Contents

Appendix 1: Our Sample
Appendix 2: Research Instruments
Appendix 3: Survey Methodology Report

 

Appendix 1: Our Sample

Herein is a description of the various social and institutional dimensions of the states chosen as case studies for this project, inclusive of partisan politics, state agency authority, assessment mandates, and labor and licensure rules for teachers.

Politics and State Oversight

Politically, the nine states selected reflect so-called red, blue, and purple realities (Table A1). Six were carried by Democrats in the 2020 electoral college vote, while three voted Republican. As of August 2024, seven states are governed by trifectas, with a single party controlling the executive office, and two have divided governments. Three states have elected state Boards of Education (AL, CO, TX), four have appointed boards (CT, IA, IL, PA, VA), and one (WA) has a hybrid model.1 Administratively, three (AL, CT, VA) have what policy researchers have classified as state-centric (as opposed to district-centric) modes of governance.2 Without initiating a technical debate about which decisions should be counted as constituting more or less state control, our focus on curriculum means that two state agency roles matter more to us than others: instructional materials adoption and assessment mandates. Two states (AL and TX) specify a role for the state agency in instructional materials adoption, while the other seven leave these decisions to local districts (Table A2).3

 

Table A1: Partisan Politics in Sample States
StateUS Census RegionPartisan Electoral Vote in 2020Partisan Control of State Government (as of August 2024)
Alabama (AL)East South CentralRepublican by more than 15%Republican Trifecta
Colorado (CO)MountainDemocrat by 10% to 15%Democratic Trifecta
Connecticut (CT)New EnglandDemocrat by more than 15%Democratic Trifecta
Illinois (IL)East North CentralDemocrat by more than 15%Democratic Trifecta
Iowa (IA)West North CentralRepublican by 5 to 10%Republican Trifecta
Pennsylvania (PA)Middle AtlanticDemocrat by less than 5%Divided: Governor (D); Senate (R); House (D)
Virginia (VA)SoutheastDemocrat by 10 to 15%Divided: Governor (R); Senate: (D); House: (D)
Texas (TX)West South CentralRepublican by 5 to 10%Republican Trifecta
Washington (WA)PacificDemocrat by more than 15%Democratic Trifecta
Table A2: State Agency Authority in Sample States
StateState Board of EducationEducational Governance ModelState Authority over Instructional Materials
ALElectedState-CentricState Board of Education approves a list of adopted titles that LEAs must choose from
COElectedLocal-CentricState Board prohibited from prescribing textbooks to localities
CTAppointedState-CentricNo role specified
ILAppointedLocal-CentricNo role specified
IAAppointedLocal-CentricNo role specified
PAAppointedLocal-CentricNo role specified
TXElectedLocal-CentricState Board of Education publishes a list of approved titles, but LEAs may choose outside the list
VAAppointedState-CentricState Board of Education publishes a list of approved titles, but LEAs may choose outside the list
WAHybridState-CentricNo role specified

 

Assessment

Currently four of these states (CO, TX, VA, WA) have a mandate for state testing in US history (Table A3). As a proportion of our sample (four of nine), this roughly reflects testing’s footprint on the national landscape (with 21 of 50 states plus DC requiring testing in US history), but our sample also reveals the wide spectrum of accountability contexts that surround assessment.

Table A3: Required US History Assessment in Sample States with State Mandates
StateNumber of AssessmentsLevelInstrument, Scoring, and Extent
CO1High SchoolCommon standardized instrument scored by state agency; spot check of sample districts on three-year cycle
TX2Middle and High SchoolCommon standardized instrument scored by state agency; all students assessed yearly
VA3Primary, Middle, and High SchoolCommon standardized instrument scored by state agency in primary and middle school; instrument options available for high school state-approved instrument; all students assessed yearly
WA1High SchoolState-designed instruments optional; all students assessed every year; scoring conducted locally

 

Texas sits at the top with regard to standardization and stakes, with common US history exams (the STAAR test) in middle and high school. The US history exams are required for student promotion and graduation, a fact that sets Texas apart even from other states with a US history test. Schools are motivated to invest in STAAR test preparation, as results factor into annual accountability scores assigned to schools and districts and used by the Texas Education Agency to rate them, compare them, and assign interventions.4

