ACLU V. ATLASIA

[DieselDogg]

[quote ACLU v. Atlasia

Comes now, DieselDogg, chief counsel for Actors and Cinema Lovers United (ACLU), asking that the Supreme Court grant a writ of certiorari to hear the following case against the government of Atlasia.

In August of this year, the government of Atlasia passed the Fostering Atlasian Cinema Act (the full text of which can be found at the link attached hereto as Exhibit A). This act violates the constitutional rights of many of the actors and movie studios that are members of the ACLU, specifically freedom of speech (Art. 1, Sec. 2 of the Atlasian Constitution), equal protection of law (Art. 1, Sec. 1 of the Atlasian Constitution), and due process of law (Art. 1, Sec. 5 of the Atlasian Constitution). Accordingly, we seek the Court to strike down this unconstitutional law.

Claim 1: Freedom of speech

Of specific importance to this claim is Section 3 of that act, which is as follows:

Section 3: Ethical Filmmaking and Cultural Authenticity

3.1 Ethical Casting and Representation:

a) Encourage casting practices that prioritize the authentic representation of characters, cultures, and experiences.

b) Require that non-Atlasian settings and foreign cultures be portrayed by actors, experts, and crewmembers from those respective backgrounds, ensuring cultural context and accuracy.

3.2 Filming in Foreign Languages:

a) Encourage filmmakers to produce films in the language spoken in the setting of the story.

b) Provide incentives and resources for filmmakers to hire linguists and cultural consultants to ensure linguistic and cultural authenticity.

This section unconstitutionally violates the free speech rights of actors by seemingly prohibiting movies that cast Atlasian actors as fictional characters who are scripted with foreign backgrounds that do not correlate with the background of the actors. That is blatant censorship of free speech. Actors have freedom of speech, including the freedom to speak on camera during a performance while making a movie in which they are acting as someone else. This bill would make classics like Ben Hur, Spartacus, the Passion of the Christ, and Gangs of New York illegal if made today, as each feature domestic actors acting as characters with foreign backgrounds.

Preferences and thus implied discrimination is also conditioned on the language used in the film. Since this censorship law only applies to films about foreign backgrounds but not domestic backgrounds, as well as films featuring foreign languages as opposed to English, this is textbook content discrimination and strict scrutiny applies. See Reed v. Town of Gilbert, 576 U.S. 155 (2015). This law fails strict scrutiny, since ensuring accurate cultural context in movies is not a compelling state interest and this law is not the least restrictive means of achieving this end.


Claim 2: Equal Protection

Of specific importance to this claim is Section 3 of that act, which is again as follows:

Section 3: Ethical Filmmaking and Cultural Authenticity

3.1 Ethical Casting and Representation:

a) Encourage casting practices that prioritize the authentic representation of characters, cultures, and experiences.

b) Require that non-Atlasian settings and foreign cultures be portrayed by actors, experts, and crewmembers from those respective backgrounds, ensuring cultural context and accuracy.

3.2 Filming in Foreign Languages:

a) Encourage filmmakers to produce films in the language spoken in the setting of the story.

b) Provide incentives and resources for filmmakers to hire linguists and cultural consultants to ensure linguistic and cultural authenticity.

This unconstitutionally violates the equal protection of Atlasian actors as a law is being applied against them but is not similarly applied to foreign actors. Ditto for foreign language speakers vs English speakers. This is a textbook equal protection violation because the sole determining factor of whether the restriction applies is the nationality, ethnicity, or language of the actor or movie speech. The same strict scrutiny analysis applies, and has not been met by Atlasia.


Claim 3: Due Process

Finally, the entire bill violates the due process rights of studios, directors, actors, and others involved in film making by being written unconstitutionally vague such that persons cannot reasonably be able to conform their behavior to the law to avoid criminal penalties. The Constitution requires that any law be sufficiently clear and not vague so that persons can reasonably be able to conform their behavior to the law to avoid criminal penalties. See Connally v. General Construction Co., 269 U.S. 385 (1926).

