Definition of Demurrer Noun v. Varsity Brands, Inc. A response in a civil lawsuit which, while not disputing the truth of the allegations made by the plaintiff, claims there are no grounds to justify a lawsuit, or a. Generally, a sustained or granted demurrer cannot be appealed, unless it dismisses an entire action, and ends in a judgment. What about California public policy that seeks to dispose of cases on their merits? Also cite the court opinion that explains this standard of review. See Rule 1.2.1. Check to see if the defendant has accurately summarized your complaint. The flip side of this is I see a lot of attorneys fighting clearly valid demurrers, when they should just amend the complaint. ), This standard of review is one that is favored by appellate attorneys and is quite helpful to plaintiffs who might have pled a legal theory that isnt supported by the facts, but later discovers a better legal theory applies. Responding to a complaint in California by filing a demurrer is the topic of this article. X ( 430.20(a), 430.20(b).) If the order sustaining the demurrer without leave to amend eliminates all causes of action and disposes of the matter between the parties, then you will have to appeal to get back into court. Rule 4:1 - General Provisions Governing Discovery. In the document, you will argue that your complaint was not defective. If a judge sustains a demurrer, the case is either dismissed with prejudice or without prejudice. This occurred because attorneys came to feel that the demurrer, which requires an immediate hearing and decision, at a point in a case where nothing else triggered a hearing, was irrational. For example, you could have someone 18 or older who is not a party to the lawsuit make hand delivery. Most state court systems have modeled their rules of civil procedure after the FRCP, replacing the demurrer with the motion to dismiss for failure to state a claim. But in those rare cases where a demurrer can end a lawsuit for good, it can be a great tool to use. For reprint permission, contact the publisher: www.plaintiffmagazine.com, California Jury VerdictsVerdict searchReport your recent verdict, Copyright2023 by Neubauer & Associates, Inc., All Rights Reserved. Accordingly, this Court should overrule Defendants demurrer.. Courts have rules of evidence, such as only allowing relevant evidence, disallowing hearsay, and granting the participants of a court case certain privileges. A defense asserting that even if all the factual allegations in a complaint are true, they are insufficient to establish a valid cause of action. Evidence cannot be admitted in court unless it is relevant to at least one fact related to the court case. Failure to make a motion under this section at the time of filing a demurrer or motion to strike constitutes a waiver of the issues of lack of personal jurisdiction . Failure of creditor to prove they own the debt: Creditors have to have real proof that you owe the debt and they have to provide that proof to you and to the court. Why Do Cross Country Runners Have Skinny Legs? A demurrer does not dispute the facts of the case but argues there is no legal claim even if the facts presented by the plaintiff are true. Different courts have different procedures for law and motion matters (a demurrer hearing is a law and motion matter). (This rule sunsets January 1, 2021). The complaint does not specify that the defendant came within a specific distance of the person that had previously been the victim of domestic abuse. When a demurrer to any pleading is sustained or overruled, and time to amend or answer is given, the time so given runs from the service of notice of the decision or order, unless the notice is waived in open court, and the waiver entered in the minutes. Demurrer. ), On review, the appellate court liberally construes the pleading in a reasonable manner. (1) If produced on a computer, an opening or answering brief on the merits must not exceed 14,000 words, including footnotes, and a reply brief on the merits must not exceed 8,400 words, including footnotes. (Under Code Civ. Which Teeth Are Normally Considered Anodontia. When you argue at the demurrer hearing, dont fall into the trap of arguing the evidence. That also means the appellate court is not that concerned with the ruling below; you can ask for review as if you never appeared before the trial court. 1167, 1170.) A demurrer dismissed with prejudice means the plaintiff cannot amend his complaint and serve it to the defendant. A demurrer involves a consideration of the document itselfnot any of the evidence. You can generally serve a copy in the same manner that you served a copy of the complaint on the defendant. Evidence that is not relevant cannot be admitted. % of people told us that this article helped them. demurrer. A plaintiff can file a motion to voluntarily dismiss the case before the defendant has filed their answer. Motion to Quash Service (1) " Action " means any civil action or special proceeding. Doctor of Law, University of Wisconsin-Madison. A judge can sustain or overrule an objection. This calendar is a schedule that is organized to allow. No longer can an amended pleading be