Virginia has the most state-required testing of US history content, with one Standards of Learning (SOL) test in the primary grades, one in middle school, and an end-of-course exam in high school.5 While SOL tests are tied to the verified credits required for students to graduate, the Virginia Department of Education no longer uses these assessments in their accreditation system for school districts (called “divisions” in Virginia).6 Recent policy changes have expanded local discretion over the format and timing of testing, allowing divisions to use state-designed (but locally scored) performance-based assessments (PBAs) rather than standardized multichoice SOL tests.7

In Washington, classroom-based assessment (CBA) instruments for US history are state designed but administered and scored locally. Schools must affirm that students took a CBA but are not required to use the state-offered instrument, and there are no further reporting or accountability requirements for districts.8 To some, these expectations leave things “murky.”9 As one Washington teacher put it, “CBAs only exist on the form administrators fill out every year.”10

A Colorado Measures of Academic Success (CMAS) assessment in social studies is supposed to be given in all three grade bands (primary, middle, high). It was implemented as a rolling spot check, sampling districts on a three-year cycle, but never attached to any consequences for districts, teachers, or students. Following a systemwide pause and the official elimination of the high school requirement during the COVID-19 pandemic, CMAS social studies is set to resume for primary and middle schools. Legislation to eliminate the social studies testing requirement failed to pass in 2023.11

None of the testing and accountability regimes in the remaining five states have ever included history as a tested area.12 Many of these state assessment instruments, particularly English and language arts assessments, will include nonfiction reading passages that cover or reference social studies subject matter, but they are neither designed nor expected to deliver data related to student learning in history or social studies.

Labor Relations

With administrators and teachers sometimes at odds about what should be taught and assessed—and how prep and class time should be spent—rules governing public sector labor relations carry important consequences for curricular decision-making, with a wide range among our sample states (Table A4). In Alabama and Texas, collective bargaining agreements are prohibited by law.13 Teachers can (and do) join local associations and even affiliates of national unions at high rates in states with “right-to-work” laws, but they exert no leverage over contract terms or working conditions.14 Virginia’s long-standing right-to-work landscape is changing, with a 2020 law allowing localities to authorize collective bargaining for public employees, which five Virginia school boards have now done.15 Colorado has had similar local opt-in rules for public sector collective bargaining since the 1960s, with teachers in 39 of 179 school districts currently working under a collective agreement.16 Meanwhile, Colorado’s school choice laws also limit the reach of unions, with a higher proportion of public school students (13 percent) attending charter schools than in any of our other sample states.17 At the other end of the spectrum, localities in Connecticut, Illinois, Iowa, Pennsylvania, and Washington have a state-mandated duty to bargain collectively if a majority of teachers vote for union representation.18 In Illinois, where public sector workers enjoy the widest scope of bargainable subjects and special constitutional protections, 97 percent of teachers are union members and only a handful of the state’s 853 districts operate without a collective bargaining agreement.19

Table A4: Labor Regulations for Teachers in Sample States
StateCollective BargainingDetails
ALProhibitedn/a
COOpt-in Allowed by Locality21% of districts allow for collective bargaining agreements
CTRequired97% of districts under collective bargaining agreement
ILRequired~97% of districts under collective bargaining agreement
IARequired75% of public school teachers represented by a collective bargaining agreement
PARequired100% of districts under collective bargaining agreement
TXProhibitedElected consultation allowed
VAOpt-in Allowed by Locality4% of districts allow for collective bargaining agreement
WARequired96% of districts under collective bargaining agreement

 

Teacher Licensure

All but one sample state require that teachers pass a test to teach social studies, with Iowa the sole, and recent, exception. Teacher coursework requirements vary with some states requiring specific courses and credit hours and others leaving it up to the teacher preparation programs on college campuses (Table A5). Even in states that do not specify the courses or credit hours a social studies teacher must take, the state-approved teacher preparation programs typically require their graduates to have taken a substantial number of history courses. Among the sample states, state agencies in Texas and Washington are the least specific regarding the number of credit hours required for social studies teachers. In contrast, Virginia’s state agency specifies that teachers complete an approved teacher preparation program in history or social science or earn a BA with various specific course requirements including either a major or 18 semester hours in history, with US, Virginia, and world history specified, as well as a course in state and local government. A 2021 law added African American history to the list, but it is still being rolled out following pandemic delays and changes in gubernatorial administrations. In all nine states, alternative certifications and reciprocal agreements with other states further muddy the history course requirements. Still, the alternative certifications typically link to the same requirements after a preliminary period of approval.20

