Sunday, February 17, 2019

DAVID UPHAM on Everson/The Religion Clause

Professor David Upham makes the case for overturning Everson at the Law & Liberty site here. In this piece he is more clear on how he feels about the Establishment Clause applying against the states than the Free Exercise Clause. Yes, before the 14th Amendment the entire Bill of Rights including the Free Speech and Free Exercise Clauses applied to the federal government only.

But he writes:
To my knowledge, the sole exception to the Permoli legal consensus, from 1875 to 1925, can be found in dicta made only by Justice John Harlan and only in his last decade on the Supreme Court (1900-1911).  So, for instance, in Maxwell v. Dow, Harlan objected to the majority’s anti-incorporation conclusion with an argument ad absurdum, that the logical result would be that Utah could establish the Mormon Church.[2]
So I noted in the comments:

There is one point of view that says religion is left to the states and the 14th Amendment didn’t incorporate any of the bill of rights. If this is true states would be permitted to infringe on the free exercise rights. What conservative jurists presently support this position? State Blaine Amendments, even though they discriminate against religion would be perfectly constitutional.
There is another point of view that says individual rights are what was intended to be incorporated. Free exercise clearly relates to an individual right. Establishment would only incorporate to the extent you can demonstrate it relates to such. Clarence Thomas has endorsed this point of view. But he doesn’t see what beyond the FEC incorporates. Akhil Amar suggests there are some “equality” rights that the FEC (which is more of a “liberty” right) doesn’t capture.
To which Upham replied:
... Nonestablishment is not a privilege or immunity of citizenship under the 14th Amendment. No one said it was, and for good reason–it did not fit the definition of the terms, as understood by that generation. Conversely, many mentioned other rights in the bill of rights–and for good reason–they did fit the general definition.
State Blaine amendments, as I understand them, are not inconsistent with the original understanding. They are, I think, unjust and imprudent, but not unconstitutional–in part because their very existence, passed often by the same folks who adopted the 14th Amendment, is strong evidence that they were not inconsistent with the 14th Amendment. Did anyone–in any of the states–protest such measures as contrary to the 14th Amendment?
To which I then replied:

Kurt Lash has suggested that the last state establishment ended in 1833 — well before the 14th Amendment — one could argue the right to be free from a religious establishment is included in the P or I Clause.
And again, Prof. Amar has suggested, rightly in my opinion, it’s liberty and equality interests that drive the First Amendment and the entire BOR generally.
If Utah did have the Mormon Church as a state establishment or Maryland the Roman Catholic Church, is that consistent with a state treating its citizens as equals without regard to religious creed[?]
These kinds of questions as opposed to original expectation of the constitution’s applied text are what drives the new originalism.
And finally Upham:

Lash rightly and easily points out that nonestablishment can be an individual right and not exclusively a federalism provision. But it cannot satisfy the full test of being fundamental to the United States–whether that test is Corfield’s or the similar tests announced in various formal interpretations of the proposed Amendment–that it be foundational to the American Republic since 1776.
Those tests, and that failure, I think adequately explain why no one seemed capable of saying that the Fourteenth Amendment incorporated the Religion Clauses, even when the silence was deafening. that is to say–the original meaning explains fairly clearly the originally expected NON-application.
As for equality before the law: the establishment of republicanism, as presupposed by our entire Constitution, does not make monarchists second-class citizens of our Republic. So too the establishment of Mormonism or Roman Catholicism–which would be highly unlikely, imprudent and even un-American, in my opinion, would not, absent a suppression of liberty or an imposition of special taxes or burdens–reduce non-Mormons or non-Catholics to second-class citizenship in Utah and New Mexico, respectively.
I gave him the last word in the comments over there, but  let me take a final word here. One of the difficulties in constitutional interpretation is that the text of the Constitution doesn't specify a formula or a "test" for interpreting it.

I'm certainly skeptical of Upham's application of his aforementioned "tests." What does "foundational to the American Republic since 1776" mean? That we freeze everything in 1776? What about 1789 or 91 or 1868? Is Upham arguing that what the 14th Amendment incorporates has to relate back to 1776?