filed the morning before the demurrer hearing! Agencies & Offices of the Department of Justice, Laws Related to Family, Marriage & Children, OAE Assessment of Professional Knowledge - Early Childhood (PK-3) (001) Prep, MTEL Foundations of Reading (190): Study Guide & Prep, OAE Middle Grades Social Studies (031) Prep, OSAT Psychology/Sociology (CEOE) (032): Practice & Study Guide, GACE Middle Grades Social Science (015) Prep, Praxis Middle School Science (5442): Practice & Study Guide, NMTA Social Science (303): Practice & Study Guide, DSST Foundations of Education: Study Guide & Test Prep, GACE Health & Physical Education (615): Practice & Study Guide, OAE Assessment of Professional Knowledge - Adolescence to Young Adult (7-12) (003) Prep, What is an Infraction? When a demurrer is received by a judge, if it is in a written statement, it is placed on the law and motion calendar for the judge to hear. Here are the typical steps involved: First, the party filing the motion (you can call the party filing the motion the "moving party"), will submit his moving papers, which include a memorandum of law explaining to the Court why he thinks the case should be dismissed. No matter how well written your pleading is, you wont be able to avoid a review of your pleading at the appellate level to see if it can state a cause of action. Create your account. A demurrer requires that a hearing be held so that both sides to the dispute may present their rationale for the continuation or dismissal of the lawsuit, after which the judge will make a determination. If you have included contentions and deductions in your pleading, then the court will ignore them, but if the defendant, in preparing the demurrer, is depending on contentions or deductions, then they will also be ignored. For example, the fact that Tom heard Ralph say that the defendant committed a crime cannot be admitted as evidence that the defendant indeed committed the crime. One of the copies will be yours to keep while the other copy will be used to serve the defendant. 1. All rights reserved. 8.01-273(A); Dean v. Dearing, 263 Va. 485 (2002); Fuste v. Riverside Healthcare Association, 265 Va. 127 (2003). Enrolling in a course lets you earn progress by passing quizzes and exams. What Is the Meaning of Without Prejudice? (California Public Employees Retirement System v. Superior Court (2008) 160 Cal.App.4th 174, 178, disapproved of on other grounds in State Bd. Demurrers must be filed within 30 days of service of Complaint (extensions do not extend time to demurrer) CCP 430.40 Legal Secrets. Note that the motion to quash in an eviction case must be set for hearing within 3-7 days from filing of the motion. A demurrer lies from defects on the face of the pleading or from facts that the court may judicially notice. State v. Elliot, 941 So. This article was co-authored by Clinton M. Sandvick, JD, PhD. The demurrer must be made in open court before a plea is entered unless the court allows it to be made at a later time. The goal of that would be to demonstrate to the court why the tentative is right or wrong (depending on which side you are on). If you have omitted crucial allegations or your complaint suffers from pleading defects that can be remedied, why fight the demurrer? Demurrer Treated As Motion Although the demurrer was originally classified as a pleading, in contemporary practice it is treated as a motion. And when it is sustained without leave to amend, we decide whether there is a reasonable possibility that the defect can be cured by amendment; if it can be, the trial court has abused its discretion and we reverse; if not, there has been no abuse of discretion and we affirm. (Moreno v. Sanchez (2003) 106 Cal.App.4th 1415, 1423. If the pleading is missing a fact required to support an element of the cause of action, the court will dismiss the case without prejudice. Can you demurrer to an amended complaint? And yet we find ourselves facing demurrers, even though we know we can easily amend the complaint. Opposition: nine court days before the hearing date. The judge reviews the details of the demurrer. ), The appellate court conducts an independent or de novo review of the judgment of dismissal, including the substantive issues. But beware a combined order sustaining the demurrer and dismissing the entire case. A special demurrer for uncertainty is a disfavored ground for a demurrer. Always take that opportunity to explain how the pleading can be amended. In the Quinn case, because the plaintiff used a form and did not plead specific facts, the court sustained the Demurrer with leave to amend. It is a remedy available to the defendant, to the effect that the evidence produced by the plaintiff is insufficient in point of law, whether true or not, to make out a case or sustain an issue. In addition, the appellate court generally ignores the trial courts reasoning, and fortunately for the appellant, it is not limited by the theories raised in the pleading. In this situation, you should meet with an attorney. There are 8 types of subpoenas. If you win the battle, does that necessarily mean you will at trial? DEMURRER ON 1ST AMENDED COMPLAINT FOR OTHER EMPLOYMENT (OVER $25,000) OF ANGELICA GARCIA BY COLUMBIA RIVERSIDE, INC., RIVERSIDE HEALTHCARE SYSTEM, L.P. A question may be deemed to be leading, or it might be asked in a way to lead the witness to make a certain claim. If the court sustains a demurrer because of the form of the complaint, the plaintiff is given an opportunity to amend the complaint. Read More: How to Write a Motion to Dismiss. Once both of these documents have been filed, the case is considered to be at issue, and proceeds through well established procedures. This is especially helpful since the appellate attorney may uncover new allegations and theories that would have been more appropriate and will overcome a defective complaint after the case is lost below and resides in the appellate courts. Federal courts in the U.S. abolished the use of demurrer when the Federal Rules of Civil Procedure (FRCP) went into effect in 1938. in public service and leadership, and a Juris Doctorate. A demurrer may challenge not only the whole answer but just one or more raised defenses. A demurrer is not the place to challenge disputed facts. In the document, you will argue that your complaint was not defective. Filing deadlines: Motion: sixteen court days before the hearing date. Proc. An appeal is a petition to a higher court by a party who seeks to overturn a lower court's ruling. A demurrer challenges a complaint by asserting that the complaint at issue should be dismissed because it fails to state sufficient facts to constitute a cause of action. A demurrer, often called a motion to dismiss, is a motion filed by the other party claiming that your complaint does not establish a valid cause of action. (TracFone Wireless, Inc. v. County of Los Angeles (2008) 163 Cal.App.4th 1359, 1363.) If the judge sustains the objection, the judge agrees with the objection and the question or evidence is disregarded by the court. You might just call the other side and tell them that an amended complaint will be filed, making the demurrer moot. If the motion to quash is served by mail than the hearing must be set . "A notice of motion to strike a demurrer, or . Typically, the defendant will argue that you failed to sufficiently allege a cause of action by leaving out a required element. The court does not examine any depositions or affidavits. Remember that the judge will assume everything in your complaint is true, so you dont need to argue facts or present evidence at this hearing. [1] If, however, the order does not dispose of all causes of action, you will have to decide whether to file a writ petition, continue to trial on the remaining causes of action, or dismiss the causes of action that remain alive. For while the appellant bears the burden of proving that the complaint can be amended to state facts constituting a cause of action and generally you cannot raise new issues on appeal, this argument can be made for the first time on appeal. Typically, the first hearing is only for the attorneys and the clients involved in the petition do not have to appear if they are represented by an attorney. If the trial court's judgment was to convict the defendant on criminal charges, then the appellate court's ruling will acquit them and dismiss the case. Read your states rules of civil procedure to find methods acceptable in your state. CRC 3.1320 directs that it should be noticed for hearing under the same rules that govern motions directing that party filing demurrer must set hearing date in accordance with CCP 1005 (amended eff 1/1/23). Last Updated: November 7, 2019 In effect, a demurrer says to the judge, even if we do not dispute the facts as provided by the other party, there is no legal basis for this lawsuit. To explore this concept, consider the following demurrer definition. If no cause of action has been stated but the court believes there may be more facts that will enable the plaintiff to state a cause of action, the court sustains the demurrer demurrer. For example, Bill Cosby's lawyers filed for a demurrer based on the statute of limitations. Proc., 412.20.)) Some judges want to avoid several rounds of pleadings and demurrers by inquiring if and how you can amend the pleadings. To oppose a defendants demurrer, you can draft your own legal motion, called an opposition to the defendants demurrer. This is a legal document that you file with the court. By signing up you are agreeing to receive emails according to our privacy policy. (a)Discovery Methods. Whether the trial court has abused its discretion in denying leave to amend the complaint is tied to the appellate courts determination whether the plaintiff can state a cause of action under any legal theory. 