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Posted Tue, November 1st, 2011 8:19 am
Ineffective assistance of counsel – Lafler and Frye
Today in the Community we are discussing Lafler v. Cooper and Missouri v. Frye, a pair of cases raising issues about plea offers and the ineffective assistance of counsel in which the Court heard oral argument yesterday. In both cases, the respondents received deficient advice from their trial counsel. In Lafler, the attorney mistakenly told the defendant that the state could not establish a necessary element of its case – intent to murder – because he had shot the victim below her waist, the state could not establish a necessary element of its case (intent to murder); based on that advice, the defendant rejected a guilty plea, was ultimately convicted at trial, and was eventually sentenced to a much longer prison term. In Frye, the defendant's counsel simply failed to inform him that a plea bargain had been offered at all, allegedly leading him to enter a guilty plea on terms far less favorable than he would have received had he agreed to the state's offer. In each case, the Court is now considering whether the defendant-respondents can seek relief on the ground that their attorneys were constitutionally ineffective and, if so, what remedies are available to them.
We want to hear your thoughts on the two cases below.
Aaron Tang – 0 Promoted Comments
What is your view of the merits? Are the defendants right, or are the states correct that the defendants received what the Constitution guarantees because they were convicted at a fair trial?
Tim Baughman – 1 Promoted Comment
As the Chief of Appeals for the county that obtained the conviction, and litigated it successfully in the state appellate courts—and also as one who filed an amicus brief in support of the Warden—it is not surprising that I believe the Court should reverse the Sixth Circuit's decision in Lafler v. Cooper. First, the right protected by the Sixth Amendment right to counsel is the right to a fair trial (including its waiver by plea), and defendant had a fair trial. And it is impossible to recreate history and put the parties back in the position they were in before trial. Before trial, the prosecution could withdraw its plea offer even on a whim; now, because counsel arguably did not perform well during plea negotiations, the prosecution is to be put in a position where the conviction it obtained is wiped out, and it must make the same plea offer as made before the successful trial, and now cannot withdraw the offer? That makes no sense. Nor does some "presumption of vindictiveness" which must be overcome if the prosecutor wishes to make a more "severe" offer; it is both unfair, and, in any event, if properly viewed, would always be overcome by the fact that the prosecutor went to trial successfully and thus knows that a conviction at trial is a realistic possibility. And if the remedy is not to require the prosecution to re-offer the same plea agreement, an offer it now cannot withdraw, but to allow a new trial, that makes no sense, as the defendant has already had a fair trial, and the prosecution may have to proceed to trial with a weaker case, given the passage of time (likely a fairly substantial period). No point is served by requiring a second fair trial.
But given existing case decisions, the State has an uphill battle—a battle I believe the Warden should win. I look forward to reading the argument transcript.
Aliza Kaplan – 2 Promoted Comments
The Supreme Court should uphold the lower courts' rulings that a criminal defendant who rejects a plea offer because of his lawyer's deficient performance may show prejudice and be entitled to relief if he later receives a longer sentence than the prosecution had offered under the plea.
In Lafler v. Cooper and Missouri v. Frye, the state petitioners incorrectly argue for a very narrow interpretation of Strickland v. Washington, 466 U.S. 668 (1984)'s prejudice prong, applying it only to trials and not to pretrial proceedings or sentencing. They contend that there is no prejudice if the defendant has not been deprived of a fair trial; they argue that different from a fair trial, there is no "substantive or procedural right" to a plea agreement, so the defendants were not prejudiced by their lawyers' deficient performances that only affected their plea bargaining process. However, this argument is misplaced and Cooper and Frye should prevail. A defendant has a Sixth Amendment right to effective assistance of counsel during the plea stage—once the prosecution makes an offer, the defendant has a right to have his attorney tell him that offer and provide reasonable information about the consequences of accepting or rejecting it. The Court has clearly and consistently recognized this right. See Padilla v. Kentucky, 130 S. Ct. 1473, 1480-81 (2010) ("Before deciding whether to plead guilty, a defendant is entitled to the effective assistance of competent counsel."); Strickland, 466 U.S. at 688 (explaining counsel's "dut[y] to consult with the defendant on important decisions and to keep the defendant informed of important developments in the course of the prosecution"). Moreover, the Court has not only acknowledged that the overwhelming majority of cases are resolved by plea bargains, "[p]leas account for nearly 95% of all criminal convictions," Padilla, 130 S. Ct. at 1485, but it has "long recognized that the negotiation of a plea bargain is a critical phase of litigation for purposes of the Sixth Amendment right to effective assistance of counsel." Id. at 1486. Whether the defendant's final sentence is reached by a trial or plea bargain, the attorney's performance in providing his or her client with a fair process is crucial to the final result being fair. Accordingly, a defendant is entitled to a remedy if he or she relies on his or her attorney's performance to communicate plea offers or interpret the law in the plea stage and receives ineffective assistance of counsel. If the Sixth Amendment guaranteed only a fair trial, Padilla would have come out differently.
Jane Moriarty – 1 Promoted Comment
The issues at stake in Lafler v. Cooper and Missouri v. Frye are critically important to defendants, the government, and the justice system. There is a continuing trend toward greater reliance upon guilty pleas; in the last few years, fewer than 4% of all federal defendants and only 5% of state-court defendants took their cases to trial. Our criminal justice system has become nearly trial-free and our Sixth Amendment jurisprudence must recognize that reality.
In both these cases, the focus is on the competence of the defense counsel at the plea bargaining stage and the proper scope of relief if counsel's incompetence caused a reasonable probability of a different outcome. Here, the failure to explain competently the implications of accepting a plea or going to trial prejudicially affected the outcome of the entire plea process. I do not believe a fair trial subsequent cures the failure to properly advise the defendant on whether to plead. I would hope that the Court would reject the prosecution argument that as long as the defendant received a fair trial, there is no Sixth Amendment violation. Defendants are dependent upon their counsel to provide competent information and advice about whether to plead guilty or go to trial. With hope, the Court will recognize the reality of that dependence and the crucial role that competent counsel plays in the decision whether to waive the right to trial. To do otherwise would render toothless the important constitutional right to assistance of counsel at this critical point in the process.
Jenny Roberts – 1 Promoted Comment
Padilla gave the long-ignored process of client counseling about the decision of whether to plead guilty or go to trial its proper Sixth Amendment due. Lafler and Frye present an opportunity to continue that critical discussion, in the larger context of the Court's seeming willingness to begin to regulate the reality of our current plea-bargaining based criminal justice system. Indeed, at oral argument, several Justices noted the current high rates of guilty pleas.
All parties in both cases agree that counsel for Mr. Frye and Mr. Cooper rendered deficient performance under the first prong of Strickland. However, counseling about a potential guilty plea and the fact that almost all convictions flow from guilty pleas is also a core concern of the contested issue in the cases, that of whether the incompetent lawyering prejudiced either defendant. Missouri and Michigan want to take plea negotiations and the failure to communicate a favorable plea offer out of the prejudice picture, arguing instead that Frye's later guilty plea and Cooper's later trial were valid, so that any earlier missed opportunities are irrelevant. This ignores the fact that these missed opportunities were, in a system where plea bargains and guilty pleas dominate, the main event. If a missed opportunity to cut one's losses, plead guilty, and take ninety days in jail rather than three years (in the case of Frye) or four-to-seven rather than fifteen-to-thirty years (in the case of Cooper) to is not prejudicial, then it is hard to imagine what is.
In deciding Frye, the Court is confronted with a particular (if not completely unique) fact that should not drive the decision: that just days after his original plea offer expired, Mr. Frye was re-arrested. Without this fact, it is easier to focus on the underlying principle that any decision must address: is there prejudice when a person pleads guilty and get a sentence that is significantly longer than the sentence he would have received had his counsel told him about an earlier, more beneficial plea offer? The broader issue is presented in starker, and likely more realistic, light in the absence of the re-arrest. In deciding the prejudice issue, the Court should reject the government's weakly-supported argument that the Sixth Amendment only protects trial rights (or the waiver of those rights at the moment of entering a guilty plea) and indeed does not even apply to plea negotiations between defense counsel and the prosecution. Such an approach would render the Sixth Amendment meaningless in our plea-driven system, where things like Cooper's lawyer's bad advice about his chances at trial or Frye's lawyer's failure to communicate the plea offer are the most significant moments in the case.
Kent Scheidegger – 6 Promoted Comments
"If a missed opportunity to cut one's losses, plead guilty, and take ninety days in jail rather than three years (in the case of Frye) or four-to-seven rather than fifteen-to-thirty years (in the case of Cooper) to is not prejudicial, then it is hard to imagine what is."
I can rather easily imagine two things more prejudicial: (1) being convicted of a crime you did not commit, and (2) being sentenced to more than is just for the crime and your criminal history.
These are the outcomes the Strickland Court was worried about when it limited relief to cases where the judgment "resulted from a breakdown in the adversary process that renders the result unreliable." (687) That did not happen in this case. A fair trial or an informed, voluntary guilty plea is no less reliable because defense counsel muffed a prior offer that the prosecutor had no obligation to offer in the first place.
Loren AliKhan – 1 Promoted Comment
The Court should hold that the Sixth Amendment is violated when a defendant forgoes a plea due to ineffective assistance of counsel and is then convicted and receives a more severe sentence than would have resulted from the plea. Neither a subsequent trial nor a less favorable plea can cure that violation or undo the prejudice suffered from the counsel's deficient performance. Instead, courts must fashion a remedy that places the parties as close as possible to the position they were in before the ineffective assistance occurred.
The Court has already recognized that plea bargaining is a critical stage of criminal proceedings, and with over 95% of criminal cases being resolved through guilty pleas, the Sixth Amendment's guarantee of effective assistance would be a hollow promise if the Court does not recognize the right, and an appropriate remedy, in the context of forgone pleas.
Kent Scheidegger – 6 Promoted Comments
The starting point here is to remember what a drastic measure it is to overturn a judgment for ineffective assistance of counsel. Where else in American law can a judgment in favor of a party who did nothing wrong be reversed for the failings of opposing counsel?