The entire law at issue however violates this Constitutional principle. For starters, there are only two (2) complete sentences in the entire law, and neither of those perform any clear operative exercise of power. Every subsection begins with an inoperative collection of words that does not form a complete sentence or clear thought, let alone a clear exercise of legislative power. The law is at best a glorified outline that was never reduced into actual, legal text. For example, lets look at Subsection 2.1:

a) Establish guidelines for standard contracts that outline the rights, compensation, and working conditions of actors, screenwriters, and crewmembers.

b) Require production companies to provide timely and fair payment for services rendered.

c) Enforce penalties for non-compliance with contractual obligations, including fines, mandatory restitution of unpaid wages, and suspension or revocation of production licenses.

Notice, none of these are complete sentences or complete thoughts. I haven't clipped anything out, this is the direct text of the law. In (a) it is not established who will "establish" the vague guidelines for contracts or who will be subject to the "guidelines". In (b) it is not established who will "require" production companies to abide by the clause or what "timely and fair payment" means in this context/ who decides what is timely and fair. In (c) it is not established who will "enforce" purported penalties, the scope of potential "fines", or what a "production license" even is. None of these clauses are complete sentences or complete thoughts. None of them are clear exercises of legislative power. None of them are sufficiently fleshed out and clear to allow persons to comply with them. All of them give unfettered discretion to law enforcement to decide when to enforce or not enforce. This is a textbook violation of Constitutional due process protections against vague laws. See Kolender v. Lawson, 461 U.S. 352 (1983).

And this is only a single subsection. Every single clause in this law is similarly written in this poor, grammatically incorrect, vague, indecipherable, arbitrary manner. Every one. It is impossible for anyone to read this law and know what they need to do to avoid violating the law. I am willing to go through each subsection to show this. Thus, the entire law is unconstitutionally vague, unenforceable, and resultingly void.


Conclusion

The Fostering Atlasian Cinema Act is indisputedly unconstitutional by violating the free speech, equal protection, and due process rights of ACLU members. It censors speech on the basis of content without satisfying strict scrutiny, it discriminates on the basis of alienage, ethnicity, and language, and it is so poorly written that the entire law is void for vagueness as without complete sentences Atlasian citizens cannot reasonably be expected to conform to its requirements and arbitrary discretion is given to the government in deciding against whom it is to be enforced.

I do not know why such an unconstitutional law was passed. My guess is a sponsor illegally had ChatGPT spit out a bunch of words and was too lazy to format them into actual, operative sentences, then the floor leader shamefully pushed through the bill without adequate debate for political reasons, and then a bunch of lazy Senators voted for it without bothering to read it. Regardless of the reasons, the law is undeniably unconstitutional as adopted, and must be struck down. I thus ask for certiorari so that this blight on the nation can be excised. Thank you.

- DieselDogg, ACLU Counsel

Exhibit A:

https://talkelections.org/FORUM/index.php?topic=558713.msg9157709#msg9157709

[/quote]

[Associate Justice PiT]

     This has been seen.

[Associate Justice PiT]

     The Court grants cert on claim 1 only. The petitioner has until 11:59 PM EDT on Friday, November 3rd to file a brief. The respondent on behalf of the Government of the Republic of Atlasia has until Tuesday, November 7th to file the response brief.

[DieselDogg]

Honorable justices,

The Fostering Atlasian Cinema [Act] violates the constitutional rights of ACLU members and must be struck down as unconstitutional. Of particular relevance is Section 3.1(b) which reads:

b) Require that non-Atlasian settings and foreign cultures be portrayed by actors, experts, and crewmembers from those respective backgrounds, ensuring cultural context and accuracy. [Sic]

In addition to what was argued in my Petition for Cert, I offer the following argument:

Freedom of Speech

The Atlasian Bill of Rights includes freedom of speech. This Court has previously held that when interpreting a clause in the Atlasian Constitution that originated from the U.S. Constitution, U.S. Supreme Court precedent is presumptively binding, absent subsequent changes made in game. See PoliticsFan v. South (2020).