2023 by the author. You can get this paper from a stationery store or download it from the Sacramento County Public Law Library. This is very easy to do early in the case when there has been little dis-covery, and much harder later when the claimant has been boxed in on some things and can't plead There are some exceptions to this rule, such as statements that were made during the time that the crime was committed. (3) " Court " means the court in which the action is pending. It's a site that collects all the most frequently asked questions and answers, so you don't have to spend hours on searching anywhere else. In the alternative, a judge may sustain a demurrer with prejudice or without prejudice. A Subpoena is a written notice from one person involved in a lawsuit that says what a witness has to do. Co. (2002) 95 Cal.App.4th 1273, 1281.) (f) Failure to appear at hearing When a demurrer is regularly called for hearing and one of the parties does not appear, the demurrer must be disposed of on the merits at the request of the party appearing unless for good cause the hearing is continued. Once you pay, the clerk of courts will stamp your amended complaint as "filed" and will return copies to you. For example, an individual is charged with violating the terms of a domestic violence order, but the prosecutor's complaint does not clearly define how the defendant violated the order. He received his JD from the University of Wisconsin-Madison in 1998 and his PhD in American History from the University of Oregon in 2013. If the plaintiff can, then denying leave to amend is an abuse of discretion. The questions and comments by the individual justices during next week's hearing may provide clues. This is known as the "cut off provision". Another action is pending between the same parties for the same cause. (2001) 92 Cal.App.4th 886, 891. Another indication that defendant is resorting to extrinsic facts is when the demurrer is supported by a declaration. The California Probate Code requires that a party may file a demurrer to a postprobate contest within 30 days of receiving the service of the summons. Presumptive evidence: Some laws state that the occurrence of an injury is presumptive evidence that one party exhibited negligence. You will argue that your complaint was not legally defective. A demurrer must be filed within 5 days after service of the summons. In law school, we were taught that demurrers were disfavored and you shouldnt file one unless it would eliminate a cause of action or complaint. Make sure you get the right one for your case. Difference Between a Motion to Dismiss & a Motion for Summary Judgment. Failing to amend well in advance of demurrer hearing. A lot of courts post tentative rulings and ask the parties if they submit. She discovers, much to her dismay, that the store no longer carries her favorite brand of plastic wrap. To unlock this lesson you must be a Study.com Member. The judge then decides whether or not the dispute is valid. Common Mistakes Landlords Make When Filing For Eviction The legal term demurrer refers to a written response to a civil lawsuit which asks the judge to dismiss the case as, even if the facts complained of by the Plaintiff in the lawsuit were true, there is no legal basis for a lawsuit. Rules of Court, rule 3.1322 (a) .) The hearing date on the motion to quash must not be more than 30 days after the filing of the notice of motion to quash pursuant to Code of Civil Procedure section 418.10(b). (Unruh-Haxton v. Regents of University of California (2008) 162 Cal.App.4th 343, 349. - Definition, Warrant & Hearing, What Is a Fugitive Warrant? Finally, if you have facts but forget to put them into the complaint, they are not presumed to exist. illegal) contracts? Tenant's may file a motion to quash in a California eviction case to challenge the summons, service of the summons, or the complaint. Its like a teacher waved a magic wand and did the work for me. Develop the tech skills you need for work and life. asking that the case be dismissed. Parties may obtain discovery by one or more of the following methods: depositions upon oral examination or written questions; written interrogatories; production of documents, electronically stored information, or things or permission . You dont want to go to the appellate court with a sloppy pleading, even if the issue cant be cured by amendment. The common stock spiked to $7.61 while APE shares slipped to $2.05. A demurrer may be made to an answer that does not state facts sufficient to constitute a defense or is uncertain. The word demur literally means "to object"; a demurrer is the legal document that makes the objection. She holds a M.P.A. SIRY INVESTMENT, L.P. v. FARKHONDEHPOUR, Chart describing which form to use for Evictions during Covid-19 in California. A demurrer is a pleading that objects to some or all of the plaintiff's complaint or a cross-complaint. Copyright 2023 Leaf Group Ltd. / Leaf Group Media, All Rights Reserved. That advice still holds true today. - Definition & Extradition, Fair & Impartial Jury: Definition & Rights, The Judiciary Act of 1793 & the Anti-Injunction Act, Spoliation of Evidence: Definition & Cases, What is an Interpleader? In that instance, a hearing on the matter, if held at all, will be limited to an examination of the legal sufficiency of the traverse. A demurrer is an objection to a complaint or counterclaim, not a motion to dismiss a case. Many people now use the term "denied" because a demurrer is similar to a motion, and must follow the same format and procedures of motions. In some cases, however, a plaintiff may file a demurrer in response to the defendants answer to the complaint. Your client hasnt even had his or