This unique ground of reversal is allowed in criminal law alone because the stakes in criminal law are unique. The conviction of an innocent person is an otherwise irreparable harm, not compensable by a malpractice action against the attorney. It is to guard against a miscarriage of justice that we allow a result that otherwise seems absurd, and this unique remedy should be confined to that situation.
The general principle of the Strickland "prejudice" prong is that ineffective assistance is a ground to overturn a judgment only when we have reason to lack confidence in the result. For most cases, this general principle is crystallized in the specific rule that "prejudice" means there is a reasonable probability of a different result if counsel had acted differently. But that test does not always apply. There are some situations where an attorney might have gotten the defendant off with less, yet we do not doubt the reliability of the result. These include making a pitch for jury nullification (Strickland), letting the client commit perjury (Nix v. Whiteside), or making an argument of law that might have been accepted at the time but is now known to be incorrect (Lockhart v. Fretwell).
In both of the Cooper and Frye cases, the defendants were convicted of crimes they actually committed and received sentences no greater than they deserved. We have no reason to doubt the reliability of the result. The fact that a better lawyer might have gotten them an undeserved windfall is insufficient reason to overturn the judgments.
Reinstatement of the plea bargain would also be a bizarre result after trial, as in the Cooper case. Avoiding trial was the consideration for which the prosecution offered the bargain. That is like someone who rejects your offer to buy his car and later wants to go through with the deal, but he has wrecked the car in the meantime. He still wants you to perform your part of the bargain when he can't possibly perform his.
As counsel for Frye noted at argument, there is no perfect solution. He was quite wrong about what is the least imperfect solution. Given that the process has ended at a just result for the crime committed, the least imperfect solution is to let the judgment stand.
roxanne friedman – 4 Promoted Comments
The starting point here is to remember just how bad representation is at the state trial court level and just how high the standard for ineffective assistance is. There are still lots of places here in the South where defendants don't see their lawyer between arraignment and trial date, where lawyers depend on the good graces of prosecutors and judges to maintain their practices, where motions practice is perfunctory, where fees for investigators and experts are unavailable or inadequate, where there are so many appointments that a single lawyer or law office can't give individual attention to any case. Ineffective assistance is not malpractice, it is a symptom of a system which offers only enough due process to sustain a conviction. So that makes habeas the only effective remedy.
Peter Goldberger – 0 Promoted Comments
Kent: Your query ("Where else in American law can a judgment in favor of a party who did nothing wrong be reversed for the failings of opposing counsel?") has a false premise, which was exposed and debunked in Cuyler v. Sullivan, 446 U.S. 335, 342-45 (1980). The Court held there, on the way to explaining that privately-retained counsel can render constitutionally-ineffective counsel, that the duty under the 14th Amendment to ensure a fair criminal process, including effective counsel for the accused, always rests, in the end, on the State — not on the prosecutor, of course, but on the State as a whole. When defense counsel renders ineffective assistance, it is not correct to suggest that the adverse "party" — that is, the State — has done "nothing wrong."
Kent Scheidegger – 6 Promoted Comments
The attribution of defense counsel's failings to the state is a convenient fiction, not a reality, and hardly constitutes "debunking" of my premise. The fiction is particularly obvious in the case of retained counsel, where the defendant has his choice of any attorney who agrees to represent him, and there is absolutely nothing the state can do about it.
Peter Goldberger – 0 Promoted Comments
If it is fiction, Kent, it is a "legal fiction" and is thus "reality" in a sense that counts importantly when assessing the likely outcome of a pending case. In other words, I was pointing out that as to one argument you advanced there was pertinent Supreme Court precedent of 30+ years' duration against you. If your comment was not meant to be taken as a legal argument, then I guess I missed the point.
Sanjay Chhablani – 2 Promoted Comments
As an initial matter, the Court is likely to reject petitioners' claims that the right to effective assistance of counsel only applies in cases where defendants enter a guilty plea (and thereby waive the various Sixth Amendment trial rights). Instead, the Court will likely find that counsel have a duty to provide effect assistance throughout the plea bargaining process, including a duty to communicate plea offers to clients and to provide reasonable professional evaluations of those plea offers.
But, having established the right to effective assistance of counsel, the Court will likely deny relief for one of two reasons. First, the Court could find that the defendants suffered no prejudice, in effect rendering counsel's constitutionally deficient conduct without remedy. Alternately, the Court could find that defendants in such cases can meet the Strickland prejudice prong but still not be entitled to relief because of harmless error analysis.
As to the first option, it would in effect mean that there is no remedy for counsel's constitutionally deficient conduct. As troubling as that sounds, it would not be the first instance in which the Court has found that a Sixth Amendment right lacks a remedy. Consider the right to an impartial jury. If a judge improperly excuses a prospective juror for cause over the defendant's objection, the defendant will not be entitled to relief absent a showing that the resulting seated jury was not impartial. In other words, even if one could assumed that the excused juror might have been more favorable to the defendant than the jurors actually selected, the defendant would not entitled to a new trial because the Constitution guarantees only a trial before an impartial jury, not a trial before any particular juror.
As to the second option, typically claims of ineffective assistance of counsel are not subject to harmless error analysis in part because such analysis is unnecessary. Harmless error analysis is generally speaking less exacting than the Strickland prejudice prong. So, if an error meets Strickland's prejudice prong, and therefore qualifies for relief, harmless error analysis would not lead to a contrary determination. However, a harmless error inquiry in Lafler and Frye would be quite distinct. While the purpose of the Strickland prejudice prong is show that the defendant is harmed by counsel's deficient performance, the purposes of harmless error analysis are resource conservation and the promotion of federalism, comity and finality. Particularly in light of the fact that prosecutors in both Lafler and Frye have made clear that they will not extend the same offers again (and the effect such opposition would have on the trial judge), these interests might compel a finding of harmless error. Alternately the Court might conclude that the convictions that were entered in both cases (whether after a trial or pursuant to a unrelated plea) rendered any error in the preceding plea bargaining process harmless. This would be analogous to the Court's approach in United States v. Mechanik with respect to errors in the grand jury process that are raised after a subsequent conviction.
Aaron Tang – 0 Promoted Comments
Assuming that the Sixth Amendment is violated by a lawyers flawed advice about the plea process, what should the remedy be?
Aliza Kaplan – 2 Promoted Comments
As to the remedy, "[c]ases involving Sixth Amendment deprivations are subject to the general rule that remedies should be tailored to the injury suffered from the constitutional violation and should not unnecessarily infringe on competing interests." United States v. Morrison, 449 U.S. 361, 364 (1981). Therefore, courts must "identify and then neutralize the taint by tailoring relief appropriate in the circumstances." Id. at 365. Based on this, the trial courts should be given discretion to create remedies that are the most fitting under the circumstances for the particular case. In some cases this will mean enforcing the original plea bargain's terms and in others, it will mean vacating the conviction and starting over.
Laurie Levenson – 2 Promoted Comments
Given how critical the plea bargaining process has become in our criminal justice system, it is too cavalier to say that any failures by defense counsel during that process are remedied by a fair trial. Once a defendant denies a plea offer, prosecutors often become entrenched in presenting the most damaging case possible against the defendant. Thus, mistakes by counsel at the plea bargaining stage will have a long-lasting effect on the defendant, including at sentencing.
Although Strickland sets the general standard for ineffective assistance of counsel, there are different kinds of prejudice that arise from rejecting a plea offer. The Court's focus should be on remedying prejudice. Offering a trial at which the prosecution believes that the defendant is refusing to take responsibility for his or her actions is not the answer. Perhaps it is time for prosecutors to articulate why they are making plea offers and for defense counsel to articulate why they are rejecting them. Then, the court will be able to evaluate whether defense counsel's erroneous advice really did have an impact on the defendant's decision to reject a deal.
Aaron Tang – 0 Promoted Comments
Offer your predictions of how the cases are likely to be decided.
David Perez – 1 Promoted Comment
The biggest sticking point for both these cases is the remedy, which is neither simple nor intuitive. The Court has two options: order specific performance of the plea bargain, or vacate both convictions and order a new trial (thereby resetting the process to the plea bargaining stage). I think the Court will ultimately conclude that it has no power to order specific performance and that it has no choice but to order a new trial.
Although specific performance of the plea bargain is the most intuitive remedy, it is also the most complex, and often impossible to implement. Traditionally, specific performance of a plea offer has only been available where the prosecution has abused its discretion or reneged on an accepted plea agreement. Otherwise, there are difficult logistical issues involved. For instance, since most of these cases originate in state court, permitting federal courts to order specific performance could implicate federalism concerns, such as the abstention principle, which generally bars federal interference with state criminal proceedings. Additionally, forcing the prosecution to reoffer a plea bargain that it initially offered to avoid the expense and risk of a trial it has already won, would violate basic fairness principles enshrined in the separation of powers doctrine – especially since it would often entail dismissing charges.
Certain changed conditions may also make the original plea irretrievable under the Constitution's double jeopardy clause, which forbids a defendant from being prosecuted twice for the same crime if he has already been found innocent. For instance, imagine a scenario where the defendant is indicted for both felonious possession of a firearm and also aggravated manslaughter. The initial plea offer stipulates that if the defendant pleads guilty to the firearm offense, the state will drop the manslaughter charge. Instead, the defendant turns down the plea and goes to trial, where he is convicted of aggravated manslaughter, but is found innocent of the firearms charge. The prohibition against double jeopardy would then prevent the defendant from pleading guilty to felonious possession of a firearm, a charge for which he has been declared innocent. The plea, at this point, would be impossible to resurrect.
Courts that order specific performance rarely consider these constitutional principles. Those courts that do, however, usually opt for a retrial. The new trial remedy is, admittedly, redundant and risks awarding the defendant a windfall chance at acquittal, which would be completely disproportionate to the harm alleged. But since a court cannot order a member of the executive branch to reoffer the plea bargain, a retrial isn't just the best solution – it's the only solution. I think the Supreme Court will realize that only by ordering a new trial can it adequately balance competing constitutional interests while still remedying a clear constitutional violation.