This isn't what Akhil Amar argues. Rather he argues it's an 1868 understanding or lens of the Bill of Rights that were ratified in 1791 (not 1776). But 1868, not the late 18th Century is the more centrally determinative time. And if that's the case, given the state establishments were gone by 1868 one could argue, after Lash, that it's foundational to the American Republic since 1868 that American citizens have a right not to live under a state established church.

I'm also skeptical that the state level establishment of Mormonism, Roman Catholicism or a fundamentalist sect of the Baptist religion can be done without making other members into second class citizens on account of their religion.

Our Founding Truth said...
This comment has been removed by the author.
Our Founding Truth said...

The Judiciary Act of 1789 written by Ellsworth says a state law can be overturned, obviously through natural law. That puts in question the ability of Utah to establish Mormonism. Otherwise, a state establishment does not violate the establishment clause.

Jonathan Rowe said...

OFT: That's a strange comment in more ways than one.

Our Founding Truth said...

Jon wrote :OFT: That's a strange comment in more ways than one.

Why is that?

Tom Van Dyke said...

ROWE: the right to be free from a religious establishment

UPHAM:

So too the establishment of Mormonism or Roman Catholicism–which would be highly unlikely, imprudent and even un-American, in my opinion, would not, absent a suppression of liberty or an imposition of special taxes or burdens–reduce non-Mormons or non-Catholics to second-class citizenship in Utah and New Mexico, respectively.

ROWE: I'm also skeptical that the state level establishment of Mormonism, Roman Catholicism or a fundamentalist sect of the Baptist religion can be done without making other members into second class citizens on account of their religion.

Your "skepticism" is not a counterargument. It is a feeling. Feelings are not facts.

The "right to be free from a religious establishment" is constitutional gobbledegook. I would have no problem living in Mormon state. Except for the no-booze part. But if it were that important to me, I'd move to one of the other 49.

For many, escaping the high crime and abusive taxation of many other states would be well worth it.

Anonymous said...

Thanks very much for reading my post and for the conversation.
-David Upham

Jonathan Rowe said...

David: My pleasure and keep up the great work.

Jonathan Rowe said...

Tom: "The "right to be free from a religious establishment" is constitutional gobbledegook."

https://prawfsblawg.blogs.com/prawfsblawg/2013/08/the-establishment-clause-and-reverse-incorporation-with-some-implications-for-town-of-greece-v-galloway.html

"If one takes an originalist approach to Fourteenth Amendment incorporation, the principle of non-establishment as a privilege or immunity of citizens of the United States emerged at the time of Reconstruction and was entrenched through the adoption of the Fourteenth Amendment."

Jonathan Rowe said...

OFT:

I'm sympathetic to the notion that we can look to essences in nature discoverable by reason and use such principles found in documents like America's DOI to supplement our understanding of constitutional law. However, I wasn't aware that the The Judiciary Act of 1789 written by Ellsworth provides a smoking gun proof for such a proposition; I guess I'll have to reread it.

And given that Mormons not only endorse the DOI but do so in a way where they actually incorporate it into their religion, in a way that your religion (properly understood) never could, I'm not sure how such proves anything against the state establishment of Mormonism.

Our Founding Truth said...

Jon wrote: "If one takes an originalist approach to Fourteenth Amendment incorporation"

All of us know the above statement is demonstrably false. Religion is left to the states.

And we all know the constitution is founded on natural law:

L]aws human must be made according to the general laws of Nature, and without contradiction to any positive law of Scripture, otherwise they are ill made. John Locke, Two Treatises on Government (London: J. Whiston, etc., 1772), Book II, p. 285, Chapter XI, §135, n., quoting Hooker's Eccl. Pol. 1. iii, sect. 9

Jonathan Rowe said...

"All of us know the above statement is demonstrably false. Religion is left to the states."

It's actually me quoting law professor Kurt Lash. Maybe he knows something you don't. Read the statement carefully again. It's the originalist approach to the FOURTEENTH Amendment. Religion was left to the states of the original 1787-91 Constitution. Not the incorporated one in 1868.

The US Constitution was based on a number of things. Natural law has nothing to do with scripture. And somehow something is proven against the against the establishment of Mormonism at the state level?

Our Founding Truth said...

It's the originalist approach to the FOURTEENTH Amendment. Religion was left to the states of the original 1787-91 Constitution. Not the incorporated one in 1868."

