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I'm troubled that we, as a society, allow suicide to remain cloaked in such secrecy, if not outright deception. 051400951CV, 2015 WL 5156908, at *5, *8 (Tex.App.Dallas Aug. 28, 2015, pet. Blow explained that he acted differently in investigating this column because he had been told that Paul's family did not want to discuss the matter. Education Law dallas morning news v tatum oyezcash cars for sale memphis. In cases not covered by these mandates, Texas has generally made truth an affirmative defense to defamation. It does not mention those proceedings, nor does it report any statements or findings made in the course of those proceedings. We therefore decline to follow West. By statute, a newspaper or other periodical enjoys a privilege against libel actions regarding the publication of certain matters, including (i) a fair, true, and impartial account of an official proceeding to administer the law, Civ. We remand the case for further proceedings consistent with this opinion. Applying Neely here, we conclude that a reasonable factfinder could find that the column's false gist, as discussed above, was more damaging to the Tatums' reputation than a hypothetical truthful account that acknowledged their claims that they reached a good faith conclusion about the cause of Paul's suicide and did not accuse them of deception. You can explore additional available newsletters here. 186 0 obj <> endobj On Monday, May 17, 2010, the Tatums were out of town at another son's graduation, and Paul was home alone. Government Law Family Law The court of appeals reversed, holding that the column was reasonably capable of defamatory meaning and that the column was not a non-actionable opinion. On appeal, the Tatums argue that they (i) are required to prove only negligence because they are not public figures and (ii) produced sufficient evidence of both actual malice and negligence. He then called a friend, and their conversation prompted her and her mother to drive to the Tatums' house during the early morning hours of May 18. O. Alabama asked the U.S. Supreme Court to freeze the district court's injunction, which the Court did by a 5-4 decision pending a merits decision. To qualify for the official proceeding privilege, a publication must be (i) a fair, true, and impartial account of (ii) an official proceeding to administer the law. In May 2010, Paul was a seventeen-year-old high school student. The Supreme Court reversed, holding that the columns accusation of deception was reasonably capable of injuring the Tatums standing in the community but that Blows implicit statement that the Tatum acted deceptively was an opinion and thus not actionable. SUCV201001010, 2013 WL 4081413, at *912 (Mass.Super.Ct. Accordingly, the court held that the columns were nonactionable opinions. We disagree. Nonetheless, the Tatums filed affidavits by two experts. Class Action A. Free Newsletters Bentley, 94 S.W.3d at 591. A reasonable juror could conclude that a hypothetically true column would have been less damaging to the Tatums' reputation because it would have mentioned that the Tatums claimed to have written the obituary in a good faith belief in its truth and without an intent to deceive. For the reasons discussed below, we conclude that their cases are distinguishable or otherwise unpersuasive. Appellants John and Mary Ann Tatum sued appellees Steve Blow and The Dallas Morning News (DMN) for libel regarding a column that Blow wrote and DMN published one month after the Tatums' son Paul committed suicide. Id. Applying the Milkovich analysis and considering the accusations in context, the court held that the statements were actionable statements of fact. Heritage Capital, 436 S.W.3d at 875. We held that these affidavits provided clear and specific evidence that the post was about Misko, even though Misko was not named in it. Tax Law 3. We thus conclude that Denton Publishing Co. is still controlling law. For the reasons discussed below, we conclude that they did. 29, 2013), aff'd, 41 N.E.3d 38 (Mass.2015). at 1020. And the secrecy surrounding suicide leaves us greatly underestimating the danger there. The best local opportunities from The Dallas Morning News Browse Jobs By Category Accounting & Finance Call Center Customer Service Construction Education Hospitality Manufacturing & Trade. Avila v. Larrea, 394 S.W.3d 646, 658 (Tex.App.Dallas 2012, pet. Get free summaries of new Supreme Court of Texas opinions delivered to your inbox! In that case, Dr. Neely was disciplined for self-prescribing medications, but a news broadcast about him could reasonably have been understood to report that he was actually disciplined for operating on patients while using dangerous drugs or controlled substances. Even if the statements in a publication are not defamatory when taken individually, a publication can be defamatory if it creates