Kent Scheidegger – 6 Promoted Comments
No, there is a third option and another solution. That is to recognize that the case is analogous to Lockhart v. Fretwell.
Fretwell's attorney might have gotten him a lesser sentence by making an argument of law now known to be incorrect. The Court held that was not "prejudice" within the meaning of Strickland because there is no reason to doubt the reliability of the result. In that situation, even if the attorney was ineffective, the judgment stands.
Conducting a second trial when there was nothing wrong with the first one is not just "redundant," it is preposterous.
Jeffrey Kirchmeier – 1 Promoted Comment
In thinking about the possible outcomes, an interesting question is whether the Court might apply a different standard to each of the two cases.
Because lack of preparation for trial may constitute ineffective assistance of counsel, it seems clear there is a constitutional right to counsel at the plea bargain stage. So the key aspect of the cases will be how the court addresses the prejudice issue. There is a way that the Court may decide that creates different outcomes for the two cases.
In Lafler v. Cooper, the ineffectiveness claim is based on deficient performance, i.e., that counsel gave bad advice about the plea. If an attorney gave bad advice during trial, a defendant would have a Sixth Amendment claim if the defendant could show prejudice.
In Missouri v. Frye, though, where counsel failed to notify Frye about a plea offer, the claim is comparable to situations where a defendant was without counsel during a critical stage or counsel concedes guilt. In cases where counsel does not participate or is absent, the Court has held that prejudice is not required.
There is an unfairness in both cases, and the defendant in Lafler was not able to make an informed choice either, so there is also an argument the cases are similar. But one option for the Court in these cases is to draw a line between the two cases and not require a showing of prejudice where a defendant was not even aware of the offer.
As others have noted, the Court's decision on these cases is important considering the large percentage of criminal cases that are decided at the plea bargaining stage. So I hope that the Court is able to craft its decisions to protect the important rights at this stage.
Sanjay Chhablani – 2 Promoted Comments
There is a possibility that Lafler could be disposed by a determination that the Michigan courts' resolution of the claim of ineffective assistance of counsel was not unreasonable, making the lower federal courts' granting of habeas relief improper under the AEDPA.
More likely, the Court will address the substantive questions raised by Lafler and Frye, and, perhaps unanimously, find for the petitioners in both cases.
Aaron Tang – 0 Promoted Comments
Finally, in this thread discuss any other issues related to Lafler and Frye, or the Court's ineffective assistance of counsel jurisprudence that you think warrant attention.
Larry Benner – 1 Promoted Comment
The oral arguments in Cooper and Frye dramatically demonstrate the bankruptcy of the Court's ineffective assistance of counsel jurisprudence in the context of plea negotiations and advice. They also reveal a Court seemingly unaware of the current crisis in indigent defense across the county. What is at stake, as Justice Kagan recognized, is the integrity of our criminal justice system which resolves 97% of its cases through plea bargaining. If no consequences result from providing ineffective assistance of counsel at this stage, then there will be little incentive to prevent local governments from forcing underfunded public defender offices to handle crushing caseloads, and little hope of ending the practice of those contract attorneys who, in order to make court appointments profitable, "meet, greet and plead" their clients at the first court appearance with little or no investigation.
Every one admits that the court appointed defense counsel in both of these cases made egregious errors which harmed their client's liberty interests. Virtually everyone (except perhaps Justice Scalia) agreed this was unfair. Yet like fish out of water, counsel and the Justices flailed about attempting to apply the Strickland formula for determining prejudice to factual situations that were not before the Court in Strickland. Perhaps in such circumstances the Due Process Clause, which incorporates and applies the Sixth Amendment to the states, should stand on its own two feet, as Justice Harlan believed in Gideon, because what is undermined in these cases is confidence in the fundamental fairness of our criminal justice system.
Sanjay Chhablani – 2 Promoted Comments
While the Court's effective assistance of counsel jurisprudence will likely not lend itself to remedying the problems faced by defendants such as Cooper and Frye, there may well be an underlying Due Process issue. While it is true that the Due Process clause guarantees defendants the right to a fair trial, it does more. It guarantees procedural fairness in all proceedings that lead to deprivations of life, liberty or property. This would arguably include the process of plea bargaining. Of course such a Due Process claim would be subject to harmless error analysis, which as noted above might well lead to the denial of relief in Lafler. In Frye, one might argue that counsel's complete silence rendered the Due Process violation a structural error, exempting it from harmless error analysis.
Moreover, it is significant that all lower courts to consider this issue have found it deeply problematic when deficient performance by counsel leads a defendant to reject or not accept a plea. This raises the possibility that some state courts may use state constitutional provisions to adopt prophylactic rules in such cases that provide a remedy to defendants for the deficient performance of their counsel. For instance, when the Court decided in Mechanik that errors in grand jury proceedings may not be remedied when the defendant is subsequently convicted, several state courts interpreted their state constitutions as giving defendants the right to have their grand jury indictments dismissed despite being convicted by a jury. So it is entirely possible that if the Court reverses these two cases, the states will be the battleground for efforts to ensure that a remedy is provided for deficient performance by counsel in the plea bargaining process.
Finally, the conceptual problems raised in Lafler and Frye highlight the need for the Court to revisit fundamental problems with the test for effective assistance of counsel adopted by the Court in Strickland v. Washington.
A Hays Town III JD – 0 Promoted Comments
In Cooper, counsel conveyed the offer- while counsel may have misinterpreted the law and facts- that is a strategy call, albiet poor. While in Frye, counsel failed to communicate with his client and caused harm to his client. That warrants a withdrawal- client should not be penalized because of counsel mistake.
While one may say an Accused is not entitled to a plea offer-one must be real- can not try all cases.
So what is the object lesson- carry the message, explain the offer in both terms the postive and the negative. Carry to the State your clients answer. Thanks Hays
Brandon Cogswell – 1 Promoted Comment
Is the plea bargaining stage of a criminal case a critical stage? Yes. In most criminal courts the plea bargaining stage is spread throughout the pretrial stage. Defendant's are entitled to counsel at their arraignment, through the pre-trial process and at trial as these are critical stages. The Court is not going to remove the plea bargaining stage as a non-critical stage. Since the plea bargaining stage is a critical stage, defendant's are entitled to relief when their counsel is ineffective.
The two cases are only similar in that they deal with ineffective assistance of counsel and they both have attorneys who were negligent in their representation. They are very different, however, in that Frye deals with an attorney not communicating with his client and Cooper deals with an attorney communicating the offer but believing the State cannot meet its burden at trial. The client in Frye was provided ineffective assistance. The client in Cooper was provided bad advice, but not necessarily ineffective assistance.
In Frye, the failure to communicate the plea offer to the Defendant is similar to the failure to convey a settlement offer in a civil case. Attorneys do not make the decision to go to trial. We may encourage, but ultimately the choice is our client's. In the 6th amendment context, the Supreme Court here is likely to find that the 6th amendment was violated. But for counsel's failure to communicate the offer to his client, client would not have proceeded to trial. So what is the remedy? I propose that the Supreme Court is going to grant some sort of relief to the Defendant. The problem is that the Defendant was provided with a fair trial he just wasn't provided with an opportunity to take a plea bargain.
In Cooper, counsel gave bad advice but it may not rise to the level of ineffective assistance under Strickland. The client still elected to take the case to trial presumably having all the information necessary to make decisions in the case. Counsel gave his advice which, even though very poor, is the job of a defense attorney. Client then has the opportunity to accept or reject a plea offer. I propose in this instance the Court will not grant relief.
I agree with the comment above, both cases involve ineffective assistance of counsel. With 97% percent of cases resolving by way of plea, there must be a remedy when counsel is deficient. One problem is forming a test for what makes counsel deficient in the pretrial stage as opposed to the trial stage. Until the Court decides to create a new standard for effective assistance in the pretrial stage, we are left with resolving ineffective assistance cases using the Strickland test. And under that test, I believe there is only ineffective assistance in the Frye case, not the Cooper case.
Mohammad Hamoudi – 1 Promoted Comment
I think it is important to remember that the Sixth Amendment is a fundamental right that belongs to the defendant. The Sixth Amendment is not concerned with the collateral consequences underlying a Sixth Amendment violation. The right to a fair trial is a component of the Sixth Amendment. The right to effective assistance of counsel is a component of fair trial.
Most criminal defendants involved in these cases are indigents. Indigent criminal defendants lack the necessary skills and knowledge to navigate through the "give and take" bargaining involved in plea agreements. The defense attorney is their agent. If this case involved a contract right where property rights were at stake, the court would find little trouble in fashioning a remedy that addresses the contractual harm.
Concepts of offer, acceptance, condition, terms, consideration, and performance exist in plea bargaining. The criminal defendant who loses out on a deal because of his lawyer's incompetence cannot obtain relief in a civil court for malpractice. There is no political representative out there willing to introduce legislation to protect a criminal defendant from an incompetent criminal defense attorney.
The only thing available to the defendant who loses out on a bargain or suffers any harm because of his lawyer's incompetence is an ineffective assistance claim. The district court is more than capable like any other court in a contract case to consider all the facts and tailor an appropriate remedy to address the harm. A hard and fast rule by the Supreme Court would not be appropriate.
There are many capital defendants who get sentenced to death because of their attorney's failure to save their client's life through early disposition of the case. Many capital attorneys are too eager to go to trial. There is a lot at stake with these two cases that is not specifically addressed by the cases themselves.
The remedy should be specific performance of the original bargain in Lafler's case. The court should be allowed discretion to either approve the terms or disapprove the terms based on conditions, elements of the bargain, etc.. That discretion should be informed by the extent the defendant established a Strickland violation, i.e., to what extent the defendant was aware of the bargain and refused to take it.
The prosecutor should not have the option to retry the case. There will be no watershed effect by such a ruling because Strickland relief is rarely granted.