Table A5: Licensure Requirements for Teachers in Sample States
StateLicensure Requirements
ALPreservice teachers take the ETS Praxis general social studies test. Alabama requires teachers to major in one of the social studies subject areas and to take a course in the teaching of social studies but has not listed requirements specific to history.
COPreservice teachers take the ETS Praxis general social studies test. The Colorado secondary endorsement in social studies requires either 1) a bachelor’s degree in social studies, history, or political science or 2) the completion of coursework that includes 6 semester hours of history and 3 semester hours of social studies methods, in addition to other social science courses.
CTPreservice teachers take the ETS Praxis general social studies test. Connecticut requires a minimum of 9 semester hours in history and other social sciences for the middle school endorsement in history and social studies and 12 for the high school level, with a US history course specified for both endorsements.
ILTeachers must pass the state-designed Illinois Licensure Testing System test in one of the social sciences. They complete a state-approved education program and can meet the course requirement minimum through 18 credit hours in history, political science, or psychology.
IANo test is required for a social studies endorsement. Iowa requires coursework minimums for teachers enrolled in “a regionally accredited college.” For example, the 5–12 Social Sciences-Basic Endorsement requires 9 semester hours each of American history, American government, and world history.
PAPreservice teachers take the ETS Praxis general social studies test. Teachers must complete an approved teacher education program for their initial certification and then they must earn an additional 24 postbaccalaureate credits to get their Level II certification, of which six credits are associated with their certification or professional practice.
TXDepending on grade level, teachers must pass the state-designed Texas Examinations of Educator Standards test in English Language Arts and Reading/Social Studies: Grades 4–8 or Social Studies 7–12. Texas does not stipulate credit hours for its state-approved teacher preparation programs.
VAPre-service teachers take the ETS Praxis general social studies test. Teachers complete an approved teacher preparation program in history or social science or earn a BA with various specific course requirements including either a major or 18 semester hours in history, with US, Virginia, and World History specified, as well as a course in state and local government. A 2021 law added African American history to the list.
WATeachers must pass the state-designed Washington Educator Skills test in either Social Studies, History, or Middle-Level Humanities, depending on the grade level they seek to teach. Washington does not stipulate credit hours for its state-approved teacher preparation programs.

 

Working Conditions

The workload for a typical American teacher varies greatly across locales and states (Table A6). Measured nationally, the average ratio of public school students to teachers in American classrooms comes to 15.5 students per teacher. Among our sample states, teachers experience a wide range of conditions, with the pupil-to-teacher ratio more than 50 percent higher in Alabama than Connecticut. While the average pupil-to-teacher ratio among our sample states showed greater teacher workloads in city and suburb locales, this also varied by state. For example, the highest ratio by state locales is found in the town locales in Alabama (19.7) and the lowest ratio was rural locales in Connecticut (9.9).21

Table A6: Working Conditions in Sample States
StatePupil-to-Teacher Ratio22Total Current Expenditures per Pupil23Teacher-to–Instructional Coordinator Ratio24
AL17.87$10,728742.7*
CO16.26$12,23314.8
CT11.67$22,21614.3
IL13.68$18,52733
IA14.15$12,71413.9
PA13.3$17,82262.8
TX14.78$11,04979.4
VA13.6$13,85610.1
WA17.23$15,61515.3

 

Curricular conditions are also shaped by the level of oversight or direction that teachers receive, which varies from state to state and district to district. The prevalence of instructional coordinators provides a rough proxy for varying degrees of curricular management. Current national average ratios of teachers to instructional coordinators come in at 32 teachers per coordinator. Among sample states, Colorado, Connecticut, Iowa, Virginia, and Washington had more instructional coordinators per teacher compared with the national average, whereas Alabama, Illinois, Pennsylvania, and Texas had fewer. Resources also vary widely across our sample states, with a wide range in the current expenditures per pupil, a number which includes salaries, benefits, purchased services, supplies, tuition and other expenditures not related to capital expenditures.