There is no incorprated one. The courts violated natural law (right reason) and overstepped their authority by whatever rulings they made that would distort the constitution.

"I entirely concur in the propriety of resorting to the sense in which the Constitution was accepted and ratified by the nation. In that sense alone it is the legitimate Constitution...What a metamorphosis would be produced in the code of law if all its ancient phraseology were to be taken in its modern sense."
JM to Henry Lee on June 25, 1824

Jon wrote:Natural law has nothing to do with scripture."

Notice, Locke quotes Hooker and they tie natural law to scripture.

"[L]aws human must be made according to the general laws of Nature, and without contradiction to any positive law of Scripture, otherwise they are ill made. John Locke, Two Treatises on Government (London: J. Whiston, etc., 1772), Book II, p. 285, Chapter XI, §135, n., quoting Hooker's Eccl. Pol. 1. iii, sect. 9"

Jonathan Rowe said...

OFT: You are still not getting it ....

On a related note: This is Lash's entire paper on the topic. I'm not sure if we ever featured it here at AC. Perhaps it's time.

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1133615

Our Founding Truth said...

A post from the law and liberty website, someone posted this from from justice Thomas:

"That said, recall Thomas’s dissent in Elk Grove Unified School Dist. v. Newdow, 542 U.S. 1 (2004), where he argued that the 1st Amendment’s Establishment Clause was a federalism provision, defending states against overweening federal powers, and did not apply to defend individuals against state powers.

(Basically the opposite of his view of the 2d Amendment.)"

The first part is correct in that establishing Christianity does not prohibit free exercise. Sounds like Upham correctly agrees that States can prohibit free exercise. It's not a mystery. Even TJ believed that.

Jonathan Rowe said...

I'm not exactly sure what you are getting at. Justice Thomas is sympathetic to the notion that the Free Exercise Clause incorporates against state and local governments as a "privilege or immunity," but that the Establishment Clause doesn't, because it doesn't relate to a privilege or immunity. Rather it's a federalism provision.

Lash disagrees.

Jefferson thought the Bill of Rights, including the entire First Amendment applied only to the federal government, because it did.

In terms of "natural right," the ideal that TJ thought all governments ought to follow, see the VA Statute on Religious Freedom which he and Madison helped get through (to the chagrin of Patrick Henry).

Tom Van Dyke said...

https://prawfsblawg.blogs.com/prawfsblawg/2013/08/the-establishment-clause-and-reverse-incorporation-with-some-implications-for-town-of-greece-v-galloway.html

"If one takes an originalist approach to Fourteenth Amendment incorporation, the principle of non-establishment as a privilege or immunity of citizens of the United States emerged at the time of Reconstruction and was entrenched through the adoption of the Fourteenth Amendment."

Vague principles that "emerged" are not judiciable. The failure of the Blaine Amendment at that same time shows that the principle was not ratified.

https://ij.org/issues/school-choice/blaine-amendments/

Tom Van Dyke said...

ibid.:

"Blaine Amendments are controversial state constitutional provisions rooted in 19th century anti-Catholic bigotry. Their purpose was to prevent the government from funding Catholic schools. Today, opponents of educational choice employ Blaine Amendments—found in 37 state constitutions—as blunt weapons with which they attempt to block modern educational choice programs. However, IJ is pursuing a legal strategy to eliminate these obstacles to educational freedom.

This opportunity arises from the U.S. Supreme Court’s decision last summer in Trinity Lutheran Church of Columbia, Inc. v. Comer. In that case, the Court stated that excluding qualified institutions—like schools—from public benefit programs solely because of their religious affiliation is “odious to our Constitution . . . and cannot stand.” IJ believes this opinion is a death sentence to Blaine Amendments, which have been invoked by teachers’ unions and their allies for decades to try and prevent choice programs from spreading and generating widespread reform. IJ’s cases in Washington State, Maine, and Montana are designed to drive our arguments up to the U.S. Supreme Court and to vindicate the right of all parents to access meaningful educational options."

Our Founding Truth said...

"Justice Thomas is sympathetic to the notion that the Free Exercise Clause incorporates against state and local governments as a "privilege or immunity,"

I've never read anything near that from a founding father. I wonder where judge Thomas got it from. What could free exercise be a privilege of? Free exercise is unalienable unless that exercise is immoral or subverts public order.