The prosecutor represents the state and the defense attorney is regulated by the state. It is the state's responsibility to regulate plea bargains especially when the state is heavily regulates conduct of the prosecution and defense attorney. When the state fails to do so and the client suffers like clients did in these cases, the state should bear the burden.
On the one hand, the rare circumstance where a new trial is warranted and the prior trial was fair, what is really lost? money? resources? an illogical application of the Sixth Amendment?
On the other hand, the rare death penalty circumstance, where a client is sentenced to death, is executed, and is later exonerated, what could have a plea of life afforded that client?
It seems like an easy decision to me. I guess it is a much more difficult decision for the reasons cited above.
saul Sandoval – 0 Promoted Comments
I am not a lawyer.
My solutions are simple and are not very sophisticated. Here's my two cents on SCOTUS solution to these type of cases
My point is that there should be a automatic standard form that the defendant signs that says I am moving in this direction on advise of my counsel since I am being told that my out come is more favorable to follow his advice. If the favorable condition turns out to be unfavorable due to my lawyers incompetency (lawyers incompetency would be defined with a laundry list of what constitutes incompetency) then the unfavorable outcome is null and void and I shall be automatically reinstated to the original position I was in before following the advice of counsel. ( In other words the key word here is that the form is a conditional agreement in going forward)
But this would have to be the law of the land which only SCOTUS can do. Just like Miranda became the law of the land. I know that Miranda has been very watered down since its inception but if there was such a law then all you would have to do is to show any incompetency (very low bar) as described in the laundry list and the unfavorable out come would be null and void and the defendant would now get a second chance of getting the best outcome with a different lawyer. You think that SCOTUS would be in favor of such a law since it's not like you are letting an obvious guilty person to be free you just sort of guaranteeing that he get another chance with an effective counsel and get the best deal possible vs the bad one he originally got. Plus if the goal is to reduce cases involved with ineffective assistance of counsel being brought up before SCOTUS then this law would reduced them considerably
I know this is an over simplification of the complexities of such a law but crazier things have turned out of SCOTUS. Look at the Citizen United case. If they can allow such a crazy law of the land like that to be created then my suggestion is not that far fetched. This court though is too conservative


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Water use at conferences is primarily for drinking water, sanitation, and for washing/cleaning. Appropriate wastewater management is important for protecting waterways from contamination.
As mentioned, preparatory meetings have been held in Istanbul prior to the launch of Green Forum Initiative activities and thus little data is available.
However, at the Cevahir Hotel, venue of preparatory meetings in February 2008, it can be mentioned that sinks with infrared sensors on the water taps and dual flush systems were in use. Water for participants was served in jugs, rather than in plastic bottles, which normally reduces wasted drinking water and significantly reduces plastic waste.
Drinking water: Water used in the building that must be of the highest purity comes from the municipal water system and is purified further using reverse osmosis and UV treatment and activated carbon filters. This avoids the need for bottled water in food preparation areas. Water for other uses does not go through this extensive treatment process.
Sanitation: Water saving flush system 3l / 6l are in use in toilets and infrared detectors are in place for the water taps.
Food preparation areas: oil traps are used to prevent used cooking oil from going into the city's waterways. Irrigation: Pop-up sprinklers are installed and are set on timers to allow for optimal irrigation of landscaped areas.
Forum Environmental Policy
Istanbul Hotel Survey
Hotel Greening Workshop Presentation
Hotel Greening Audit Checklist
GFI Flyer
Green Forum Initiative Overview
Report on the Forum Venue
Share your ideas with the Green Forum Initiative

subset: commoncrawl


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Proof of Insurance
You must have current proof of insurance to register a vehicle, showing the vehicle VIN number, date of issue, and the month of expiration. If you don' t have this card, have it faxed to us prior to your arrival. It sometimes takes 30+ minutes for some companies to get it to us. There is no requirement for proof of insurance on trailers, boats, or snowmobiles. Evidence of insurance may be provided in paper or electronic format. If provided electronically, you assume liability for the device. Nebraska law 60-387.01
I just moved, what do I need to do?
Please select the following link: What do I need to do if I moved (detailed list for new residents and current residents?
Fax - New purchases (402) 593-4360 (new purchase & titles window)
Fax - Renewals (402) 593-4438 (renewals and refunds window)
If you sell, trade, wreck, or junk a vehicle, or terminate a lease; keep your pink registration and plates. Failure to bring in the registration and plates will result in a reduction in your refund. Refunds must be issued within 60 days of title transfer. If sold in the month prior to registration expiration, there is no refund. Bring in your plates (one or both) and registration to obtain a refund.If you move to another state and register your vehicle there, you may also receive a refund. Send the Nebraska plates (one or both) and registration along with a copy of your new state registration for a refund. Please remit these items to:
Sarpy County Treasurer
1210 Golden Gate Drive
Papillion NE 68046-2893
Sales Tax
In the city limits of Bellevue, Gretna and Springfield, the sales tax is 7 percent. The Cities of Papillion and La Vista the sales tax is 7 1/2 percent. It is 5 ½ percent in the rest of the county. Sales tax is charged on the purchase price minus trade in(s) and rebates. Maintenance agreements, add ons, delivery charges, improvements, extended warranties and documentation fees are also subject to sales tax.
If you purchase a vehicle, pay the sales tax within 30 days (not one month) or expect to pay a late fee ($5.00 plus interest). You may pay the sales tax only without registering or titling the car. You may not register the car without paying all the taxes and fees due.
The Nebraska Department of Motor Vehicles issues handicap placards, which hang in your vehicle window. You can turn in the necessary paperwork at your nearest city hall or the Sarpy County Clerk's Office. Once the paperwork is submitted, the Nebraska DMV typically mails the cards within 5-10 business days.
Handicap plates are also issued by the Nebraska Department of Motor Vehicle and get delivered to the Treasurer' s Office. After the paperwork is recieved by the Nebraska DMV, the turnaround time is about 4-6 weeks.
A doctor's certification form must be filled out and submitted to the state for approval in either case, prior to receiving the placard or plates. Forms may be downloaded here.
Message Plates
Message/prestige plates are ordered from the state. They are $40.00 per year, in addition to all other fees. Forms to order are available from the Treasurer' s office or may be Specialty Plate Application Form. Order 6 to 8 weeks prior to renewal to avoid additional fees. Check/Click on the Nebraska DMV web site concerning message availability. Already know what you want and would like to check availability and order online with a credit card. Go to the Nebraska DMV message/Husker plate ordering website. If you do not wish to retain your message plates you must bring in one or both plates to be reissued county plates.
Spirit Plates
(Nebraska Cornhusker) Spirit plates are ordered from the state. They are $70.00 per year, in addition to all the other fees and applicable taxes. Forms to order are available from the Treasurer' s Office, or may be Specialty Plate Application Form. Spirit plates can now also be ordered with a message or the traditional state issued numbers. Check on the NEBRASKA DMV web site concerning message availability. Order 6 to 8 weeks prior to renewal of existing plates to avoid additional plate changing fees. This application should then be mailed to: State of Nebraska, MV Dept, PO Box 94789, Lincoln NE 68509-4789. If you would like to check availability and order online using a credit card, just go to the Nebraska DMV message/Husker plate ordering website. If you do not wish to retain your spirit plates you must bring in one or both plates to be reissued county plates.
Gold Star Plates
Beginning January 1, 2010, gold star plates are available to families of persons who have died while in good standing on active duty in the military service of the United States. They are $40.00 per year if a message is placed on the plate or $5.00 per year if a randomly selected number is on the plate. Information and applications are available at: Gold Star Plate information. If you do not wish to retain your gold star plates you must bring in one or both plates to be reissued county plates.
Organizational License Plates (new in 2010, LB 110)
Beginning in January, 2010, organizations will have the opportunity to have their own organizational license plates. Any non-profit organization, whose primary activity is to serve the community, contribute to the welfare of others and are not offensive or discriminatory, may submit a request to the Nebraska DMV for the creation of a specialty license plate that contains their name and/or logo. If your local organization does not have enough members it could be a plate recognizing the group all over the state such as a Volunteer Fire Fighters Plate or a plate recognizing a group such as Kiwanis or Rotary. These plates will cost $70 annually. Initial application must include 500 pre-paid specialty plate applications. These plates will not be handed out until 2011 with the issuance of the new license plate design. Additional details and applications are available at: DMV organizational license plates.
Military Honor Plates
Beginning in January 2016, active duty military members and veterans will be able to display Military Honor Plates representing their branch of service. Applications are now available and will require the person to have already registered with the Nebraska Department of Veterans Affairs. Please see the state web site for more information.
- Military Honor Plates
- Approved Military Honor Plate Designs
- I am registered and want to order my veteran's plates by selecting Vehicle Services/Specialty License Plates
Veterans who have served in more than one branch of the service and have registered their varied service with the Department of Veteran's Affairs can choose a plate from one branch or multiple branches if they so choose. In any and all cases, thank you for your service.
Single License Plate Option
Beginning January 1, 2017, one license plate may be issued, upon request. for any passenger car which is not equipped with a bracket on the front of the vehicle to display a license plate. A license decal shall be issued with the license plates and shall be displayed on the driver's side of the windshield. In order to request a single license plate and license decal, there shall be an additional annual nonrefundable registration fee of $50 plus the cost of the decal paid to the county treasurer at the time of registration. We advise you to put the sticker in the upper left corner of your window so it is visible in the winter if there is snow on your car. You will receive a new decal every year when you renew your single plate registration. If at any time you want to put a bracket on your vehicle and go back to two plates you will have to surrender the single plate and receive a new set of plates. If you have a specialty plate it will be retained and we will order a second plate from the state. This option is not available on a truck. With this option you will not be able to renew your registration online. It must be processed in person or by mail.
Bill of Sale
It is a good idea to use a bill of sale when buying or selling a vehicle. It provides evidence that a transfer of ownership has taken place. The following link will provide you with a courtesy Bill Of Sale provided by DMV. This specific bill of sale does not have to be used and does not have to be notarized. Of course, having it notarized provides evidence that the signatures are valid. In any case, we require the buyer to provide a bill of sale, signed by the seller, prior to registering a vehicle. You can also obtain a Nebraska Form 6 sales and use tax form from any county treasurer which can be used instead of a bill of sale. In the event that the transaction is suspect we reserve the right to require a notarized bill of sale prior to registration.