Peculiar Conditions

As we got to know the teachers, administrators, and curricula across our nine sample states, we quickly learned about other peculiar conditions that influence the facts of history teaching on the ground. In Texas, a long history of assessment and accountability (dating back to 1980) has built a unique set of state agency structures and approaches to curriculum alignment. Texas’s model of self-funded regional education service centers (ESCs) has facilitated the development of a full bundle of TEKS-aligned curriculum in the form of the TEKS Resource System, in use in hundreds of districts across the state.25 In other states, regional offices have a far more limited role in curriculum development, though some area education agencies (AEAs) in Iowa and intermediate units (IUs) in Pennsylvania will staff a social studies position to develop model materials and connect teachers with professional development.26 Pennsylvania and Illinois reflect the highest levels of fragmentation of local educational governance. In much of suburban Chicagoland, elementary and high schools exist as separate governance units, each with their own school board. Pennsylvania’s system is the most loosely aligned among sample states, with course sequencing varying from district to district—the “wild west, man” as one administrator described it.27 In Alabama and Connecticut, public-private institutions have grown alongside the state agency to address certain educational needs. In Alabama, the A+ College Ready program, a public and privately funded statewide educational nonprofit initiated to upgrade student preparation for Advanced Placement classes in math and science, has since expanded to serve subject areas including US history, running three-year competitive grants for professional learning and curricular support for high school and middle school teacher cohorts at the district level.28 In Connecticut, the quasi-public State Educational Resource Center (SERC), begun in the late 1960s with the goal of serving special needs students, now operates in an occasional tandem with the state department of education on a broad mission related to “institutionalized racism and other issues of social justice in schools and districts.”29 SERC’s role in social studies curriculum was most recently enhanced when it was tapped by the state legislature to lead the development of the new Black and Latino studies course curriculum.30 State-specific oddities like these do not always express themselves in curricular terms, but they can shape the character and density of professional networks that assemble around education policy in different states. Organs like SERC in Connecticut or the Texas Curriculum Management Program Cooperative form distinct constituencies for curricular reform, neither employed in local districts nor directly accountable to the state agency.

Appendix 2: Research Instruments

The report’s questionnaires, rubrics, and release forms are available for download as a PDF.

 

Appendix 3: Survey Methodology Report

The survey methodology report, provided by NORC at the University of Chicago, is available for download as a PDF.

 