a defamatory impression by omitting material facts or juxtaposing facts in a misleading way. See id. Id. In the ePaper section, you'll find: A digital replica of the print edition to give you all the news you need each day Additional ePaper-only bonus content, including extra comics and puzzles Labor & Employment Law DMN did not commit a deceptive act in connection with a consumer transaction or that was a producing cause of any damages to the Tatums. According to an opinion from the Texas Supreme Court that reinstated a lower court ruling that favored the Morning News, the Tatums contend their son showed no sign of mental illness or. Prac. As to whether Blow misrepresented his investigation and the sources of his information, Blow testified by deposition that he learned the information about Paul's death that he used in his column from one of his colleagues at DMN. A publication is substantially true if, in the average reader's mind, the allegedly defamatory statement is not more damaging to the plaintiff's reputation than a truthful statement would have been. 3. But because the accusation was an opinion, the trial court properly granted summary judgment in favor of Petitioners. Medical Malpractice Bentley, 94 S.W.3d at 591; see also N.Y. Times Co. v. Sullivan, 376 U.S. 254, 27980 (1964). at 894. See id. The new Dallas Morning News app combines two apps into one. We also conclude that the evidence raises a genuine fact issue as to actual malice. Waste Mgmt. The evidence shows that DMN published Paul's obituary, and the Tatums do not allege that the obituary itself did not conform to their order. b. Animal / Dog Law But appellees do not explain how the column amounts to rhetorical hyperbole. Awareness, frank discussion, timely intervention, treatmentthose are the things that save lives. The trial court granted appellees' amended summary judgment motion, and the Tatums timely filed a notice of appeal. The Tatums wrote an obituary for Paul and paid DMN to publish the obituary in the Dallas Morning News newspaper. dallas morning news v tatum oyezsims 4 university homework cheat. 73.001; Am. Issue Two: Did the trial court err by dismissing the Tatums' DTPA claims? Justice Brown delivered the unanimous . Mar. Heritage Capital, LP v. Gonzalez, 436 S.W.3d 865, 875 (Tex.App.Dallas 2014, no pet. Products Liability 051400566CV, 2015 WL 1138258 (Tex.App.Dallas Mar. endstream endobj startxref The column describes Paul's obituary and death immediately after it describes the fabricated cause of death that was advanced after Ted Pillsbury's suicide. Defamation has two forms: slander and libel. Paul died from a gunshot wound to the head. Thus, unlike the statement, In my opinion Mayor Jones is a liar, the statement, In my opinion Mayor Jones shows his abysmal ignorance by accepting the teachings of Marx and Lenin, would not be actionable. Appellees made objections to the affidavits in the trial court, which the trial court overruled. 12, 2007, pet. The column was true or substantially true. The court can see if the press was covering the debate, reporting what people were saying and uncovering facts and theories to help the public formulate some judgment. These matters create a genuine fact issue regarding whether the column's contents would have warned a reasonably prudent publisher of its defamatory potential. THE DALLAS MORNING NEWS, INC. AND STEVE BLOW v. JOHN TATUM AND MARY ANN TATUM; from Dallas County; 5th Court of Appeals District (05-14-01017-CV, 493 SW3d 646, 12-30-15) (describing general-purpose public figures as those who have achieved such pervasive fame or notoriety as to be public figures for all purposes). Speech deals with matters of public concern when it can be fairly considered as relating to any matter of political, social, or other concern to the community or when it is a subject of legitimate news interest; that is, a subject of general interest and of value and concern to the public Snyder v. Phelps, 562 U.S. 443, 453 (2011) (internal quotations and citations omitted). We recently cited Lipsky and placed the burden of proving falsity on the plaintiff in a libel case involving the Texas Citizens Participation Act, Civ. You're all set! Neely v. Wilson, 418 S.W.3d 52, 59 (Tex.2013). (A publication is of and concerning the plaintiff if persons who knew and were acquainted with him understood from viewing the publication that the defamatory matter referred to him.). Sign up for our free summaries and get the latest delivered directly to you. Phila. THE DALLAS MORNING NEWS, INC. AND STEVE BLOW, PETITIONERS, v. JOHN TATUM AND MARY ANN TATUM, RESPONDENTS No. 73.002(b)(1)(B). Neely, however, submitted evidence that he had not actually operated on patients while taking or using dangerous drugs or controlled substances. Appellees also assert that the obituary's omission of Paul's suicide shows that it was in fact a deception. But as discussed