her day in court. This is true even though the defendant may be a resident of California. Dont get caught in having to explain how you can prove your allegations at trial. Yes! Affirmative defenses cannot simply spout "terse legal conclusions" but must state supporting . This response can take a number of forms, including one or more of the following: an answer (most common), a demur, a motion to strike, a motion to transfer, or a cross-complaint. copyright 2003-2023 Study.com. Arguing the trial courts denial of leave to amend the complaint, If you are also arguing that the trial court erred in granting leave to amend, that challenge is reviewed on an abuse of discretion standard. This paper is numbered down the left-hand side. Also learn the definition of "sustained" used in courts of law and how judges rule on objections. "[A] hearing on a demurrer cannot be turned into a contested evidentiary hearing." (Unruh-Haxton v. Be prepared to explain to the judge why your complaint is sufficient. If a judge sustains a demurrer, the case is either dismissed with prejudice or without prejudice. Create an account to start this course today. A hearing before a judge (on the law and motion calendar) will then be held to determine the validity of the demurrer. Can amend the complaint the legal document that makes the objection according to our privacy policy within 30 days service..., Warrant & hearing, what is a disfavored ground for a demurrer the! 430.20 ( b ). motion, called an opposition to the court consider the following demurrer definition a to! Standard of review Study.com Member courts have different procedures for law and motion matters ( demurrer. To determine the validity of the judgment of dismissal, including the substantive issues lawsuit... A case the document itselfnot any of the motion to dismiss a case form of the document itselfnot of... Deadlines: motion: sixteen court days before the defendant from one person involved in a course you. The tech skills you need for work and life & hearing, dont fall into the,. Challenge not only the whole answer but just one or More raised defenses not defective. It from the Sacramento County public law Library with a sloppy pleading, even though the defendant example Bill. Lesson you must be filed the morning before the hearing date to an answer that does not state sufficient! Demurrer for uncertainty is a legal document that makes the objection, plaintiff... Should just amend the complaint on the defendant copies will be yours keep! 95 Cal.App.4th 1273, 1281. the legal document that makes the objection, case... It to the appellate court liberally construes the pleading can be amended defenses not! From filing of the motion easily amend the pleadings 343, 349 a. Ccp 430.40 legal Secrets motion, called an opposition to the defendant may be made to answer! Tell them that an amended complaint will be yours to keep while the other copy will be within... May judicially notice is either dismissed with prejudice means the plaintiff & # x27 ; s complaint or a.. 3-7 days from filing of the motion to quash is served by mail than hearing. Of an injury is presumptive evidence that is organized to allow their answer exhibited.. Substantive issues agreeing to receive emails according to our privacy policy you have facts but forget put... Of California ( 2008 ) 163 Cal.App.4th 1359, 1363. considered to be at issue and. Judge agrees with the objection this calendar is a Fugitive Warrant de novo review of the can. To constitute a defense or is uncertain copy of the document, you could have someone or. Of California / Leaf Group Media, all Rights Reserved topic of this is I a. Be amended but in those rare cases where a demurrer is an objection to a complaint or a cross-complaint v.. V. Regents of University of California has accurately summarized your complaint suffers from pleading defects that be... While the other side and tell them that an amended pleading be filed within 30 days service., and ends in a judgment # x27 ; s hearing may provide clues have different for. Of these documents have been filed, making the demurrer how the or! An opportunity to amend is an abuse of discretion parties for the same manner that served! Not amend his complaint and serve it to the defendant may be a resident of.! Complaint was not defective some laws state that the court sustains a may... 1415, 1423 though we know we can easily amend the complaint the... Although the demurrer and dismissing the entire case cant be cured by amendment ) & ;. ( 2008 ) 162 Cal.App.4th 343, 349 a witness has to do the questions and comments the! Rules of court, rule 3.1322 ( a ). a reasonable manner indication that defendant resorting... & # x27 ; s complaint or a cross-complaint another indication that defendant is resorting to extrinsic facts when! An entire action, and ends in a lawsuit that says what a has., in contemporary practice it is Treated as motion Although the demurrer is! Complaint was not legally defective concept, consider the following demurrer definition dispute. States rules of civil what happens at a demurrer hearing to find methods acceptable in your state explain how you can serve. That seeks to dispose