I personally believe the framers were egregiously wrong to allow idolatry (various false religions) when ratifying the 1A. It is a stupendous blasphemy and contradiction to think Jehovah would condone committing the most grievous sin in all scripture, which actually has the creator taking part in that sin.

If any enlightenment rationalism seeped into the constitution it was that.

Our Founding Truth said...

And if that's the case, given the state establishments were gone by 1868 one could argue, after Lash, that it's foundational to the American Republic since 1868 that American citizens have a right not to live under a state established church.""

If states still established Christianity in their constitutions after 1868, his opinion is flawed.

Jonathan Rowe said...

State establishment churches were gone by 1833

Our Founding Truth said...

I saw a state establishment according to the modern definition till 1878.

Tom Van Dyke said...

I saw a state establishment according to the modern definition till 1878.

There are religious tests for state office still technically on the books in several states.

The thing about Torcaso is that it was never litigated until 1961, and the decision was just an extension of Everson, 1947.

IOW, if you're going to use 1878, you have to show something active happening in 1878, not just an obsolete law left on the books.

djf said...

"I'm also skeptical that the state level establishment of Mormonism, Roman Catholicism or a fundamentalist sect of the Baptist religion can be done without making other members into second class citizens on account of their religion."

Late to the party here, but you seem to imply that establishment of a liberal, or at least non-"fundamentalist," church - such as the modern Church of England or Church of Scotland, I suppose - would be okay. But so long as the established church's standards of behavior are not enforced, that church does not control personal status issues (marriage & divorce, principally), and nobody is required to affirm its doctrines - in what way are non-affiliates of that church made second-class citizens? The government takes all kinds of official positions on controversial issues, but that does not give people who disagree with those positions grounds for complaint that they are being made second-class citizens. As far as I can see, anyway. So I still have a hard time seeing non-establishmentarianism as an individual right, privilege or immunity.

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Things fell off and I needed a car loan, but all attempts went to no avail because of my bad credit. After so much research online I came across JAMES DOLAN, I saw good recommendations and I sent him a mail though I was skeptical. To my great surprise my score was raised to 835 from 591 in no time, my collections was wiped and I got approved for a new car loan. The least I could do is to let the others know about him cause I know how frustrating the credit system can be. Send him a mail via James Dolan Credit Expert At Gmail Dot CoM or 720 358 7042 if you having credit problems.

Unknown said...