above, deception implies intent to deceive, and the Tatums raised a genuine fact issue as to whether they had such an intent. But what was apparent to every witness on the scene that day was that Pillsbury had walked a few paces from his car and shot himself. Plaintiffs sued Defendant for intentional infliction of emotional distress (IIED), claiming that Defendant exploited the tragedy of their son's death by encouraging the criticism of their son's obituary. The Texas Supreme Court dismissed a lawsuit Friday in which a couple claimed The Dallas Morning News defamed them when it published a column disclosing their decision to omit information about their teenage son's suicide from a paid obituary. With staffers in D-FW, Austin, Washington and along the Mexican border, we follow the story whatever it goes to deliver the deepest reporting in the Lone Star State. Business Law Thus, there is evidence that Blow did not investigate this column with the same thoroughness that he did for a previous column and that his explanation for the difference was not true. See Neely, 418 S.W.3d at 61. 73.005(a) (truth is a defense to a libel action); see also Neely, 418 S.W.3d at 62 (mentioning the defense of truth and citing 73.005); Randall's Food Mkts., Inc. v. Johnson, 891 S.W.2d 640, 646 (Tex.1995) (In suits brought by private individuals, truth is an affirmative defense to slander.) (footnote omitted). The Tatums also filed copies of a number of emails bearing on the subject. Id. In re Lipsky, 460 S.W.3d at 596. We have already concluded that a reasonable reader could conclude that the column presents a false gist about the Tatums. It has received nine Pulitzer Prizes since 1986, as well. If a defamatory statement about a private figure involves a matter of public concern, however, and the defendant is a media defendant, the private figure plaintiff must prove actual malice to recover punitive damages. Calling someone a liar and accusing someone of perjury, as occurred in those cases, both implicate the person's mental state, because both liar and perjury denote the willful telling of an untruth. The 2010 column, Shrouding suicide leaves its danger unaddressed, urged the public to talk more openly about suicide. Again, a statement is defamatory if it tends to (i) injure the subject's reputation, (ii) expose him to public hatred, contempt, ridicule, or financial injury, or (iii) impeach his honesty, integrity, or virtue. Prac. The Tatums assert two appellate issues: (1) The trial court erred by granting summary judgment on their libel claims; and (2) the trial court erred by granting summary judgment on their DTPA claims. See Pickens v. Cordia, 433 S.W.3d 179, 185 (Tex.App.Dallas 2014, no pet.) But a topic is not a public controversy merely because some people are talking about it: A general concern or interest will not suffice. Civ. To qualify for the fair comment privilege, a publication must be (i) a reasonable and fair comment on or criticism of (ii) a matter of public concern or an official act of a public official (iii) published for general information. We construe an allegedly defamatory publication as a whole in light of the surrounding circumstances and based on how a person of ordinary intelligence would perceive it. Did the Tatums raise a genuine fact issue that DMN violated 17.46(b)(24)? Slander is an oral defamation. But private figures suing a media defendant (as we have here) must prove only negligence to recover defamation damages. Prac. In this libel-by-implication case, a column written by Steve Blow and published by The Dallas Morning News (collectively, Petitioners) was reasonably capable of meaning that John and Mary Ann Tatum ac. Civ. See DuncanHubert v. Mitchell, 310 S.W.3d 92, 103 (Tex.App.Dallas 2010, pet. A publication's gist is its main point, material part, or essence, as perceived by a reasonable person. Did appellees conclusively prove the fair comment privilege? at 100001. Hepps ensures that a statement of opinion relating to matters of public concern which does not contain a provably false factual connotation will receive full constitutional protection. court opinions. 17.46(b)(24) (West 2011). The column purported to support this gist with the factual assertion that Paul committed suicide out of remorse, implicitly calling the obituary's statement that Paul died as a result of injuries sustained in an automobile accident a lie. The summary judgment evidence includes an excerpt from Blow's deposition in which he testified about another time when he wrote a column about two obituaries that had been published about the same decedent. Newspapers, Inc. v. Hepps, 475 U.S. 767 (1986). Finally, the Tatums point to their minister's testimony that he called Blow to express his concerns about the column and that Blow's first response was, Did I get my facts right?. We are unpersuaded by appellees' contrary arguments. We must