It is well established that the constitutionally-protected right to engage in free speech includes speech made as part of a non-obscene artistic performance, so therefore actors have a right to perform even if they are portraying a fictional character with different scripted life experiences than the actor. As confirmed by the U.S. Supreme Court: "An actor, like everyone else in our country, enjoys a constitutional right to freedom of speech ..." Schacht v. U.S., 398 U.S. 58 (1970). This is no less the case when the performance is recorded and reduced to film. As confirmed by the U.S. Supreme Court: "Expression by means of motion pictures is included within the free speech and free press guaranty of the First and Fourteenth Amendments. It cannot be doubted that motion pictures are a significant medium for the communication of ideas. Their importance as an organ of public opinion is not lessened by the fact that they are designed to entertain as well as to inform." Joseph Burstyn, Inc. v. Wilson, 343 U.S. 495 (1952). This right extends not just to actors but to persons involved in making the film as well. As confirmed by the U.S. Supreme Court: "That the production, distribution and exhibition of motion pictures is a large-scale business conducted for private profit does not prevent motion pictures from being a form of expression whose liberty is safeguarded by the First Amendment." Id. It is thus beyond dispute that the federal law at issue here restricts constitutionally-protected speech.

Since the law restricts films about "non-Atlasian settings and foreign cultures" but not films about Atlasian settings or domestic cultures, the law has engaged in content discrimination. According to the U.S. Supreme Court: "A content-based law or regulation discriminates against speech based on the substance of what it communicates." Reed v. Town of Gilbert, 576 U.S. 155 (2015). A law that discriminates against speech based on content is facially unconstitutional unless the law survives strict scrutiny analysis. According to the U.S. Supreme Court, "A law that is content-based on its face is subject to strict scrutiny regardless of benign motive, content-neutral justification, or lack of animus toward the ideas contained." Id. According to the U.S. Supreme Court, strict scrutiny requires "... a showing that the regulation is necessary to serve a compelling state interest and is narrowly drawn to achieve that end." Simon & Schuster, Inc. v. Members of N. Y. State Crime Victims Bd., 502 U. S. 105, (1991). According to the U.S. Supreme Court, a law is only narrowly drawn if it is the "... least restrictive means possible of achieving ... the compelling state interest." McCutcheon v. FEC, 572 U.S. 185 (2014).

The law fails strict scrutiny

The law at question in this case fails strict scrutiny because the purpose of the law is not a compelling state interest and is not the least restrictive means of achieving its purpose. According to the U.S. Supreme Court, "A government interest is compelling if it is essential or necessary rather than a matter of choice, preference, or discretion." Palmore v. Sidoti, 466 U.S. 429 (1984). The U.S. Supreme Court has recognized that protecting the public health and safety, when lives are at risk, as a compelling state interest, but never something as trivial as the law at issue in this case. There is no purpose statement in the Fostering Atlasian Cinema [Act], so we have to look at the text of the law to determine its purpose. Given that the law is largely unreadable due to the lack of sentences and shamefully poor grammar, determining a purpose from the crude text is not easy. Section 3.1(a) immediately preceding the racist ban on acting, reads:

Encourage casting practices that prioritize the authentic representation of characters, cultures, and experiences.[sic]

Presumably then the purpose of the law is the promotion of diversity in artistic performances. This absolutely is not a compelling state interest and thus the law fails strict scrutiny. Even assuming arguendo that there is a compelling state interest, this law is not the least restrictive means of achieving that interest. This law seeks to promote diversity by prohibiting persons from acting in or producing films about different cultures. Rather than censoring this speech however, the government could instead accomplish its goals by merely requiring a disclaimer about the actor's background in the credits, or by promoting information about the films, or by directly sponsoring the films it wants. It is painfully obvious that the law in question is not the least restrictive means of promotimg diverse films; therefore again this law fails strict scrutiny.