Vehicle Inspection
Preowned or previously titled vehicles purchased outside Nebraska, (or you have moved to Nebraska), must be inspected to verify accurate VIN numbers. Fee: $10.00. Office located at the east side of the courthouse. Parking is available for this inspection, near the southeast corner. Some out of state lenders or dealers require an instate title be issued even though they may be selling a new car to someone who lives in Nebraska. Therefore you will have an out of state title on your new car and it must be inspected.
Present title to the County Treasurer (title and purchase window) to be processed. If you received a postcard from the Treasurer, present it instead. Fees are $10.00 to $17.00. $10.00 TITLE fee, $7.00 LIEN notation (signed security agreement showing name of lienholder and vehicle used as collateral is required), $14.00 Duplicate title (or spoiled)
Your vehicle property tax will be computed by the treasurer. Property tax is computed based on the original MSRP (manufacturers suggested retail price) and a tax table which is then reduced/depreciated based on the age of the vehicle.
Sales tax, personal property tax, tire tax, title fee, and plate fee will be collected by the treasurer.. Tire tax is $1.00 per tire on new tires.
Plate transfers: bring your old registration, your credit will be subtracted from your fees. Credit for trades must be obtained within 60 days or we cannot issue the credit. See refunds above. A credit is a better thing to do rather than a refund because it will save you money.
Leased Car Information
Leased vehicles domiciled in Nebraska must be registered and titled in Nebraska. Non-resident Military personnel stationed and living in Nebraska should refer to the military registration section below. Sales tax on leased vehicles is usually part of the monthly lease payments and is rarely paid at the time of registration. Normal registration fees at the Treasurer' s office include plates/registration and assessed property tax. If you buy out your lease (purchase the car) you are required to pay sales tax on the purchased price and reregister your car in your name, without the leasing company on the title and registration. If you fail to pay the sales tax within 30 days of buyout you will incur significant penalties at the time of proper registration.
Estimate The Taxes Due On A Vehicle
The State of Nebraska Department of Motor Vehicles has a web site which will give you an estimate of what you owe on a new purchase or on a renewal. You WILL need the VIN (vehicle identification number) of the vehicle to use this system. You may also obtain a renewal quote by following the instructions on the screen. It will add in a plate fee which can be ignored if you already have alpha-numeric plates. Please visit their web site at DMV Nebraska online vehicle tax estimator. If you do not have the VIN number or do not wish to use the site you may call us at 402-593-2143.
Motor Vehicle Renewals ONLY:
Renewal and refund window. Bring proof of insurance, your old registration, and the renewal letter you were mailed. Proof of insurance is the one thing we must have. We do not need your renewal notice or your registration to renew your car, it's just easier on both of us. Did you know most people can now register online for a nominal fee. Please click on the link on the side of the page.
If you are a business with a large number of vehicles (generally exceeding 20), you may be asked to leave your transactions, depending on the time of day or month. That we can process your registrations and continue to wait on the public in a timely manner. If you call ahead we can arrange a convenient time which will allow us to process your work as you wait. Please call (402-593-2152) to arrange an appointment. Of course your work can also be done by mail if that is more convenient.
Moved?: Previous Nebraska registration, go to the renewal and refund window; from out of state, see "registering a newly purchased vehicle" above. Procedures are the same. There is no sales tax if previously properly registered in another state.
Active Duty, Non-Resident Military Personnel Stationed in Nebraska
An active duty military servicemember, stationed in Nebraska, with a state of residency other than Nebraska, does not pay personal property tax on vehicles registered in Nebraska. Plates/registration fees are generally $30.25 for a car, $33.25 for a truck. There is no motor vehicle tax on owned or leased vehicles. However, (if this is a new purchase) you will be required to pay sales tax as part of the registration process. You are not exempt from any fees nor sales tax. (NOTE: Keep your copy of the sales tax form. You may need it at your next assignment.)
Active Duty non-resident military personnel and/or spouses must produce a current end of month Leave and Earnings Statement (within last two months) and the military ID card of the member or the dependent ID card of their spouse, to claim non-resident status. Your LES must reflect a state of residence other than Nebraska (NE). If these documents are not available we will accept a letter, on letterhead paper, from your commander, the base JAG or the finance office attesting to your state of legal residence.
If you are moving from another state we will need your old registration. You do not have to get a Nebraska title.
If the vehicle is coming from overseas without a stateside issued title, you must get a Nebraska title issued first. If the vehicle has a stateside title you do not need to get it retitled in Nebraska unless required by your lender. If the vehicle was registered overseas and all foreign fees and taxes were paid at the time of registration you may not have to pay sales tax here, if appropriate documentation is provided. Please refer to this link to review the documents you must provide: Imported Vehicles from Outside the U.S.
New York Residents - Military Personnel
If you purchase and register a vehicle in Nebraska and then return to New York with that vehicle they will charge you sales tax in addition to what you paid here. This applies if you are stationed there or returning to New York after military service. Therefore check with New York DMV prior to registering your purchased vehicle.
Commercial Vehicles
Every commerical motor vehicle used in interstate commerce needs a U.S. DOT (Department of Transportation) number. For more information please visit here: DOT Web Page
Registration Weight On Commercial Vehicles
The registration fee for commercial trucks is based upon the gross weight. The gross weight (tonnage) is the sum of the empty weight of the trucks and any commercial trailer plus the weight of the maximum load to be carried at any on time. So the truck, trailer and load added together determines your registration weight. Round up to the next highest tonnage.
All applicants for registration of vehicles with a declared gross vehicle weight of 55,000 pounds (28 tons) or more must present proof of payment of Federal Heavy Vehicles Use Tax to the IRS. Heavy Vehicle Use Tax Form Heavy Vehicle Use Tax Information
Alternative Fuels
Every person registering a motor vehicle designed or modified to be propelled in whole by alternative fuel shall obtain from the department an annual alternative fuel user permit for each motor vehicle propelled by alternative fuel. A person shall obtain all required alternative fuel user permits within thirty days of becoming an alternative fuel user. This permit is presently $75.00 per year.
Alternative fuel shall include electricity, solar power, and any other source of energy not otherwise taxed under the motor fuel laws which is used to power a motor vehicle. The term shall not include motor vehicle fuel as defined in Nebraska statutes section 66-482, diesel fuel as defined in section 66-482, or compressed fuel as defined in section 66-6,100;
Anyone using a total alternative fuel driven vehicle should contact the Nebraska Department of Reveneue, Motor Fuel Tax Section at 402-471-5730.
Utility Vehicles/Slow Speed Vehicles/Golf Carts/ATV
In the last few years laws have changed on the operation and use of various vehicles. Different rules apply to each type of vehicle. A handout that discusses the different vehicles and their use may be viewed at Vehicles, ATVs, Slow Speed Vehicles, Golf Carts. Please note that a utility vehicle is not a slow speed vehicle.
You may also view the Nebraska DMV web page which discusses the various types of vehicles at: Nebraska DMV Information
I bought a vehicle what do I need to bring?
A comprehensive list may be viewed at What do I need to bring?
I just moved to Nebraska, what do I need to do about my vehicles/drivers' license?
A list of things to review are at What do I do first?
I am a Nebraska resident. I want to renew my car license plates. What documents do you need to see?
Proof of Insurance and either current registration or renewal notice. Proof of insurance is the only mandatory item. Proof of your insurance is usually in our computers but not always. Therefore we always recommend you bring proof. We can accept proof of insurance on your latest technology/IPhone/android/etc.
I am moving. What do I need to do? This includes out of state as well as within Nebraska.
If you are arriving from out of state, take your vehicle and title to Vehicle Inspections for VIN inspection. The fee is $10.00. If you have a lien on the car (e.g. bank has title), you will need to request the title from your lien holder before you can go any further. Go to our forms section to fill out our form and request your title, Customer Request for out of state title. They will send the title to us and we will send you a postcard informing you that it has arrived and to bring in your vehicle for inspection. After the vehicle has been inspected you can proceed to the Treasurer's Office for titling and registration. If you already have the title go to the County Treasurer's office (window 1) where you will obtain a new title. The car will then be assessed and you will receive your plates/registration from the Treasurer's office. A more comprehensive and detailed list for new residents and people who moved can be viewed at I just moved, what do I need to do?
Where do we obtain "In Transit" stickers or signs?
Only dealers are authorized to provide "In Transit" signs. Nebraska dealers will provide them at purchase. If you purchased your car from other than a Nebraska dealer, keep the title, proof of insurance, and bill of sale with you when you are driving. You have 30 days to obtain plates from the date of purchase. In Transits cannot be renewed past the original 30 days. The State informs us that handmade "In Transits" are not legal even though you may see them on the street.
I'm selling a vehicle, how do I sign off on the title?
Transfer ownership of a vehicle with examples
I lost my renewal card, do I need it?
No, it is not required.
I am moving to Sarpy County from another Nebraska county. What do I need to do?
Nothing until it is time to renew your plates. At that time, bring in your current registration, proof of insurance, and we will load you in the computer as a Sarpy County citizen. Be aware of your vehicle expiration. You will not get a renewal card from us but could get one forwarded from your previous county. PLEASE check Drivers License requirements for change of address (they are different)
I lost my registration and/or plates. How do I replace them?
Come in and we will produce a new registration for $6.50 or a new set of plates and registration for $14.50.
I lost my stickers. What do I do?
We can mail a new set or you can come in and pick them up after we verify the currency of your registration.
I just separated/retired from the military. How long do I have before I register as a resident?
30 days from your retirement or separation date. The intent to leave the state at some time in the future does not change this requirement. If you do not have a Nebraska title for your vehicle, you will have to obtain one prior to registration as a Nebraska resident. The process is basically the same as moving in from out of state.
I'm military. Why do I have to show my LES?