Do you know that an excellent credit score of 830 is better than $100,000 cash in hand? Don’t fall into the wrong hands Contact JAMES DOLAN for your credit score upgrade and He will remove all evictions from your card among other negative issues. He did a surprising job on my credit score and since then my life have been different. That’s why I have to tell everyone with a bad score to act now and fast. Contact him on his mail; James Dolan Credit Expert At Gmail Dot CoM or Phone number; 720 358 7042. Unknown said... Do you have problem with increasing your credit score and removing your poor credit reports, I’ve got a good news for you guys, my credit score was just increased from 470 to 820 and and all my awful credit reports has been cleared,he also hacked into my 3 credit bureaus, let me introduce you guys to JAMES DOLAN, you can contact him through; James Dolan Credit Expert At Gmail Dot CoM or Phone number; 720 358 7042. Unknown said... I almost concluded that all hackers and credit repairs are scam until I met this mind changer. I’m Cody Hayes; I had so much fixing to do on my profile including liens and IRS after been scammed once by one self-acclaimed hacker. James Dolan gave me a boost, removed all negatives and gave me a high 830 as my new fico score. Now I am a proud owner of a house here in Idaho, with a very low interest rate. What more can I say hit him up via James Dolan Credit Expert At Gmail Dot CoM or 720 358 7042 for any kind of hack/repair. He remain the best credit Expert in the US. Unknown said... Are you searching for a HACKER for HIRE? The solution to all hacking jobs is right here. Are you looking for 100% services in terms of CREDIT SCORE increase, GRADES CHANGE, EMAIL, Facebook, GMAIL HACK, ACCESS TO YOUR PARTNER'S INFO or wiping CRIMINAL RECORDS. Go ahead & contact James Dolan Credit Expert At Gmail Dot CoM or 720 358 7042 for all jobs and efficient delivery of services is guaranteed. Unknown said... If you need to hack into any database, delete record, improve credit score, spy on whatsapp, text, phone, emails, as long as it's hack contact James Dolan via James Dolan Credit Expert At Gmail Dot CoM or 720 358 7042 he is great, you won't be disappointed, it's very cheap and fast, he saved my relationship. Unknown said... Do you know JAMES DOLAN in specialized in all these listed below; 1-Facebook hack 2-gmail hack 3-Whatsapp hack 4-website hack 5-tracking calls 6-online hacking lectures 7-phone clone 8-online records changes 9-retrieval of hacked social media account 10 ATM Marchine hack/password from any Email Address. 11 Get any password from any Facebook, Twitter or Instagram account. 12 Cell phone hacking (whats-app, Viber, line, We-chat, etc) 13 Grades changes (institutes and universities) 14 Websites hacking, pen-testing. 15 IP addresses and people tracking. 16 Hacking courses and classes. 17 blank ATM CARD. 18.Credit Repair Contact him via James Dolan Credit Expert At Gmail Dot CoM or 720 358 7042. He is very trustworthy. Unknown said... I’m very happy to be one of those writing positive comments about a hacker because prior to my contacting a hacker, i almost didn’t believe it was actually possible to get your credit repaired by one but i’m so glad it worked out and i now know a trusted hacker. He erased my bankruptcy which was the cause of a lot of other problems and raised my credit scores to excellent scores. So i want you all to also contact him on his email address; James Dolan Credit Expert At Gmail Dot CoM or Phone numer; 720 358 7042. Unknown said... Many people have tried to be in touch with hackers but in most cases, they end up disappointed either with their service or with the charges. You can hire a professional and ethical hacker JAMES DOLAN to keep yourself safe online or to keep a watch on your family members just for legal reasons. This hacker “JAMES DOLAN” will provide you complete security from cyber-crimes and mischievous people who are trying to steal your personal data.He can also help you upgrade your credit score to a golden score of 830 and removed the eviction from your credit among other negative listings.You can reach him on his number: 720 358 7042 or James Dolan Credit Expert At Gmail Dot CoM. Unknown said... I was trying to get some help on a forum about how to repair my credit report and how i could get a hacker to help me clear my credit card and personal loan debt,That was how i came across with JAMES DOLAN who saved me away from many years debts and helped me boost my credit score to an excellent result of 830 and also help me retrieve my Stolen Bitcoins. Don't let me talk much about him! try him and let his job speak for him. Contact him on his private mail: James Dolan Credit Expert At Gmail Dot CoM or on his phone number:720 358 7042. Unknown said... Hello everyone I'm 35 years old and I had 14 negative accounts in collections. 12 from the emergency room/ medical and one from sprint and a cable company. And 5 hard Inquirys. Never had credit cards or loans or anything like that before. I got introduced to JAMES DOLAN by a friend . So I contacted him for credit fix. He disputed all the collections and hard inquiries and got them all removed with the 609 dispute letters within 3 weeks. And now I have nothing negative on my credit file. You can be happy too . Send a descriptive Email to him on JAMES DOLAN CREDIT EXPERT AT GMAIL DOT COM or on his Work number; 720 358 7042 trust me his fee is very affordable. Kind Regards ! Unknown said... I just have to testify about this here and let everyone know how much better I feel right now. About a couple months ago I applied for a car loan and it was declined because my credit score was in a low 500 with some negative items including (eviction, bankruptcy and a judgment), I was broken. I approached a colleague and narrated everything to him, he referred me to James Dolan and told me to believe in him. Within 8 days James Dolan raised my credit score to 830 and erased all the negative items replacing them with beautiful tradelines. I am ever grateful to him for such a discreet service. He fix a Chexsystem report and a DUI report as well. Write him on James Dolan Credit Expert At Gmail Dot CoM or text him via 720 358 7042 and consider your job done. Anonymous said... Are you looking for prove to know if your spouse is cheating on you just mail James Dolan on his private mail; JAMESDOLANCREDITEXPERT@GMAIL.COM or text him via 720 358 7042 his really a God sent to me and i really appreciate his good work that he did for me this hacker broke into my husband phone cause i felt my husband was cheating on me then i contacted him for help i couldn't believe that this great hacker was able to hack into my husband cell and brought me all his social media messages he uses and all the call logs\text messages\deleted text messages and many more believe me this hacker is good inbox him if you need help in hacking thank you. Anonymous said... James Dolan is a professional hacker that specializes in exposing cheating spouse,and every other hacking related issues. He helps catch cheating spouse by hacking their communications like call, Facebook, text, emails, Skype. He raised credit score, fix credit report and many more. I have used this service before and he did a very good job, he gave me every proof i needed to know that my fiancee was cheating. You can contact him on his email; Jamesdolancreditexpert@gmail.com or on his work number; 720 358 7042 to help you catch your cheating spouse, or for any other hacking related problems, he will definitely help you, he has helped a lot of people, contact him and figure out your relationship status. I wish you the best too. Anonymous said... I know a professional hacker named JAMES DOLAN who has helped me this week. He offers very legitimate services such as clearing of bad records online without being traced back to you, He clone/hack mobile phones, hack Facebook account, instagram, WhatsApp, emails, Twitter, bank accounts, Skype, FIXES CREDIT REPORTs, track calls. He also help retrieve accounts that have been taking by hackers. His charges are affordable, reliable and 100% safe. For his job well done this is my own way to show appreciation, Contact him via his Email address; Jamesdolancreditexpert@gmail.com or on his work number; 720 358 7042. Anonymous said... If you are in need of a hacker to help you fix your credit report, contact James Dolan. He helped me raised my credit score from 550 to 830 excellent and erased all bad report on my credit line. He also help me paid off my debts and got a new home and job for me. Thanks to him have been living fine since the day i texted him. He is reliable and one of the best hacker, his charges are affordable. You can get in touch with him on his private mail; JAMESDOLANCREDITEXPERT@GMAIL.COM or his work number; 720 358 7042. Anonymous said... Let me tell you all about JAMES DOLAN. He help me clear my home equity line debts, erased my criminal records and raised my credit score to 825 excellent within 48 hours. He help me pay off my chase and capital one credit cards debts and also help me apply for a new credit card with over$200,000 available balance. Contact him on his mail; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his number; 720 358 7042. He is very fast and reliable.