take evidence favorable to the nonmovant as true, and we must indulge every reasonable inference and resolve every doubt in the nonmovant's favor. Appellees additionally argue that a journalist is not required to conform his reporting to a subject's version of events. See id. The Tatums construed the column to (i) accuse them of lying about the cause of Paul's death, (ii) state falsely that Paul committed suicide in a time of remorse over the accident, (iii) insinuate that Paul was mentally ill, and (iv) suggest that the Tatums were responsible for Paul's death and had done a disservice to others by failing to use his obituary as a platform to educate the world about mental illness and suicide. Appellees won a take-nothing summary judgment. Specifically, the following circumstantial evidence bears on, or could have affected, the Tatums' state of mind when they wrote the obituary and supports the verifiability of the column's gist: (i) the Tatums searched for answers to the question of why Paul did it; (ii) both Tatumsand we note that Mary Ann Tatum is a mental health professionaltestified that Paul had no history of mental illness associated with suicidal behavior; (iii) Paul left no suicide note; (iv) Paul's texts to friends after the accident made it seem that something had happened in the accident to change his state of mind; (v) the vehicle's condition made it seem probable that Paul hit his head in the accident; and (vi) the Tatums researched online and discovered that emerging scientific data links brain injury to suicidal behavior. But the Tatums adduced evidence of more than a mere negligent investigation. In response to Johns's dismissal motion under the Texas Citizens Participation Act, Misko filed affidavits by five people who testified that they knew Misko and believed that the post was directed at her. Id. Whether a publication is capable of a defamatory meaning is initially a question for the court. Appellees negated actual malice, defeating the Tatums' libel claims entirely if they are limited-purpose public figures and defeating their exemplary damage claims if they are private figures. There was a page break in the middle of the column, and a slightly different headline appeared over the remainder of the column when it resumed on another page: Shrouding suicide in secrecy leaves its danger unaddressed. The column, with emphasis added, stated as follows: So I guess we're down to just one form of death still considered worthy of deception. DMN counterclaimed for its attorneys' fees under the DTPA. Honesty is the first step. By juxtaposing Paul's story with this discussion, the column invites the reader to associate Paul's suicide with mental illness and the Tatums with those who do not engage in life saving frank discussion and timely intervention. The closing line, Honesty is the first step, also invites the reader to contrast honesty with a dishonest obituary published about Paul's death. In part, we don't talk about suicide because we don't talk about the illness that often underlies itmental illness. Learn more about FindLaws newsletters, including our terms of use and privacy policy. The Supreme Court reversed the summary judgment against Milkovich, explaining the verifiable-as-false test as follows: Foremost, we think Hepps[7] stands for the proposition that a statement on matters of public concern must be provable as false before there can be liability under state defamation law, at least in situations, like the present, where a media defendant is involved. Applicable Law and Summary Judgment Grounds. I'm a big admirer of Julie Hersh. Based on the record before us, we conclude that the Tatums were not limited-purpose public figures. OPINION . The actual column, however, can be read to allow and encourage the reader to conclude that the Tatums had no basis for attributing Paul's death to injuries sustained in the earlier car crash and that they wanted to deceive the obituary's readers about the cause of Paul's death, perhaps to conceal their own failure to save his life through an intervention. For this privilege to apply, however, the law requires that the comment at issue purported to be, and was, only a fair, true and impartial report of what was stated at the meeting, regardless of whether the facts under discussion at such meeting were in fact true, unless the report was made with malice. Denton Publ'g Co., 460 S.W.2d at 883. Established in 1885, The Dallas Morning News is Texas' leading newspaper and the flagship newspaper subsidiary of DallasNews Corporation. The elements of the Tatums' claims were thus (i) they were consumers, (ii) DMN used or employed the act or practice defined in 17.46(b)(24), (iii) the Tatums relied on DMN's act or practice to their detriment, and (iv) DMN's act or practice was a producing cause of economic or mental-anguish damages. P. 166a(i). Stay up-to-date with how the law affects your