Conclusion

The Fostering Atlasian Cinema [Act] is unconstitutional because it violates freedom of speech by facially censoring private speech on the basis of content, and is not the least restrictive means of achieving a compelling state interest. Thus, it is imperative that the Court grant the relief requested by ACLU in its Petition and strike down the law as unconstitutional.

This law is a disgrace. It is a testament to the incompetence of the Peace Party that would allow a blatantly unconstitutional law like this pass without a single thought. This is what happens when you let a non-native English speaker use robots to spam dumb bills that don't even contain complete sentences. This is what happens when you let opportunistic PPTs push through votes without adequate debate. This is what happens when you have party drones as Senators who rubber stamp whatever their team introduces. This is what happens when you have an absentee President who puts in minimal effort at best.

For the constitution and free speech to prevail, the Fostering Atlasian Cinema [Act] must fall.

Thank you.

- DieselDogg
Chief Counsel, ACLU

[Associate Justice PiT]

     Sorry for the delay in handling this case. I've tried to get in touch with the Attorney General of the Republic of Atlasia to file a response, which has met with limited success. I will give the Republic of Atlasia until 11:59 PM EST on Wednesday, December 6th to file a response brief or formally request an extension. Absent a satisfactory response the case will proceed regardless.

[Associate Justice PiT]

     Acting Attorney General John Dule has informed me that he will be delayed in submitting a brief on account of finals.

[Associate Justice PiT]

     It's kind of a wonky time for the court, but it looks like we are back on track and I don't want to delay things any further. The respondent should have a brief ready for us by 11:59 PM EST on Saturday, 12/30. I'll be off with the New Year's celebration, but if there isn't one in the New Year we can proceed without an official response.

[John Dule]

Respondent Brief

Honorable Judges,

On behalf of the government of Atlasia, I, Acting Attorney General John Dule, submit this brief in response to the arguments outlined in petitioner’s brief. There are three separate clauses of the challenged law-- 3.1(b), 3.2(a), and 3.2(b). This response will first summarize the state's First Amendment argument and then apply it to each of these sections.

I. Freedom of Speech

The First Amendment of the Atlasian Constitution holds that the state shall make no law "abridging the freedom of speech, or of the press." Laws burdening freedom of speech must serve a compelling state interest and be narrowly tailored to achieve that goal in order to satisfy strict scrutiny. Laws incidentally burdening speech by placing time, place, or manner restrictions on the circumstances of the speech are held to a lower standard, as they do not censor the content of speech.

When analyzing a First Amendment claim, it is crucial to engage with the intent of the law. The purpose of the First Amendment is to protect individual expression from censorship or silencing by government interference. This protects speech that is critical of the government, but also many other kinds of expressive speech-- arguing for political perspectives, promoting or criticizing religious/philosophical views, performing comedy, etc.

A consistent through line in all of these examples is that the individual whose speech is protected is the individual who holds the beliefs and thus authors the communicative speech. A hypothetical: If a political activist wishes to speak on a subject, she is entitled to do so. She is also free to hire a surrogate to speak for her if she so desires. However, if the state enacts employment qualifications for that surrogate (age requirements, for example), it does not burden the surrogate's free speech rights. The surrogate is an employee of the activist-- his job is to convey the activist's views, not his own. While it is true that the surrogate's choice to convey the activist's views is itself expressive, laws burdening the hiring of the surrogate do not censor the content of the speech-- they merely regulate the manner in which it is expressed by limiting the class of individuals the activist may hire to express it.

II. The 3.1(b) Claim

Bearing in mind this analysis of the First Amendment, the court should reject the petitioner's challenge of 3.1(b). The law in question places a minor burden on speech in Atlasian cultural products, and does so in such a way that passes strict scrutiny.