Anonymous said...

After I was been ripped off by a girl i met online i lost my credit cards, my credit score was decreased from 830 to 425. So i went online to check how i can fix and raised my credit score then i saw some comment about an expert called JAMES DOLAN. I sent him a mail to his email address, i explained to him then he help me raised my credit score back to where it was before, he erased all negative items off my credit line and help me apply for new credit cards with over $300,000 available balance. Contact him now on his email address; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his work number; 720 358 7042. He can help you out with any problem/issues you have...... Thanks James Dolan... Am very grateful. Anonymous said... Contact JAMES DOLAN. He is an expert in fixing credit scores, raising credit score and erasing criminal records and negative reports. He also specializes in exposing cheating spouse. He hack mobile phones, hack Facebook account, instagram, WhatsApp, emails, Twitter, bank accounts, Skype, track calls without any traces, he can also help you recover your lost bitcoins. You can get in touch with him on his number; 720 358 7042 or on his Email address; JAMESDOLANCREDITEXPERT@GMAIL.COM. He will definitely help you, his charges are affordable. Anonymous said... If not for James Dolan i wouldn't have know my wife was cheating on me. He help me hack into her social media accounts, then i discover she was having sexual affairs with different men.. He also help me boost my credit score to 810 excellent and delete my bad reports on my credit line. Contact him now if you are in need of an expert hacker.. He is reliable and trustworthy... You can get in touch with him on his email; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his number; 720 358 7042... He can help you get all your problem solved.... Thanks to James Dolan.. Unknown said... After some years have been looking hard on how to get a computer expert then i got introduced to James Dolan through a friend of mine. He help me boost my credit score from 530 to 830 Excellent and removed all negative items on my credit line. He help me apply for a loan worth over$800,000. Thanks to him have been living fine till now. Contact him now on his private email; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his number; 720 358 7042.

Unknown said...

Do you know James Dolan is specialize in exposing cheating spouse by hacking his or her mobile phones and social media accounts. He also specialize in boosting up credit scores, erasing criminal records and removing all malware in your computer. Give him a text message on his number 720 358 7042 or text him on his email: JAMESDOLANCREDITEXPERT@GMAIL.COM if you are in need of his services. He is honest and reliable.