← ConclusionAcknowledgments→

Notes

  1. Hybrid refers to a mix of elected and appointed members. “Education Governance Dashboard,” Education Commission for the States, accessed June 6, 2024, https://www.ecs.org/education-governance-dashboard/. [↩]
  2. Dara Zeehandelaar and David Griffith, “Schools of Thought: A Taxonomy of American Educational Governance” Thomas B. Fordham Institute, 2015, https://fordhaminstitute.org/national/research/schools-thought-taxonomy-american-education-governance. [↩]
  3. “Response to Information Request,” Education Commission for the States, January 1, 2022, https://www.ecs.org/wp-content/uploads/State-Information-Request_Textbook-Adoption-Policies.pdf. [↩]
  4. “How Accountability Ratings Work,” Texas Education Agency, accessed June 6, 2024, https://tea.texas.gov/texas-schools/accountability/academic-accountability/performance-reporting/how-accountability-ratings-work. [↩]
  5. “Virginia SOL Assessment Program,” Virginia Department of Education, accessed June 6, 2024, www.doe.virginia.gov/teaching-learning-assessment/student-assessment/virginia-sol-assessment-program. [↩]
  6. “School Accreditation,” Virginia Department of Education, accessed June 6, 2024, www.doe.virginia.gov/data-policy-funding/data-reports/statistics-reports/accreditation-federal-reports/soa-school-accreditation; Interview with social studies administrator (SSA 800), August 25, 2022. [↩]
  7. Virginia HB 930 (2014); Interview with social studies administrator (SSA 800), August 25, 2022. [↩]
  8. “OSPI-Developed Social Studies Assessments,” Washington Office of Superintendent of Public Instruction, accessed June 6, 2024, ospi.k12.wa.us/student-success/resources-subject-area/social-studies/ospi-developed-social-studies-assessments; Interview with social studies administrator (SSA 9), May 1, 2023. [↩]
  9. Interview with high school social studies teacher (HST 911), June 22, 2023. [↩]
  10. Interview with middle and high school social studies teacher (MST 902), May 23, 2023. [↩]
  11. Interview with social studies administrator (SSA 2), February 9, 2023; Erica Breunlin, “Colorado Democrats Want to Ax Social Studies from State Standardized Tests. Here’s Why,” Colorado Sun, January 27, 2023, coloradosun.com/2023/01/27/social-studies-standardize-testing-colorado/; Colorado SB 23-061 (2023), https://leg.colorado.gov/bills/sb23-061. [↩]
  12. These are the Iowa Statewide Assessment of Student Progress (ISASP), the Illinois Assessment of Readiness (IAR), the Pennsylvania System of School Assessment (PSSA) and Keystone Exams, and the Connecticut Statewide Summative Assessment System (CSAS). [↩]
  13. Alabama Code, § 25-7-6 (2022); Texas Labor Code, § 101.052 (2022). [↩]
  14. “Texas AFT FAQs,” Texas AFT, accessed December 14, 2023, www.texasaft.org/about/faqs/. [↩]
  15. The Virginia divisions where teachers are now authorized to bargain collectively are Richmond, Arlington, Charlottesville, Fairfax County, and Prince William County. [↩]
  16. “AFT Colorado History,” AFT Colorado, accessed December 14, 2023, co.aft.org/about-us/aft-colorado-history. [↩]
  17. “Schools of Choice Unit,” Colorado Department of Education, accessed June 6, 2024, https://www.cde.state.co.us/choice. [↩]
  18. “Collective Bargaining Rules,” National Council on Teacher Quality, modified January 2019, https://www.nctq.org/contract-database/collectiveBargaining; Email correspondence with Mary Howes, Washington National Education Association, December 21, 2023, email message to Nicholas Kryczka. [↩]
  19. Email correspondence and telephone interview with Nick Christen, Illinois Federation of Teachers, February 6, 2024, email message to Nicholas Kryczka; Illinois, Senate Joint Resolution, Constitutional Amendment No. 11 (2022). The latest available data from 2011 indicates 16 districts without a collective bargaining agreement. See Tara Malone, “School Districts Without Unions Are Rare in Illinois, but Not Unheard Of,” Chicago Tribune, April 7, 2011, https://www.chicagotribune.com/news/ct-xpm-2011-04-07-ct-met-never-a-union-districts-20110407-story.html. [↩]
  20. Email correspondence with Jenny Gaona, Texas Education Agency, email message to Scot McFarlane, February 28, 2024; “Teacher Assignment Chart,” Texas State Board of Educator Certification, 19 TAC Chapter 231, accessed April 8, 2024, https://tea.texas.gov/texas-educators/certification/teacher-assignment-chart.pdf ; Email correspondence with Andrew Miller, Washington Office of Superintendent of Public Instruction, email message to Scot McFarlane, February 26, 2024; “Endorsement competencies,” Washington State Professional Educator Standards Board, accessed April 8, 2024, https://www.pesb.wa.gov/preparation-programs/standards/endorsement-/; Email correspondence with Charles Tocci, Loyola University Chicago School of Education, email message to Scot McFarlane, March 22, 2024; “Subsequent Teaching Endorsements,” Illinois State Board of Education, accessed April 8, 2024, https://www.isbe.net/Pages/Subsequent-Teaching-Endorsements.aspx; Email correspondence with Blake Busbin, Alabama State Department of Education, email message to Scot McFarlane, March 4, 2024; “Teacher Certification,” Alabama State Department of