Section 3.1(b) of the Fostering Atlasian Cinema Act requires that "non-Atlasian settings and foreign cultures be portrayed by actors, experts, and crewmembers from those respective backgrounds, ensuring cultural context and accuracy." In such a case, actors and other creative contributors are hired by screenwriters/directors (much in the same way the surrogate is hired by the activist) to convey speech that is written for them by others. Placing limitations on the hiring process for individuals who are paid to convey speech does place a burden on speech-- however, it regulates the manner in which the speech is conveyed, not the speech's content. The writers of Atlasia's plays, films, and TV series are still permitted to convey whatever substantive ideas they wish in their writing. This law merely restricts the range of individuals they may hire to convey it. In this sense, the Act is best construed as a hiring law, not a direct constriction on the content of speech.

Because the First Amendment rights of writers/directors are incidentally burdened by a law restricting those they may hire to convey their speech, the court will likely nonetheless find that strict scrutiny applies. Even so, the law passes this level of analysis. The government has two compelling interests in enacting this law: (1) Ensuring factual accuracy in depictions of other cultures, and (2) Preventing the unintentional proliferation of harmful stereotypes in media. Atlasia has a lengthy and sad history of racism that this court need not delve into at this time, with citizens like Bronz and Dr. Scholl routinely writing racist screeds. This law was passed in order to rectify this painful past by providing cultural creators with the resources to accurately depict the cultures about which they choose to write. The state has a compelling interest in ensuring that Atlasian media does not accidentally depict age-old stereotypes or inaccuracies about other cultures.

The petitioner's brief argues that the law is discriminatory and preferential, as it applies only to productions concerning "non-Atlasian settings and foreign cultures." However, it is only in productions set in other cultures where the state's compelling interest (preventing unintentionally inaccurate depictions of foreign cultures) applies. Domestic Atlasian productions of domestic Atlasian cultures will always have Atlasian citizens involved in their production to provide information regarding the accuracy of their culture's depiction. The state has limited the application of its law to situations where the risk it seeks to minimize (unintentionally inaccurate cultural depictions) is actually present. This is not preferential; rather, it is a way to narrowly tailor the law in question to situations in which the harm it remedies has the potential to arise.

It is crucial to understand that this law's purpose is to prevent the unintentional proliferation of stereotypes or factual inaccuracies in media-- factual errors that would accidentally occur in media if not for the presence of cultural advisors on-set. If an Atlasian writer still wishes to write a television series depicting (for example) Albanians in a negative light, they are free to do so. Such a script may include any number of harmful Albanian stereotypes, such as associations with sex trafficking, car theft, or general lawlessness. All this law requires is that those stereotypical characters be portrayed by actual members of the culture in question.

The purpose here is to provide writers/directors with knowledgeable members of the culture in question who can provide them with the facts they need to depict the culture accurately. If the writer/director still wishes to include inaccuracies or stereotypes in his work, he is free to do so. Intentional speech-- the type of speech protected by the First Amendment-- is not being censored here. The law's sole effect is to provide writers/directors with access to accurate information regarding the cultures they depict. The final decision on whether to act upon that information still lies with the writer/director. Thus, the content of their speech is neither being censored nor significantly burdened.

If the government of Atlasia had enacted a law restricting the actual substance of what writers/directors are permitted to include in their works, then this would directly burden the content of creative speech. However, this law merely regulates the hiring of actors-- the conduit through which the writer conveys his or her ideas. It is thus highly tailored to fit the goal of this law: providing on-set experts to ensure that writers and directors have access to information about inaccurate stereotypes they may have accidentally included in their work.

For these reasons, the law passes strict scrutiny and should be upheld.

III. The 3.2 Claim; Severability

In addition to his challenge to Section 3.1(b) of the Act, the petitioner also challenges sections 3.2(a) and (b). These sections of the Act "Encourage filmmakers to produce films in the language spoken in the setting of the story" and "Provide incentives and resources for filmmakers to hire linguists and cultural consultants to ensure linguistic and cultural authenticity," respectively. These laws establish no concrete requirements for writers, directors, or actors, and thus place no burden on their freedom of speech.

