxation to fund legitimate government functions such as maintaining order, enforcing the law, and providing national defense. It tends to be the $9 billion dollars swindled in the Medicaid fraud cases in Minnesota, the $312 million in business loans to children, and the $11 million spent to produce a Middle East version of Sesame Street that tends to raise the ire of American taxpayers.

If the power to tax truly is the power to destroy, it is deeply frustrating to see an unfair and inefficient system limiting Americans’ ability to save, invest, and enjoy the fruits of their labor—often in service of unnecessary programs and, at times, direct wealth transfers. If Americans are to regain confidence in their government, reforming a tax system that is both overly complex and widely perceived as unfair would be a strong place to begin.

THE BOTTOM LINE

Another April 15 has come and gone, and with it, another opportunity to rectify the inequities of the U.S. tax scheme. Americans need to muster the political will to overhaul the system before the stress and strain of a broken system destroys American prosperity.

The core disagreement: The Jewish community is right to invest in Jewish formation, but the rest of us must work to contain violent antisemitism that threatens us all.

WHAT THEY GOT RIGHT

Jewish American columnist Bret Stephens criticized the prevailing strategies for responding to antisemitism. The world’s oldest hatred, he said, is not simply prejudice born of ignorance but a nearly incurable neurosis. Rather than seeking acceptance by ingratiating themselves to others, Jews should focus on Jewish flourishing. Jewish life, he argued, thrives when Jewish identity becomes the central fact of life—the source of meaning and purpose, a spiritual compass, moral anchor, and emotional refuge.

WHERE THEY GO WRONG

Stephens’s proposed solution, however, is only partly right. He argued that fighting antisemitism “is a well-meaning but mostly wasted effort,” and that the millions of dollars devoted to it would be better spent strengthening Jewish life—especially through institutions like Jewish day schools that transmit Jewish values to children. Bari Weiss made a similar point last year at the Tikvah Fund’s Jewish Leadership Conference, arguing that “all of the resources in [the Jewish] community should go” to Jewish day schools. Any community, after all, including the Jewish community, ceases to exist when it stops transmitting its culture and values to the next generation.

But this Jewish equivalent of the Benedict Option, Rod Dreher’s proposal for a more inwardly focused Christian posture toward the world, does not take into account the existential threat that the resurgence of violent antisemitism across the West presents to civilization itself, not to mention Jews and Jewish institutions. It is undoubtedly the responsibility of Jewish parents and community leaders to see to it that Jewish young people learn Jewish history, religion, customs, and culture. That duty cannot be outsourced. But the resurgence of political and cultural forces that would be pleased to see Jewish people, Jewish institutions, and the Jewish state eradicated imperil even the possibility of that important work.

THE REAL STORY

Stephens’s position is incomplete because he overlooks two significant and related aspects of the problem. First, antisemitism is not merely a Jewish problem;. it is a civilizational one, threatening not only Jewish people and institutions but the moral and political foundations of the societies in which it emerges. If the problem is civilizational, the response must be as well. Jewish philanthropists should generously support Jewish formation. But non-Jewish philanthropists should be equally committed to supporting programs confronting antisemitism. This hatred will never disappear entirely; it can only be contained. Like a cancer in the body, the ideal would be to eliminate it. Failing that goal, we must pursue strategies of fearless confrontation to limit and mitigate its corrosive effects.

WHY THIS MATTERS

Antisemitism has always been a canary in the cultural coal mine. Civilizations that tolerate it eventually descend into violence and disorder. The enemies of civilization often begin their assault where they perceive the greatest vulnerability. When antisemitism is tolerated, therefore, it is not only Jews who are endangered. Instead, it signals a broader moral decay that threatens society as a whole. To tolerate antisemitism is to allow a corrosive poison to spread—one that ultimately weakens and undermines the foundations of the West itself.

THE BOTTOM LINE

Restoring the West is a mission requiring the courage to oppose the ideologies that threaten our civilization. Yes, Jewish philanthropists should continue to support the formation and vitality of Jewish life within their communities. But non-Jewish philanthropists must also step forward and invest in the work of confronting antisemitism and preserving the civilizational conditions that make such formation possible.

WHY IT MATTERS

Aleksandar Vucic was first elected to public office in Serbia in 1993. Over the following decades he steadily consolidated power, rising through government ranks to become prime minister and, ultimately, president in 2017. For the people of Serbia, this thirty-year period has been marked by corruption, election irregularities, and a sharp decline in press freedom. A nation with the potential to stabilize the region’s economy and help secure Europe’s borders has instead been constrained by the autocratic and narcissistic control of a single leader.

In response to decades of stagnant progress and empty promises, the United States Congress took the extraordinary step of passing the Western Balkans Democracy and Prosperity Act, signed into law in December 2025 as part of the National Defense Authorization Act. The legislation underscores the region’s strategic importance while detailing the many challenges that have hindered its development. Notably, Serbia is identified as a particularly problematic actor in the region. The act notably includes provisions for imposing sanctions on individuals and organizations. Europe is not typically a breeding ground for sanction-worthy autocrats, but the case for sanctioning Aleksandar Vucic is clear if there is to be any real hope for freedom in Serbia and for the nation to take its place among those advancing liberty and prosperity.

On November 1, 2024, tragedy struck in Novi Sad, Serbia’s second-largest city, when a train station’s concrete canopy collapsed, killing 16 people. Renovations on the Yugoslav-era structure had been completed just months earlier to prepare the station as a hub for a high-speed rail. The collapse was likely the result of corruption that turned a blind eye to poor workmanship. In response, university students took to the streets in protest, and the European Parliament passed a resolution condemning the lack of transparency in Vucic’s government regarding both the construction of the canopy and the investigation into its collapse.