Unknown said...

If you need a hacker to help you boost up your credit score contact James Dolan he is an expert in that he can also help you erase all negative items on your credit line and apply for a new credit card worth over $300,000. Contact him on his email; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his phone number; 720 358 7042. Anonymous said... Good day everyone i'm josh warren i would like to introduce y'all to JAMES DOLAN. He is an expert in boosting up credit scores, removing all bad reports off your credit line. He help me boost my credit score to 825 excellent and remove all bad reports. If your spouse is cheating on you, he can help you expose he or she. Get in touch with him now on JAMESDOLANCREDITEXPERT@GMAIL.COM or on 720 358 7042. Anonymous said... You can get in touch with JAMES DOLAN if you need his help in any of these hacking services listed below; 1-Credit repair 2-facebook hack 3-gmail hack 4-Whatsapp hack 5-website hack 6-tracking calls 7-online hacking lectures 8-phone clone 9-online records changes 10-retrieval of hacked social media account 11-Get any password from any Facebook, Twitter or Instagram account. 12-Cell phone hacking (whats-app, Viber, line, We-chat, etc) 13-Grades changes (institutes and universities) 14-Websites hacking, pen-testing. 15-IP addresses and people tracking. 16-Hacking courses and classes. Contact him now on his email address;JAMESDOLANCREDITEXPERT@GMAIL.COM or on his phone number;720 358 7042 Anonymous said... If you need a hacker to help you clear off all negative items off your credit line, you can contact JAMES DOLAN he is an expert in that. He is reliable and trustworthy. He can also help you boost your credit score and apply for new credit cards with higher limits. Contact him on his mail; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his work number;720 358 7042. He will be willingly to help you. Anonymous said... I want to buy my first home but wasn't approved for a loan due to my low credit score. Then i came across FRANK MAGUIRE while i was searching how to fix my low credit score. I contacted him and explain to him he told me he would help me clear all bad report, boost my credit score, apply for a loan and apply for new credit cards with higher limit thou i doubted him in the first place, so surprisingly he did all that for me which now I finally got me the mortgage for my first home... Thanks to him have been okay and able to do whatever i want to do with my new credit score. Contact him on his email; FrankMaguire313@gmail.com Anonymous said... Do you want to start a new year with a Good credit score? We just have some few days to New Year(2021), why don't you contact JAMES DOLAN to help you boost up your credit score and clear off negative items off your credit line. He is an expert in that and his charges are very affordable, he is trustworthy and reliable. Get in touch with him on his mail; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his work number; 720 358 7042. Anonymous said... Contact JAMES FORSHAW for all kind of hacking services; credit repair, boosting of credit score, exposing of cheating spouse, online hacking lectures, grade changes(institutes and universities), social media hacks and many other things. He is very honest and he has help me a lot. You can get in touch with him on his email; JAMESFORSHAWCYBEREXPERT@GMAIL.COM. Anonymous said... My score was as low as 430 and I had no hope anymore until i got to meet JAMES DOLAN through a forum on how to boost credit score. I saw everyone commenting and posting his good work and i sent him a mail. He help me boost my credit score to 830 Excellent and remove all negative items off my credit line and i was able to apply for new credit card with higher limits. Text him on his email; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his work number; 720 358 7042. Happy New Year in advance.... Anonymous said... Happy New year everyone, i wanna say thanks to JAMES FORSHAW for helping me boost my credit score from 430 to 820 excellent. Last year January i wasn't able to afford to pay my house rent due to my low credit score until i met James Forshaw he help me erased all bad reports on my credit line, boost my credit score. I would advise y'all to get in touch with him if you have any issues with your credit score, just text him on his email; JAMESFORSHAWCYBEREXPERT@GMAIL.COM Anonymous said... Don't start a new year with a bad report and low credit score, get in touch with JAMES DOLAN so he can help you boost your credit score, erase all bad report on your credit line. He can also help you expose your cheating spouse. He is very honest and 100% legit, his fee is very affordable. Text