If the petitioner cannot identify a situation in which a filmmaker suffered a harm as a result of these laws, the claim should be dismissed. The irreducible constitutional minimum of standing requires that a harm occur that the court can then rectify. Here there is no identifiable harm, as the state has enacted no penalty for filmmakers who choose not to tell stories using the language of their chosen setting.

The petitioner may argue that any subsidies given to accurate cultural productions under the Act are preferential, as they unfairly subsidize linguistically accurate productions. However, under this logic all government art subsidies could be considered preferential. Under National Endowment for the Arts v. Finley (1998), the government may take certain basic standards (such as cultural respectfulness) into account when choosing how to allocate funding for art subsidies. Such decisions by the government do not violate the First Amendment.

Finally, if the Court finds that Section 3.1(b) of the Act is unconstitutional, it should find that it is severable from the incentive framework created in Section 3.2. If part of a statute is found to be unconstitutional, the Court must decide whether that portion is severable from the rest of the statute. A portion of a statute is only severable if the remaining valid parts of the statute can stand alone. If an unconstitutional section of a statute is unseverable, the Court will invalidate the entire statute. In this case, Section 3.2 is independent from Section 3.1(b), and none of its clauses are contingent upon 3.1(b)'s requirements. The Court should find the two sections severable in event of a finding that 3.1(b) is unconstitutional.

IV. Conclusion

In conclusion, the petitioner's challenge to the Act overstates its effects. The Act does not penalize or restrict the content of any speech, nor does it regulate any type of art differently from another without a clearly identifiable purpose. The Act merely requires that artists choosing to depict a particular culture hire individuals who are uniquely qualified to provide information regarding the accuracy (or lack thereof) of that culture's depiction. The Act does not require filmmakers to act on that information. Its purpose is to provide them with the opportunity and resources to rectify any factual or stereotypical errors they may have accidentally made in their work-- in no way does it require them to alter the substance of the message or story they wish to convey.

[ilikeverin]

For the respondent:

1. The law applies to "actors, experts, and crewmembers". Which crewmembers would need to be of a specific background in order to meet the government purposes that you set out? To pick an example with a funny-sounding name: how about dolly grips?

2. Would "non-Atlasian" cultures include cultures that have a long history of contact with Atlasia - say, Canada, or the UK?

3. You have said that limiting the protections of the law to "non-Atlasian" cultures is a way to ensure that "the risk [the law] seeks to minimize (unintentionally inaccurate cultural depictions) is actually present". Does that imply that Atlasian filmmakers cannot produce (or, at least, are far less likely to produce) inaccurate portrayals of Atlasian cultures? To co-opt your Albanian example... this law would prevent inaccurate cultural depictions of Albanian culture, but not of Albanian-Atlasian culture. Is there ever any risk of inaccurate cultural depictions of cultural groups that exist in Atlasia?

[John Dule]

Thank you for the questions, your honor. My apologies for the delay in replying to this. If any other justices have questions, feel free to send me a private message to alert me that you've posted here.

I'll address these point-by-point.

For the respondent:

1. The law applies to "actors, experts, and crewmembers". Which crewmembers would need to be of a specific background in order to meet the government purposes that you set out? To pick an example with a funny-sounding name: how about dolly grips?

Here the court should invoke the longstanding legal principle of Noscitur a Sociis: "It is known from its associates." Under this doctrine, words may be imbued with additional meaning by the words accompanying them. If words are joined together in a list, they should be given a meaning that is consistent with the list. Here, the word "crewmembers" is included alongside "experts" and "actors"-- positions on a film set that have creative control over the film's content, not merely its form. While dolly grips, key grips, and other members of a cinematography crew may make creative decisions, they are not engaged in decisionmaking regarding the elements of the film that are relevant to the accuracy of cultural depiction. A crewmember who might have such creative control is, for example, a costume designer.