Just a year after the Novi Sad tragedy, another scandal erupted in the capital. Vucic announced plans to invoke a law—intended only for extraordinary circumstances—to remove cultural protections from a parcel of land containing the ruins of government buildings bombed by NATO in 1999. His government then pushed legislation through the National Assembly to enable the site’s redevelopment as a luxury Trump-branded hotel. The plan was ultimately scrapped, and Vucic offered up proxies in an effort to quell the anti-corruption protests that once again rocked the nation.

Serbia currently holds the third-lowest Freedom House score among Council of Europe member states. In just the past few days, another round of elections has been compromised by Vucic’s party, as hundreds of thousands of dollars flowed into just ten contests in small municipalities, overwhelming the modest resources of opposition parties. Unsurprisingly, these developments have sparked renewed anti-Vucic demonstrations, both in the affected municipalities and in the capital.

THE BOTTOM LINE

For the twentieth consecutive year, global freedom has declined. Autocrats like Aleksandar Vucic have been able to operate in the shadows for far too long, impeding the economic, political, and social progress of their nations and regions. Congress has now provided the tools for an appropriate response. It is time to use them to hold Vucic accountable and to send a clear message to autocrats everywhere.

In this conversation, Ayaan lays out exactly why treating Islamist societies as identically beneficial to Western ones isn’t compassionate, democratic, smart, or even trendy—it is actually culturally suicidal. As someone who grew under Islamist rule, she argues that Western traditions of religious, civil, and political liberties are uniquely better to create and sustain human flourishing.

This interview has been edited for clarity and brevity.

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WHY IT MATTERS

Congress has again failed to fund salaries for the TSA agents who are responsible for security screening, thanks to the second government shutdown in just a few months. Meanwhile, wait times at some American airports have approached three hours. The federal takeover of airport security after 9/11 has been controversial from the beginning. Although airports are technically allowed to opt into private security through a federal program, the process for joining the program is not designed for either clarity or efficiency.

The 9/11 attacks made clear that security surrounding air travel needed a major overhaul. Nearly 3,000 Americans died because of the systemic failures of the previous system, after all. But the system that replaced it carries two serious liabilities. We are experiencing the first now: when airport security becomes politicized, it also becomes vulnerable to partisan conflict and political brinkmanship. The second—its troubling ineffectiveness—has not had visible consequences. Or, at least, not yet.

TSA agents are classified as essential government employees, which means they must report to work even during periods of shutdown when they are not being paid. The partial shutdown affecting them stems from political conflicts in Washington over reforms to Customs and Border Protection and Immigration and Customs Enforcement. The consequences are predictable: higher absenteeism, staff shortages, and less efficient operations at airports. Although TSA screening and air travel security have nothing to do with immigration policy, agents are required to work without pay while travelers face significant delays and frustration. These disruptions become convenient political leverage, used by each side to score points against the other.

All of this might be tolerable if government screening were effective. Yet the TSA and the Department of Homeland Security have long resisted transparency. A report leaked in 2017 found TSA screening operations had a failure rate “in the ballpark” of 80 percent, an improvement over a similar 2015 report showing agents failed to detect weapons and explosives 95 percent of the time. The American Federation of Government Employees (AFGE), which represents TSA agents, warns that privatizing airport security would undermine security and accountability. But it is difficult to see how performance could worsen given those failure rates. Meanwhile, the one major American airport using private screening and dozens of major European airports that do generally operate more efficiently and are at least as safe as TSA-staffed airports.

Privatization would not magically eliminate every problem associated with air travel security. But it would do at least two things. First, private firms are more likely to be responsive to the market mechanisms that would improve service and address employee misbehavior. Second, the use of private security companies, even if funded via government grants, would insulate airport security from politicization. The reduction of basic public functions into political weapons rarely harms politicians, but it almost always harms the citizens those systems are meant to serve.

THE BOTTOM LINE

Efficient air travel is a critical part of the global economy and a part of the daily lives of hundreds of thousands of Americans. While there is a place for government oversight of air travel, citizens are best served by a system that produces the most effective results and faces consequences when it fails. After a quarter of a century trying to prove that it is that solution, the TSA has failed.

Trey Dimsdale, Senior Editor of Law & Liberty at Restoring the West, is president of the AHA Foundation. Follow him on X @TreyDimsdale.

WHY IT MATTERS

Equality before the law is the most important innovation of the Anglo-American legal system. This principle allows all citizens to expect fair treatment, just outcomes, and a predictable process. This fragile aspect of the law is most mature in the supposedly classless America, but it is now more vulnerable than ever.

The latest Epstein document release has triggered a wave of collapsed careers and reputations over newly revealed associations. Bill Clinton has been compelled to testify before Congress; Brad Karp is no longer chairman of Paul Weiss; Thomas Pritzker is no longer executive chairman of Hyatt; Sultan Ahmed bin Sulaymen is no longer CEO and chairman of DP World; Peter Mandelson was recalled as the UK Ambassador to the US; and Andrew Mountbatten-Windsor is no longer a prince of the realm. Yet only Mountbatten-Windsor and Mandelson have been arrested—albeit for alleged crimes unrelated to sexual abuse—and no one has been charged. Meanwhile, dozens of Epstein’s victims remain overlooked, marginalized, and waiting for justice. This contrast has severely eroded confidence in a system that is wholly dependent on trust.

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