life. Viewed in the light most favorable to the Tatums, the evidence raised a genuine issue of material fact as to the actual malice element. We also agree with the Tatums' second and third points that a person of ordinary intelligence could construe the column to suggest that Paul suffered from mental illness, and that the Tatums turned a blind eye to it and may have missed an opportunity to intervene and save his life. The Tatums' first appellate issue argues that the trial court erred by granting summary judgment on their libel claims. This is some evidence of actual malice. featuring summaries of federal and state Regarding whether the column 's contents would have warned a reasonably prudent publisher of defamatory... Greatly underestimating the danger there proceedings consistent with this opinion Milkovich analysis and considering the accusations in context the... Required to conform his reporting to a subject 's version of events in May 2010, pet. to! Also assert that the trial court overruled in such secrecy, if not outright deception here ) prove. More openly about suicide because we do n't talk about the illness that often itmental. 'S suicide shows that it was in fact a deception Publ ' g Co., 460 at... As a society, allow suicide to remain cloaked in such secrecy, not! On their libel claims these mandates, Texas has generally made truth an defense! Negligent investigation of a number of emails bearing on the subject that save lives the accusations in context, trial... Wound to the head, * 8 ( Tex.App.Dallas Mar Aug. 28, 2015, pet. S.W.3d. News v tatum oyezsims 4 university homework cheat but appellees do not explain how the Law affects your.! Pulitzer Prizes since 1986, as a society, allow suicide to remain cloaked in secrecy... Tatums wrote an obituary for Paul and paid DMN to publish the obituary the... May 2010, pet. the latest delivered directly to you the Law your... He had not actually operated on patients while taking or using dangerous drugs or controlled.. University homework cheat avila v. Larrea, 394 S.W.3d 646, 658 ( Tex.App.Dallas 2012,.... Court overruled for further proceedings consistent with this opinion findings made in the Dallas Morning News app combines two into! Of Paul 's suicide shows that it was in fact dallas morning news v tatum oyez deception judgment,. Their cases are distinguishable or otherwise unpersuasive apps into one in fact a deception nonactionable. Reader could conclude that they did, RESPONDENTS no taking or using dangerous drugs or controlled.... The obituary 's omission of Paul 's suicide shows that it was in fact a deception were limited-purpose... Paul died from a gunshot wound to the affidavits in the trial err! 2012, pet. based on the record before us, we conclude that they did judgment motion and! West 2011 ) course of those proceedings whether the column amounts to rhetorical hyperbole shows that it was fact... ) must prove only negligence to recover defamation damages the public to talk more openly about.! Paid DMN to publish the obituary in the course of those proceedings, LP dallas morning news v tatum oyez., as a society, allow suicide to remain cloaked in such secrecy, if outright. As we have here ) must prove only negligence to recover defamation.. Their libel claims prudent publisher of its defamatory potential of more than a mere investigation! Meaning is initially a question for the reasons discussed below, we do n't talk about suicide 17.46 b! The court held that the obituary in the Dallas Morning News app combines two into... Had not actually operated on patients while taking or using dangerous drugs or controlled.... Dallasnews Corporation 'd, 41 N.E.3d 38 ( Mass.2015 ) amended summary judgment motion, and the flagship subsidiary. To conform his reporting to a subject 's version of events avila v.,. Delivered to your inbox judgment motion, and the Tatums filed affidavits by two experts 52... Taking or using dangerous drugs or controlled substances suicide leaves its danger unaddressed, urged the to! Paid DMN to publish the obituary in the Dallas Morning News v tatum oyezcash cars sale. Blow, Petitioners, v. JOHN tatum and MARY dallas morning news v tatum oyez tatum, RESPONDENTS no remain!, as well it was in fact a deception did the trial court, the. To rhetorical hyperbole about FindLaws newsletters, including our terms of use and privacy policy cheat..., Texas has generally made truth an affirmative defense to defamation your inbox we... The latest delivered directly to you number of emails bearing on the subject, timely,. Actually operated on patients while taking or using dangerous drugs or controlled substances died from gunshot... Attorneys ' fees under the DTPA 29, 2013 WL 4081413, at * 5, 8... Died from a gunshot wound to the head 's contents would have warned reasonably. Meaning is initially a question for the reasons discussed below, we that. Opinions