It demonstrates to us your state of legal residence which allows you to register your personally owned vehicle at the non-resident rate. If your LES says Nebraska then you are not eligible to register as a non-resident and this does not apply. If you have a leased vehicle you will also have to produce an LES unless you are a Nebraska resident.
What are the fees for a Nebraska title?
$10.00 TITLE fee, $7.00 LIEN notation (signed security agreement showing name of lienholder and vehicle used as collateral required), $14.00 Duplicate title (or spoiled), $1.00 Notary fee for duplicate application.
What vehicles need a federal odometer statement?
Vehicles that are 10 model years old or newer. Currently 2003 to present. The odometer statement is part of the title document.
My vehicle has an out-of-state title, does it need to be inspected in order to register it?
Yes, unless you are non-resident military (then see below).
I am moving in from another state, what do I need to obtain Nebraska plates?
Original out-of-state title, proof of insurance, vehicle inspection ticket, and security agreement (if lien).
I am a non-resident (military) and have another state title and registration, do I need to change to a Nebraska title?
No, you will need proof of registration, insurance, Military ID, and the last end-of-month L.E.S. statement so that we can register your non-resident vehicle.
What does the vehicle inspection entail?
Only the Vehicle Identification Number (VIN) is checked to ensure that it matches the title. The VIN is also checked for stolen vehicles.
What is the fee for an inspection?
Does Nebraska require a notary to transfer title?
No, not since July 16, 1994.
Are the vehicle inspectors open the same hours as your office?
No, they close fifteen minutes earlier than we do.
Is vehicle inspection in the same building as the County Treasurer?
Yes, it is located on the southeast side of the main courthouse about forty feet east of the Treasuer's Office.. There is VIN parking on the very east side of the building.
My title reads "OR/AND OR". Do both of us have to sign-off the title?
Yes, Nebraska requires signatures of ALL persons listed as owners to transfer ownership.
What is required to note a lien?
A signed copy of the security agreement or contract between buyer and lien holder and the $7.00 fee.
I have paid off my vehicle and the bank has sent me the title, do I need to do anything with the County Treasurer's office?
Yes, the original title must be brought in (or mailed in) to the County Treasurer's office for release. The title can be taken to any County Treasurer's office in the state for release of the lien. We will need to see the release on the face of the title or a notarized lien release from the lender. There is no fee for lien release.
Do I need to change my title when I move from one county in Nebraska to another?
No, Nebraska titles are valid in any county in the state.
Can I pay for title and plates with my credit card?
No. Cash, local check, or money orders will be accepted.
I have signed-off a title on the wrong line, can I cross it out and sign on the correct line?
No, erasures or alterations VOID a Nebraska title. A spoiled (duplicate) must be issued.
Can I get a duplicate title from another county?
Yes, beginning January 2, 2003 you can obtain a duplicate Nebraska title in any county.
I have a lien on my out-of-state title, how can I register my vehicle?
We need the name and address of your lien holder and the vehicle registration or you can fill out the request at our web page Customer Request For Out of State Title. If you provide us with the information we will send for the original title and security agreement. If you use the Customer Request For Out of State Title form, then you mail it directly to your lien holder. Upon receipt of this paperwork you will be send a post card notifying you that the vehicle must be inspected. The Nebraska title will be issued and sent back to the lien holder. A licensing copy will be available for you to obtain your plates. There is a $17.00 title/lien notation fee.
Can my lien holder fax a copy of my title to issue the new Nebraska title?
No, the original documents are needed to issue a new Nebraska title.
I changed my name as a result of marriage, divorce, or etc. Do I need to change my title or registration?
Change as a result of divorce; the party receiving the vehicle should bring a copy of the divorce settlement and the old title and obtain a new title and registration.
If due to marriage it is up to the individual. However, to change the name on the registration requires that the title be changed also. Bring the old title and certified marriage license to obtain a new title and registration. If name is changed for another legal reason, bring in the certifying document for our review.
One of the owners on the vehicle is deceased. Do I need to change the title or registration?
That is up to the remaining owner(s). However, to change the registration the title must be changed. Bring in the old title and death certificate to change the title and registration.
Mail Title Desk Phone: 402/593-2108
Fax: 402/593-4360
Office is open to the public
8:00 a.m. - 4:45 p.m.
8:00 a.m. - 6:00 p.m.


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Practical, versatile and when you buy from SofaSofa, affordable, loose cover sofas are a great choice for families.All our loose cover models can be purchased with extra loose covers so you can change the appearance and style of your living room simply by changing the covers. And if disaster strikes, made to measure replacement covers are always readily available for our range of loose cover designs. Fully removable and machine washable at 30°
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Filed under: BCWJ Page & Stage, Dramaturgy, Theatre | Tags: Anne Hamilton, BCWJ Page & Stage, Hamilton Dramaturgy, The Theatre Times
I am writing to announce that this will be my last Bucks County Womens Journal Page & Stage column. For several years, I have shared the space with my talented colleague, Linda Wisniewski, whose memoirs, essays, and short stories I greatly admire.
In this column, I have written about the process of playwriting, about festivals, about area playwrights, and simply, about imagination.
Now I will be leaving Bucks County, my home of 13 years, and relocating to central New York. I will miss writing my 400-word assignment here every other month, but will continue to publish and commission articles as the Dramaturgy editor of The Theatre Times, an online global theatre journal (www.thetheatretimes.com). For that journal, I am in the midst of a two-part article on the process of dramaturgy in the New York Musical Festival, which takes place in NYC every summer. I am also writing about virtual reality on stage, and archiving women's work at the New York Public Library's Performing Arts Library at Lincoln Center.
Since I pitched the idea of writing a column about plays and playwrights to BCWJ's Editor Robin Coppinger, I have had the pleasure of advancing in my own theatre career. My drama WHO'S ANDY WARHOL? won a production in London in the Sky Blue Theatre's Cambridge Theatre Challenge, my short pieces OFEM and THE SHOEBOX were read across the country and produced in Arizona as winners of the Little Black Dress INK Female Playwrights ONSTAGE project, and I have served as a nominator for two years for The Kilroys List, which vets and promotes plays by female and trans playwrights, and playwrights who identify as female.
I have found that submitting my own plays for festivals and productions, as well supporting companies by reading entries for other fellowship and festival opportunities, helps me to remain connected to the developments and trends in the field.
And yet – I get the most enjoyment out of writing my own pieces, and maturing as a playwright and poet. Right now, I am developing I WANT TO RUN AWAY WITH YOU and RHODESIAN RIDGEBACK with NYC-based actor and director Ellen Barber.
As you can see, little by little, the path is created. Keep writing and maturing. Good luck!
Anne Hamilton has 26 years of experience as a dramaturg. She is available for script consultations and career advising through email@example.com.
Filed under: BCWJ Page & Stage, NYC Theatre, Playwrighting Awards, Script Development, Theatre | Tags: Advocacy for Women, Anne Hamilton, Dramaturg, Dramaturgy, Gender parity, Genne Murphy, Hamilton Dramaturgy, New Roles for Women, NYC, Playwright, Script Development, The Lilly Awards, Women Theatre Artists, Works by Women, Yale School of Drama
Here is my latest Bucks County Womens Journal article. Download it Anne Hamilton's BCWJ Profile of Genne Murphy.
Profile of Genne Murphy
By Anne M. Hamilton, MFA
Genne Murphy is a rising star in the theatre world. Her plays have been developed or produced in Nebraska, Colorado, New York and Connecticut as well as locally. The Azuka Theatre produced HOPE STREET AND OTHER LONELY PLACES.
Recently, she was honored with the Leah Ryan Fund for Emerging Women Writer's Award for her play GIANTESS at the Lilly Awards, hosted at the Signature Theater in New York City. The Lilly Awards celebrate significant contributions by women to the American theatre, including 2016 honorees Danai Gurira, Jesse Mueller and Martha Plimpton.
Born and raised in Philadelphia, Murphy has been deeply involved as a writer and arts educator since graduating from Central High. Her many local awards and affiliations include the Philadelphia Young Playwrights, PlayPenn, and the Leeway Foundation Transformation Award/Art and Change Grant.
Originally, she says, the idea for GIANTESS came in a dream: "I was trying to pour water into a tiny glass and it was really annoying. Then all of a sudden I realized, 'OMG I'm a giant!' I panicked, woke up. [The dream] really stuck with me–that idea of being so discombobulated and feeling extremely uncomfortable in your body. I thought there were a lot of interesting metaphors to explore."
Described by the Leah Ryan FEWW program as having, "truly singular and theatrical voice," Murphy will workshop her play with a few closed-door readings at Primary Stages in New York City and New York Stage and Film before the Fund presents a full public reading in the fall.
"GIANTESS starts with a young woman who is taking care of her ailing, disabled grandmother," says Murphy. "Early on in the play she discovers a girl her own age in the abandoned factory behind her grandmother's house – a 30-foot tall giantess. They develop a deepening connection to one another in this very fraught and heightened situation."
Reflecting on her time with Philadelphia Young Playwrights, she states, "My experience, [as] a student, educator, and staff member enabled the idea of revision – the actual work of revision – to be a less scary prospect."
She holds a bachelor's degree from NYU's Tisch School of the Arts and is currently an M.F.A. candidate in playwriting at the Yale School of Drama.
Anne Hamilton has 25 years of experience as a dramaturg. She is available for script consultations and career advising through firstname.lastname@example.com.
Filed under: BCWJ Page & Stage, Career Advising, Dramaturgy, Memoir, Script Development | Tags: @AnneHamiltonlit, Anne Hamilton, Annie Liebovitz, BCWJ, BCWJ Page & Stage, Dramaturg, Dramaturgy, Freelance Dramaturgy, Hamilton Dramaturgy, Playwright, www.hamiltonlit.com
Please note: I am continuing my practice as a freelance dramaturg with Hamilton Dramaturgy. The office is still open! I am still actively pursuing the activities that I have conducted for 24 years – freelance dramaturgy, script development, research, career advising. I am accepting new clients. firstname.lastname@example.com
Here is my last Bucks County Women's Journal column – Page & Stage (October/November 2015, column shared with Linda C. Wisniewski)
Creativity Through Planned Reflection
By Anne M. Hamilton, MFA
Last summer I made a conscious effort to set aside time to clear my mind. I took a short hiatus from my dramaturgy practice after teaching the playwriting workshop at the Philadelphia Writers Conference in June. Planning the break took a great deal of effort, because it involved notifying all of my writers and editors that I would not be available for a short while.