A related legal principle relevant here is Ejusdem Generis: "Of the same kind or nature." When general words follow specific words in a statutory enumeration, the general words are construed to embrace only objects similar in nature to those specific ones enumerated. Here, the general term "crewmembers" should be construed to embrace only those crewmembers similar in nature to the specific categories already enumerated-- that is, members of the creative team with actual creative control over the film's content.

In this case, we would ask the court to apply these principles so as to construe the word "crewmembers" narrowly, and to look to the purpose and intent of the legislature in enacting this law. The purpose of this statute is to ensure accurate cultural depictions of non-Atlasian cultures. It should be construed to apply only to those members of a production team (actors, historical and cultural experts, wardrobe and set designers, scriptwriters, etc) who are capable of exercising creative control over the cultural depictions involved in the film.

2. Would "non-Atlasian" cultures include cultures that have a long history of contact with Atlasia - say, Canada, or the UK?

I will get into this further in the next section. The general answer is yes. However, we should note that the statute does not say "Non-Atlasian Cultures"-- it specifies "Non-Atlasian Settings" and "Foreign Cultures" as two independent attributes of the creative work. I'll explain why this distinction is important next.

3. You have said that limiting the protections of the law to "non-Atlasian" cultures is a way to ensure that "the risk [the law] seeks to minimize (unintentionally inaccurate cultural depictions) is actually present". Does that imply that Atlasian filmmakers cannot produce (or, at least, are far less likely to produce) inaccurate portrayals of Atlasian cultures? To co-opt your Albanian example... this law would prevent inaccurate cultural depictions of Albanian culture, but not of Albanian-Atlasian culture. Is there ever any risk of inaccurate cultural depictions of cultural groups that exist in Atlasia?

Let's be as specific as we can. The text of the law uses two distinct phrases: "non-Atlasian settings" and "foreign cultures." Here, the legislature consciously used two different adjectives-- one, "non-Atlasian," and the other, "foreign." The court should not assume that these two adjectives are being used identically; weight must be given to every word the legislature chooses to use.

First, let us examine the phrase "non-Atlasian settings" using the plain English meanings of the words. Oxford defines a "setting" as "the place or type of surroundings where something is positioned or where an event takes place." It is thus a geographic location; an area or place. "Non-Atlasian" simply applies to anything that is not of Atlasia. In conjunction, the meaning of this phrase becomes clear: any geographic setting located outside the physical boundaries of Atlasia. This is congruous with the intent of the statute, which seeks to minimize inaccuracies in depicting cultures with which the average Atlasian may not be familiar. Such cultures generally exist outside the physical boundaries of Atlasia. Here we can draw a bright-line rule: the phrase "non-Atlasian settings" applies exclusively to physical locations outside of Atlasia's borders.

However, the legislature also included the phrase "foreign cultures." It did not say "non-Atlasian cultures," nor did it say "Non-Atlasian settings or cultures." The legislature specifically chose the word "foreign" here, and thus the word must be imbued with a meaning separate from "Non-Atlasian." "Foreign" is defined by Oxford as "Of, from, in, or characteristic of a country or language other than one's own." The range covered by the word "foreign" is thus broader than the range covered by "non-Atlasian." It applies not only to cultures that are outside the physical boundaries of Atlasia, but also to cultural elements that are "characteristic of" a culture that originates from outside Atlasia (yet nonetheless exist within its borders).

In your example, "Albanian-Atlasian" culture is "characteristic of a country or language" that would be foreign to that of an Atlasian director (or other creative). Any Atlasian director would therefore be required to hire creatives on his or her team who would be familiar with Albanian or Albanian-Atlasian culture when depicting such a culture.

[John Dule]

Out of curiosity, am I still the AG or AAG or acting AG or whatever the F? I just want to know if these duties have been passed on to a new administration

[Attorney General & PPT Dwarven Dragon]

Out of curiosity, am I still the AG or AAG or acting AG or whatever the F? I just want to know if these duties have been passed on to a new administration

You are still the Deputy AG, and Acting AG for the cases I am recused on.

With respect to this case, my office continues to fully endorse your brief.