Education, accessed April 8, 2024, https://www.alabamaachieves.org/teacher-center/teacher-certification/; Email correspondence with Kerry Helm, Pennsylvania Bureau of School Leadership and Teacher Quality, email message to Scot McFarlane, February 26, 2024; “Colorado Teacher Endorsement Requirements,” Colorado Department of Education, accessed April 8, 2024, https://www.cde.state.co.us/cdeprof/endorsementrequirements; Email correspondence with Stephanie Hartman, Colorado Department of Education, email message to Scot McFarlane, March 8, 2024; “Endorsements List,” Iowa Department of Education, accessed April 8, 2024, https://educate.iowa.gov/educator-licensure/endorsements-list; Email correspondence with Joanne Tubbs, Iowa Bureau of Education Examiners, email message to XXX, March 1, 2024; “What endorsements apply to secondary subjects?” Connecticut Bureau of Certification, accessed April 8, 2024, https://portal.ct.gov/sdecertification/knowledge-base/articles/resources/endorsements/what-endorsements-apply-to-secondary-subjects?language=en_US; “Teacher licensures,” Virginia Department of Education, accessed April 8, 2024, https://www.doe.virginia.gov/teaching-learning-assessment/teaching-in-virginia/licensure; Phone call with Christonya Brown, Virginia Department of Education, telephone interview by Scot McFarlane, April 1, 2024. [↩]
  21. US Department of Education, National Center for Education Statistics, “Digest of Education Statistics, Table 208.20 Public and private elementary and secondary teachers, enrollment, pupil/teacher ratios, and new teacher hires: Selected years, fall 1955 through fall 2031,” accessed May 6, 2024, https://nces.ed.gov/programs/digest/d22/tables/dt22_208.20.asp The national pupil/teacher ratio is projected for 2022; US Department of Education, National Center for Education Statistics, Common Core of Data (CCD), “Local Education Agency (School District) Universe Survey,” 2022-23 v.1a. In contrast to the growth in administrators, the teacher/student ratio has been relatively flat since the early 2000s. The national public school pupil/teacher ratio in fall 2005 was 15.6 and then 15.4 in fall 2021. “Fast Facts: Teacher Characteristics and Trends,” National Center for Education Statistics, accessed April 11, 2024, https://nces.ed.gov/fastfacts/display.asp?id=28. [↩]
  22. US Department of Education, National Center for Education Statistics, Common Core of Data (CCD), "Local Education Agency (School District) Universe Survey", 2022-23 v.1a. In contrast to the growth in administrators, the teacher/student ratio has been relatively flat since the early 2000s. The national public school pupil/teacher ratio in fall 2005 was 15.6 and then 15.4 in fall 2021. “Fast Facts: Teacher Characteristics and Trends,” National Center for Education Statistics, accessed April 11, 2024, https://nces.ed.gov/fastfacts/display.asp?id=28. [↩]
  23. US Department of Education, National Center for Education Statistics, Common Core of Data (CCD), "National Public Education Financial Survey (State Fiscal)", 2019-20 (FY 2020) v.2a, 2020-21 (FY 2021) v.1a; "State Nonfiscal Public Elementary/Secondary Education Survey", 2022-23 v.1a (this reflects the 2020–21 school year). [↩]
  24. US Department of Education, National Center for Education Statistics, Common Core of Data (CCD), "State Nonfiscal Public Elementary/Secondary Education Survey", 1999-00 v.1b, 2022-23 v.1a. [↩]
  25. “What Is the TCMPC?” Texas Curriculum Management Program Cooperative, accessed December 21, 2022, https://www.tcmpc.org/about-tcmpc/about. The publisher of the TEKS Resource System is the Texas Curriculum Management Program Cooperative, a pooled resource entity conjoining all 20 ESCs. The TEKS resource system is the second iteration of such a curriculum. The previous version of this ESC-produced curriculum, CSCOPE, fell victim in 2013 to parental complaints about specific lesson plans designed to teach students about Islam. Public backlash led the Texas legislature to intervene, resulting in a complete redesign into the TEKS Resource System, which only produces unit plan outlines aligned to the TEKS, suggestions for STAAR alignment, “content specificity” (historical context), and some suggested activities, but not lesson plans, which were the main focus of the CSCOPE controversy. See Morgan Smith, “CSCOPE to No Longer Offer Lesson Plans to Texas Schools,” Texas Tribune, May 20, 2013, https://www.texastribune.org/2013/05/20/cscope-will-no-longer-offer-lesson-texas-schools/. [↩]
  26. Interview with high school social studies teacher (HST 614), September 29, 2023. [↩]
  27. Interview with social studies administrator (SSA 602), February 16, 2023. [↩]
  28. “Initial NMSI Investment Started a Program That Has Transformed Alabama,” A+ College Ready, March 24, 2017, https://aplusala.org/college-ready/2017/03/24/nmsi-program-transformed-alabama/aplusala.org/college-ready/2017/03/24/nmsi-program-transformed-alabama/; Interview with social studies administrator (SSA 118), June 9, 2023. [↩]
  29. “SERC: Mission and Vision,” State Education Resource Center, accessed June 6, 2024, https://ctserc.org/about/serc/mission-vision. [↩]
  30. Connecticut Public Act 19-12 (2019). [↩]