As an adult, I find that I have to work twice as hard to find space to rest. Yet if I don't rest, I can't regenerate. During my deliberate break, I looked to other women for inspiration. I read photographer Annie Leibovitz's PILGRIMAGE, a thick coffee table book with photos that she took not on assignment, but from her own sense of interest. She began by visiting writers and artists' studios, and then began to photograph landscapes and objects. Some of the creative settings belonged to Emily Dickinson, Virginia Woolf, Louisa May Alcott and Georgie O'Keeffe.
I returned to some of the things I love to do most. I took a trip to the sea, I visited old homes and churches, and bought fresh produce from local farmers. I walked in strange cities. I took road trips. I walked by rivers and looked at the scenery. I spent more time with people I love and avoided the ones who cause me stress.
What does all of this have to do with what's happening on stage in Bucks County? Well, what eventually appears on the stage comes from the heart, mind and hands. I did an experiment to change the foundations of my thinking and perceptions.
As a playwright, I don't know yet what kind of new stage work this break will inspire; I didn't write anything new during my hiatus. Yet I noted the journeys taken by every one of the women in Leibovitz's book – whether of isolation, wandering, or exploration.
As Amy Goodman recently said, "Go into the silence."
Anne Hamilton has 24 years of experience as a dramaturg. She is available for script consultations and career advising through email@example.com. Her drama THE SHOEBOX is a winner of Little Black Dress INK's 4th Annual Female Playwrights Onstage Project – OUTSIDE THE LINES – National Festival of New Work. It was read in Minneapolis and Los Angeles and received a production in Arizona in August.
Dowload the article here: BCWJ Article -Creativity Through Planned Refection by Anne Hamilton
Filed under: Career Advising, Dramaturgy, Gender Parity | Tags: #genderparity, 50/50 in 2020, @AnneHamiltonlit, Advocacy for Women, Anne Hamilton, Dramaturg, Dramaturgy, Freelance Dramaturgy, Hamilton Dramaturgy, Virginia Woolf
Please note: I am continuing my practice as a freelance dramaturg with Hamilton Dramaturgy. The office is still open! I am still actively pursuing the activities that I have conducted for 24 years – freelance dramaturgy, script development, research, career advising. I am accepting new clients. email@example.com
Redirecting My Energies to Become A Woolf Woman
By Anne M. Hamilton, MFA
© 2015
I am about to lay it down, so listen up. I will speak in the vernacular so that everyone will understand.
It is September 13, 2015. There are less than 5 years left before 2020 arrives. That's 4 years, 3 months, 2 weeks and 5 days. In total there are 1,570 days. I support the 50/50 in 2020 movement. But the clock is ticking and desperate times call for desperate measures. We have made great strides, but it looks like we are not going to make it.
I realize that the foundation for gender parity is set. I, for my part, will now go back to the old-fashioned notion of making one's way in the world in a practical way.
I love being effective. I have skin in the game. I take every available measure to achieve every goal I set.
Therefore, I am taking these extraordinary measures to help achieve gender parity:
- I am not working with any company, festival or organization that does not have a policy in place (or in the works) for gender parity – or heritage parity for that matter (read that statement in theatre speak as "a diversity program")
- I am resigning from organizations which I don't feel are living up to their mission statement.
- I am refraining from spending time or volunteering time for "awareness" efforts. We are aware. We are just not effectively setting, pursuing and achieving our goals.
- I am not participating in shaming organizations that don't have gender parity goals. Unless they are breaking the law, their use of their own resources is their choice and they are entitled to that.
Now – here is my "I Am" list
- I am diligently focusing on creating an income stream with my talents. That means that I am actively writing my own properties that I will have control over and I can sell: plays, musicals, children's stories, essays and poetry.
- I am spending my time creating income for myself as a freelancer.
- I am seeking representation for my properties.
- I am diligently sending out my work using all the submission opportunity information that is readily available at this point in time.
Recent history shows us that boycotts and strikes sometimes do work in powerful ways. If enough of us make it a policy to spend our talents, earn our dollars – and spend our dollars – in places that please us, we will create a more equitable environment. Gender parity – and heritage parity – are rights.
Perhaps if enough of us step away from the places that don't please us, and work to create an equal presence in the places (and organizations) that do, we can create a more equitable environment for everyone.
Becoming a Woolf Woman
Now – I want to remind us all of Virginia Woolf's statement beginning, "Give her a room of her own and five hundred a year…"
Virginia Woolf delivered a set of lectures at Cambridge University in 1928. These lectures became the basis for "A Room of One's Own" which was published the following year. We have all read that book. What a woman needs, she said, is an income of £500 and a room of one's own.
Today in US dollars, that amount is approximately $53, 500. Add a taxation rate of 28% and the minimum amount of earnings is $68,480. (If one earns approximately $68,500 and pays one's taxes on time, she will end up with about $53,500 as a net income to actually utilize.)
Now – let's think about Virginia Woolf's premise that someone should "give" a woman a room of her own and five hundred a year. In Woolf's scenario, someone should give her that money. It is passive, guaranteed income. She does not have to earn it. In addition, the woman is to be left alone, without household or any other responsibilities, simply to write. For her whole lifetime. Woolf's scenario presupposes that maids, gardeners, housecleaners, cooks and servers are providing all of the necessary daily services to the woman. In addition, all other medical, legal and other professional needs would also be paid for. To fund a staff for one's household today – well, let's just say that the figure needed would probably triple.
Woolf's "Her" does not work outside the home – she does not lecture, teach, direct, dramaturg, take day jobs, write articles, make speeches, or volunteer for "the cause". She uses her time solely according to her own discretion. She is not obligated to do anything but sit and write in order for Woolf's scenario to become reality – that a great piece of literature might be written.
Now – I know a few women who are in this position, but I am not. I need to keep a roof over my head. Virginia Woolf was wealthy and had social status by birth and by marriage. She was born into a patriarchal society and was given an inhimitance. It was given to a her, but it was given by a him. At this point in history, as theatre artists in the 21st century, a scant 100 years after women were even given the right to vote, we are still being grandfathered in to the social and economic environment.
We have be grandfathered into the workplace of the theatrical profession, by dint of our place in history, and we have to create a new legal, social and economic environment for ourselves. We must heed Virginia Woolf's statement about having income and a room of one's own, and also her unintentional assumptions about the realities of patriarchal support. In order to take advantage of her wisdom and insight, we must make enough money to pay for our own expenses throughout our lifetimes, and build wealth, and leave an inheritance for someone else. That is what keeps the system, and the parity going.
So much work has been done to change the legal environment in the past 100 years so that women can own property, obtain a loan, work outside of the home and retain an inhimitance in issues surrounding marriage and divorce.
As you see – the English language at present doesn't even accommodate the reality of our situation. So let's add words to the language, change the paradigm, and create a new social and economic environment based on leaving not only laws, but wealth and property, to others that we care about.
The basis of that parity starts with wealth. Money. For some of us, income earned by working. I don't have children, but I want to leave an inheritance to someone. And I surely need to cover my living expenses while I am alive. So I am doing everything I can to build my own resources and parity. It is my privilege and my challenge to take advantage of my position in history. But mostly my privilege, and I am taking advantage of it with the time I have.
So how am I going to be a "Woolf Woman" today?
I am going to buckle down and focus. I am eliminating distractions. I am shutting out the emotional siren calls of outrage and bitterness. Woolf spoke rationally and I think that has contributed to the way that her message has endured. She looked at practicalities. And she gave me a basic outline, which I have updated for my own use.
I am combining Woolf's 86-year-old enlightened message with 50/50 in 2020's modern one. I seek to earn $75,000 per year (padding the figure for inflation) by 2019. That will make me a "Woolf Woman" by January 1, 2020, and begin to set the stage for some literary achievement.
The key to being a Woolf Woman is financial. For me, it means paying off my mortgage, creating passive income through securing royalties for my properties, and eliminating debt. Creating stability. Having income-producing investments. Owning property. Reducing costs. Increasing income.
My formal education is complete. I earned an MFA from Columbia and a BA from Drew University. I have been a college professor. I have worked in corporations, as a senior staff member at a university, and as a public relations director, a publications manager, as an editor, as a writer, a singer, an actress, a dramaturg, and a financial advisor. I am single. I own a house. I own a car. I don't have children. I am a freelance theatre professional.
If we as women are going to speak out with power and effectiveness, we must find our way into mainstream culture. And that requires financial independence. How did others do it? Often they were supported by private wealth, inheritances, their spouses or significant others, their churches or other religious and civic organizations. I do not have those support systems. I have to earn it myself.
It is time to get back to basics. Arranging my life to give myself that income of £500 a year. I have a room and I use it. Now it is time to get creative.
And by the way, if you have found value in this article – if it has helped you to focus – send me $5 (or more!) through paypal to email@example.com. I'm starting right now to earn passive income.
Anne Hamilton is a NYC-based freelance dramaturg and the Founder of Hamilton Dramaturgy, an international consultancy. She holds an MFA from Columbia University School of the Arts, and has worked with Andrei Serban, Michael Mayer, Lynn Nottage, NYMF, Niegel Smith, and Classic Stage Company. She created Hamilton Dramaturgy's TheatreNow!, and her specialties include new play development, production dramaturgy, new musicals, career advising, advocacy, and oral histories. She was a Bogliasco Foundation Fellow. www.hamiltonlit.com
Download the article here: Redirecting My Energies to Become a Woolf Woman by Anne Hamilton, M.F.A.