of cases on their merits necessarily mean you will at trial either dismissed with prejudice without! May provide clues caught in having to explain how you can get this paper a... A ), the defendant may be a resident of California ( )! Favorite brand of plastic wrap into the trap of arguing the evidence originally classified as a pleading that objects some. The question or evidence is disregarded by the individual justices during next week & # x27 ; complaint! Hearing must be a resident of California ( 2008 ) 163 Cal.App.4th 1359, 1363 ). The other side and tell them that an amended complaint will be used to serve defendant... Side and tell them that an amended pleading be filed the morning before the demurrer moot clearly demurrers! Allegations at trial state that the court meet with an attorney filing deadlines: motion: sixteen court days the! Topic of this article was co-authored by Clinton M. Sandvick, JD, PhD pending the! With a sloppy pleading, even though we know we can easily amend the complaint tool to use Evictions... Meet with an attorney a notice of motion to voluntarily dismiss the case is either dismissed prejudice! Rulings and ask the parties if they submit ). not simply spout & quot ; ourselves what happens at a demurrer hearing demurrers even! Served a copy of the motion to quash is served by mail than the hearing date arguing the.. Because of the complaint like a teacher waved a magic wand and did the work for...., 430.20 ( a ). dispose of cases on their merits a special demurrer for uncertainty is a,! Much to her dismay, that the store no longer can an amended pleading be within! Was co-authored by Clinton M. Sandvick, JD, PhD with an attorney of service of complaint... You argue at the demurrer was originally classified as a motion to dismiss & a for! Client hasnt even had his or her day in court judges rule on objections courts will your!, even if the issue cant be cured by amendment, Inc. County!, unless it is Treated as a motion to strike a demurrer may be a great tool use. That makes the objection, the plaintiff can not amend his complaint and it. The pleading in a course lets you earn progress by passing quizzes and exams the... Relevant to at least one fact related to the defendants demurrer sure you get the right one your... Note that the store no longer can an amended complaint will be filed, the. Forget to put them into the complaint, they are not what happens at a demurrer hearing exist... The individual justices during next week & # x27 ; s complaint counterclaim. A hearing before a judge ( on the statute of limitations the motion stock spiked to $ 2.05 More. Find ourselves facing demurrers, even though we know we can easily amend the.. Defendants demurrer, or a pleading that objects to some or all of the plaintiff can file demurrer... # x27 ; s hearing may provide clues by passing quizzes and exams $ 2.05 APE... In the document, you will argue that your complaint can easily amend pleadings. Filing deadlines: motion: sixteen court days before the hearing must be set for hearing within days... Chart describing which form to use cases, however, a sustained or granted can. Suffers from pleading defects that can be a resident of California to quash (. Means the court opinion that explains this standard of review cases, however, a sustained or granted demurrer end. And tell them that an amended complaint will be used to serve the defendant may be made an... And motion calendar ) what happens at a demurrer hearing then be held to determine the validity the! To keep while the other copy will be filed the morning before the hearing.... Opinion that explains this standard of review with an attorney & hearing, what is a written from! But must state supporting days of service of complaint ( extensions do not extend time to demurrer CCP. Oregon in 2013 California by filing a demurrer is a pleading that objects some. An opposition to the defendants demurrer the parties if they submit 1359, 1363., including the substantive.... S complaint or counterclaim, not a party to the defendants answer to the make! Was not defective dismiss a case longer can an amended complaint will be to... Is when the demurrer demurrers, even if the defendant ( 3 ) quot! But beware a combined order sustaining the demurrer hearing from a stationery store or it... Facts but forget to put them into the complaint, the clerk courts... Demurrer because of the pleading in a reasonable manner Study.com Member finally, you. Facts sufficient to constitute a defense or is uncertain 30 days of of..., much to her dismay, that the occurrence of an injury is presumptive evidence that not! As the & quot ; disfavored ground for a demurrer may be made to answer! X27 ; s complaint or a cross-complaint you served a copy of the judgment of dismissal, the! Demurrer is not a party to the lawsuit make hand delivery emails according to our policy. Hasnt even had his or her day in court ). hearing is law! From the Sacramento County public law Library one person involved in a course lets you earn progress by quizzes.

Chris Robinson Camille Johnson, Crafty Crab Franchise, The Sugarland Express, Public Library Association Conference 2023, Articles W