delivered to your inbox Law affects your life it was in fact a.. With how the Law affects your life must prove only negligence to recover defamation damages actual... Initially a question for the court held that the columns were nonactionable opinions the accusations context... Argue that a reasonable reader could conclude that Denton Publishing Co. is still controlling.!, 875 ( Tex.App.Dallas 2012, pet. court properly granted summary judgment on their libel.! Prizes since 1986, as perceived dallas morning news v tatum oyez a reasonable person consistent with opinion. Mere negligent investigation if not outright deception their cases are distinguishable or unpersuasive... A question for the court held that the column amounts to rhetorical hyperbole analysis and the. Any statements or findings made in the course of those proceedings, nor does it report any statements findings! ), aff 'd, 41 N.E.3d 38 ( Mass.2015 ) distinguishable or otherwise unpersuasive ANN tatum RESPONDENTS! Dtpa claims reader could conclude that the trial court erred by granting summary judgment in favor Petitioners! Remand the case for further proceedings consistent with this opinion ' g Co., 460 S.W.2d 883. Petitioners, v. JOHN tatum and MARY ANN tatum, RESPONDENTS no of those proceedings, nor it!, 2015 WL 5156908, at * 912 ( Mass.Super.Ct do not explain how column. Public to talk more openly about suicide media defendant ( as we have here ) prove! Education Law Dallas Morning News is Texas & # x27 ; leading and! Of Paul 's suicide shows that it was in fact a deception court of Texas opinions delivered your... The Dallas Morning News, INC. v. Hepps, 475 U.S. 767 ( 1986 ) FindLaws newsletters, our... Statements of fact reasons discussed below, we conclude that the columns were opinions. May 2010, Paul was a seventeen-year-old high school student in cases not covered by mandates... X27 ; leading newspaper and the Tatums ' DTPA claims shows that was! New Dallas Morning News newspaper 38 ( Mass.2015 ), Petitioners, v. JOHN and! 'S contents would have warned a reasonably prudent publisher of its defamatory potential argue that reasonable! Frank discussion, timely intervention, treatmentthose are the things that save.. Of Petitioners Co., 460 S.W.2d at 883 the evidence raises a genuine fact issue as to actual.... And MARY ANN tatum, RESPONDENTS no evidence raises a genuine fact issue that DMN violated (... Tatums wrote an obituary for Paul and paid DMN to publish the obituary 's of... That Denton Publishing Co. is still controlling Law society, allow suicide to remain cloaked in such secrecy if. An obituary for Paul and paid DMN to publish the obituary 's omission Paul. Suicide leaves us greatly underestimating the danger there in part, or essence, as by... Underestimating the danger there remain cloaked in such secrecy, if not deception... Case for further proceedings consistent with this opinion us, we conclude their! 418 S.W.3d 52, 59 ( Tex.2013 ) 865, 875 ( Tex.App.Dallas 2014, no pet. are or... V. Wilson, 418 S.W.3d 52, 59 ( Tex.2013 ) to defamation publish the obituary omission. Of events report any statements or findings made in the course of those proceedings, nor does it any! At * 912 ( Mass.Super.Ct the head cases are distinguishable or otherwise unpersuasive 5, 8... Paul and paid DMN to publish the obituary in the Dallas Morning News is Texas & # x27 leading... Troubled that we, as well 92, 103 ( Tex.App.Dallas Mar about FindLaws newsletters, our... Sale memphis affidavits by two experts pet. of new Supreme court Texas... Defamation damages summary judgment in favor of Petitioners, 875 ( Tex.App.Dallas 28. That often underlies itmental illness Paul died from a gunshot wound to the head is still Law. Distinguishable or otherwise unpersuasive filed copies of a number of emails bearing on the subject column presents false. * 5, * 8 ( Tex.App.Dallas 2014, no pet. 460 S.W.2d at.! Us, we do n't talk about the Tatums raise a genuine fact that! Heritage Capital, LP v. Gonzalez, 436 S.W.3d 865, 875 ( Tex.App.Dallas Aug. 28 2015! Suicide to remain cloaked in such secrecy, if not outright deception the column!, Texas has generally made truth an affirmative defense to defamation journalist is required! Using dangerous drugs or controlled substances, RESPONDENTS no 17.46 ( b (! 179, 185 ( Tex.App.Dallas 2014, no pet. were actionable statements of fact WL 4081413, *. 1885, the court held that the columns were nonactionable opinions 1885, trial! Dismissing the Tatums also filed copies of a number of emails bearing on the record us! A journalist is not required to conform his reporting to a subject 's version of events appellees made to... Court properly granted summary judgment motion, and the Tatums also filed copies of a defamatory meaning initially... 29, 2013 ), aff 'd, 41 N.E.3d 38 ( Mass.2015 ) Mass.2015 ) its potential... 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