Filed under: Career Advising, Dramaturgy, MFA, NYC Theatre, Recent Successes, Script Development | Tags: @AnneHamiltonlit, American Theatre, Anne Hamilton, Dramaturg, Dramaturgy, Educator, Gender parity, Hamilton Dramaturgy, Magda Romanska, THE ROUTLEDGE COMPANION TO DRAMATURGY, www.hamiltonlit.com
American Theater magazine has given a terrific review to THE ROUTLEDGE COMPANION TO DRAMATURGY, edited by Magda Romanska.
My article, "Freelance Dramaturgs in the Twenty-First Century – Journalists, Advocates, and Curators" garnered praise from the reviewer Philippa Kelly: "One of the book's highlights is Anne Hamilton's essay on who dramaturgs are and what they do: cross boundaries, multitask, act as officers of public liaison and conduits for outreach…Hamilton aims to inspire dramaturgs to build confidence in their own creative contributions, and to reach deeper, to act more broadly and boldly."
I am sending many thanks to Magda for including my chapter in this volume. It has sold out in hardcover, and is now available in paperback for $39.99. (ISBN-13: 978-0415658492, ISBN-10: 0415658497)
Filed under: BCWJ Page & Stage, Dramaturgy, Gender Parity, New Work by Anne, Playwrighting Awards, Recent Successes, Script Development | Tags: @AnneHamiltonlit, Anne Hamilton, BCWJ, BCWJ Page & Stage, Dramaturg, Gender parity, Hamilton Dramaturgy, Little Black Dress INK, New Roles for Women, New Works, Playwright, Playwrighting Awards, www.hamiltonlit.com
By Anne M. Hamilton, MFA
For the past year I have had the pleasure of being involved in Little Black Dress INK's Female Playwrights Onstage Project.
Now in its fourth year, the competition is the brainchild of Playwright and Educator Tiffany Antone, who currently resides in Texas. This national festival of new work has a different theme each year and utilizes a peer review process to identify semi-finalists, whose short plays or monologues are then read in different cities across the country. Finalists are chosen from those events. They enjoyed a staged reading at the Los Angeles Theatre Center last year, followed by a production in Arizona in January.
In 2014, the theme was Planting the Seed, and my play OFEM, inspired by my experience as a CSA member at Blooming Glen Farm, was a finalist. It was read in Ithaca, NY, and Los Angeles before being given its premiere in Arizona. Indie Theatre Now will publish OFEM and all the finalists in an online volume of 11 plays.
This year's theme is Outside the Lines, and my two character drama THE SHOEBOX is a semifinalist. This short play reunites two high school classmates to reminisce in a late night phone call after their homeroom teacher, a nun, has passed away. Theater Unbound in Minneapolis gave it a staged reading along with five other pieces in March. The festival is still unfolding in events across the country.
Tiffany summarizes her goals on her website: "Little Black Dress INK is an experiment in support, inspired by recent revelations in numbers on the subject of just how few female playwrights actually get produced. Through outreach, education, and producing opportunities, Little Black Dress INK strives to create more production opportunities for female playwrights while also strengthening the female playwright network."
I have found this competition to be a highly effective and rewarding way of reaching those goals. It grows every year, and currently involves 35 new plays and over 60 artists in eight cities. 2016 submission guidelines will be posted on www.littleblackdressink.org on October 1, 2015.
Anne Hamilton has 24 years of experience as a dramaturg. She is available for script consultations and career advising through firstname.lastname@example.com. Her play WHO'S ANDY WARHOL? was performed at The Lost Theatre in London in October, 2014. She will teach a playwriting workshop at the Philadelphia Writers Conference in June 12-14, 2015.
To be published in Anne's Page & Stage column in the Bucks County Women's Journal (April/May 2015 issue). www.buckscountywomensjournal.com
Filed under: Career Advising, Dramaturgy, Gender Parity, Recent Successes | Tags: @AnneHamiltonlit, @LMDAmericas, American Theatre, Anne Hamilton, Dramaturg, Dramaturgy, Gender parity, Hamilton Dramaturgy, LMDA, www.hamiltonlit.com
Follow the session at @LMDAmericas! #genderparity
Anne Hamilton is a NYC-based freelance dramaturg and the Founder of Hamilton Dramaturgy, an international consultancy. She holds an MFA from Columbia University School of the Arts, and has worked with Andrei Serban, Michael Mayer, Lynn Nottage, NYMF, Niegel Smith, and Classic Stage Company. She created Hamilton Dramaturgy's TheatreNow!, and her specialties include new play development, production dramaturgy, new musicals, career advising, advocacy, and oral histories. She was a Bogliasco Foundation Fellow. www.hamiltonlit.com
Questions from LMDA
What is your "focus" for the week?
During the week of March 2-8, 2015, I will tweet about several of the projects I am currently working on, as well as the recent triumphs of the playwrights for whom I have dramaturged. I think it is important to communicate the range of projects and locations that my freelance dramaturg's practice involves. My projects as a dramaturg this week will include: Volunteering for the musical THE CALICO BUFFALO by EJ Stapleton, Peter Stopschinski in the New York Musical Theatre Festivals Next Link Project (to be produced in NYC in July); Giving feedback to Anita Gonzalez and Richard Allen on their new musical LIVERPOOL TRADING, and leading a Question and Answer session for their reading in the 6th Potpourri World Women Works Series (March 8, 3pm, NYC); and consulting with a first-time screenwriter. I will also list several of the accomplishments and upcoming shows of my dramaturgy clients including: the upcoming NYC production of Jack Karp's IRREVERSIBLE and Crystal Jackson's SYNCHRONICITY; and the recent reading of Tom Cavanaugh's ADAM & YOSHI (directed by Stebos) for Artistic Director Jim Simpson at the Flea Theatre in NYC. Also, for my own development as an emerging playwright, I will be completing tasks for my drama THE SHOEBOX, which is a semi-finalist in Little Black Dress INK's ONSTAGE PROJECT; and preparing a script for publication in England. Finally, I am waiting to hear some news this week on a couple of matters, so I'm hoping there will be some surprise announcements.
What is your definition of dramaturgy?
I describe myself as a literary and historical advisor to playwrights, directors, producers, and theatre companies.
What is your favorite or dream project?
My favorite project is the one I am working on in the moment. I enjoy a range of activities, from script development, to production dramaturgy, to developing new musicals, to research, to hosting TheatreNow!, to advising young artists on developing their careers. I enjoy learning and taking advantage of new technologies to help broaden the definition and practice of the profession.
Filed under: Dramaturgy, Gender Parity, NYC Theatre, Recent Successes, Script Development, Women Theatre Artists, Works by Women | Tags: @AnneHamiltonlit, Anne Hamilton, Bernadette Cochrane, Columbia University, Columbia University School of the Arts, DJ Hopkins, Editor, Freelance Dramaturgy, Hamilton Dramaturgy, Katalin Trencsényi, Magda Romanska, NYC, Routledge Companion to Dramaturgy, Women Theatre Artists, Works by Women, www.hamiltonlit.com
On January 21st, I will speak on a panel for a book launch to be held at my alma mater, Columbia University School of the Arts. Please join us!
Filed under: Career Advising, Dramaturgy, Gender Parity, HD Clients, Recent Successes, Script Development, Testimonials, Theatre, Women Theatre Artists, Works by Women | Tags: @AnneHamiltonlit, African-American Theatre, American Theatre, Anne Hamilton, Asian, Dramaturg, Dramaturgy, Great Plains Theatre Conference, Hamilton Dramaturgy, New American Plays, New Play Competition, New Play Festival, Script Development, www.hamiltonlit.com
"Anne has worked with GPTC playwrights for several years and has been lauded for her commitment, care and insight. She brings a great body of experience and a love of the theatre to every script that she works on."
-Kevin Lawler, Artistic Director, Great Plains Theatre Conference, Omaha, Nebraska. USA.
Filed under: Dramaturgy, Gender Parity, New Work by Anne, Playwrighting Awards, Recent Successes, Script Development, Theatre, Women Theatre Artists, Works by Women | Tags: @AnneHamiltonlit, Anne Hamilton, British Theatre Challenge winner, Cambridge Theatre Challenge, Dramaturg, Dramaturgy, Gender parity, Hamilton Dramaturgy, London Theatre, New Roles for Women, New Works, Playwright, Playwrighting Awards, Script Development, WHO'S ANDY WARHOL?, Works by Women, www.hamiltonlit.com
WATCH HERE – https://www.youtube.com/watch?v=qVUzz0EJq5E
It's up! A video of the production of my short play WHO'S ANDY WARHOL?, which was performed at the Lost Theatre in Wandsworth, London on October 24th. This is one of the 10 winning plays from the British Theatre Challenge. the International New Writing Competition by the Sky Blue Theatre Company of Cambridge, England.
WHO'S ANDY WARHOL? portrays a medical crisis which redefines the relationship between two lovers when one contracts transient global amnesia.
I am very happy with the production, especially the actors Chris Towner-Jones as Matt, and Lizzie Stanton as Sarah. What a joy it is to watch my words come to life! I hope that you enjoy this piece produced by Mini Mammoth Films. This is the first of the winning plays to be posted on youtube.
Special thanks to Anne Bartram of Sky Blue, and Rah Petherbridge, the UK-based photographer who took these wonderful stills below.
If you would like to read the play, please contact me at email@example.com. Thank you for watching!


text:
Symcat is a web service that will attempt to diagnose what ails you. All you have to do is type in your symptoms, and the service will try to match it to diseases are most commonly associated with your collection of problems. It can be quite helpful for doing research, but you definitely want to consult a real physician before deciding you have cancer or bubonic plague.
There are hours of amusing fun to be had here plugging in symptoms and seeing what comes out. As long as you aren't a hypochondriac, in which case you will immediately have a meltdown when you find out that a sore throat could be a cold . . . OR IT COULD BE ACUTE RESPIRATORY DISEASE. You can also watch people's symptoms in real time, to find out if everybody in the world has achey toes today. Which apparently they do, at least when I last checked.
Go ahead — try out Symcat.