him on his email;JAMESDOLANCREDITEXPERT@GMAIL.COM or on his work number; 720 358 7042. Happy New Year... Anonymous said... Last year has been a rough year for me, i lost my job because of the pandemic. Anytime i apply for a new job i got rejected due to my low credit score and bad report on my credit line. Then i went online and search how i can fix my credit score and i got to see good reviews about JAMES FORSHAW. Then i contacted him and he help me to boost my credit score to 830 and erase all bad reports on my credit line. You can text him on his email; JAMESFORSHAWCYBEREXPERT@GMAIL.COM if you had any issues with your credit score, he will help you. Anonymous said... To hire ethical hackers, I would advise you to contact JAMES DOLAN. He’II solve all your problems like hack emails,Facebook, Twitter ,Instagram , change grades ,erase criminal records, credit and debit top up, insurance paper, credit repair, recover lost bitcoins, access or recover lost files, hack bet codes, background checks on individuals and organizations or monitor cheating spouses, phone or social media activities, contact at; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his work number; 720 358 7042. Anonymous said... Looking for a hacker who can help you monitor your spouse? Contact JAMES FORSHAW he is an expert in that, i wouldn't have know that my wife was cheating on me after all what have done for her. James Forshaw help me a lot in exposing my wife and gave me proofs that she was cheating on me, He help me hack her social media accounts, and monitor her phone calls. He is also an expert in boosting up credit score, recovering of funds and bitcoins lost to scammers, erasing of criminal records and other hacking services. Text him on his email; JAMESFORSHAWCYBEREXPERT@GMAIL.COM Anonymous said... I have been looking online on how i could get my low credit score been increased across my three credit bureaus score report until i saw good reviews about James Dolan keep pumping up on how he has really been helpful and useful to them by getting lot of people out of their credit mess. Then i mail him and he got me out of my credit mess, he also help me apply for a new credit card with higher limits. Contact him on his email; JAMESDOLANCREDITEXPERT@GMAIL.COM or on his work number; 720 358 7042. Anonymous said... James Forshaw is an expert hacker, he specialize in 1-Facebook hack 2-gmail hack 3-Whatsapp hack 4-website hack 5-tracking calls 6-online hacking lectures 7-phone clone 8-online records changes 9-retrieval of hacked social media account 10 ATM Marchine hack/password from any Email Address. 11 Get any password from any Facebook, Twitter or Instagram account. 12 Cell phone hacking (whats-app, Viber, line, We-chat, etc) 13 Grades changes (institutes and universities) 14 Websites hacking, pen-testing. 15 IP addresses and people tracking. 16 Hacking courses and classes. 17 blank ATM CARD. 18.Credit Repair Contact Him via Email; JAMESFORSHAWCYBEREXPERT@GMAIL.COM Anonymous said... Contact James Dolan if you want to boost up your grades, hack your universities portal, gain access into someone mobile phones and socail media accounts. Me and my wife had retired for so long we were unable to apply for loan due to our low credit score until we met James dolan, then our life change for better. He boost our score and we were able to apply for loan then pay our bills and he also apply a new credit card for both me and my wife. Thanks To James Dolan, you can contact him via his email; JAMESDOLANCREDITEXPERT@GMAIL.COM or via his number; 720 358 7042. Anonymous said... Do you need a hacker for hire? Do you need to keep an eye on your spouse by gaining access to their emails? As a parent do you want to know what your kids do on a daily basis on social networks ( This includes facebook, twitter , instagram, whatsapp, WeChat and others to make sure they're not getting into trouble? Whatever it is, Ranging from Bank Jobs, Flipping cash, Criminal records, DMV, Taxes, Name it, he will get the job done. He's an expert hacker with 30 Years+ experience. Contact him at JAMESFORSHAWCYBEREXPERT@GMAIL.COM Anonymous said... James Dolan is an expert in all kinds of hacking services, which leads into giving out a blank ATM card to all individuals & serious minded people only. He hack, clone ATM cards worth's with the total sum of$500,000.00 United States Dollars, with this card you can withdraw the sum of \$10,000 as daily limit till you cash out the sum total & this cards has been cloned & hacked in the manner that you'll never be caught nor detected during usage. For more info, kindly email him: JAMESDOLANCREDITEXPERT@GMAIL.COM or via his number; 720 358 7042.

Anonymous said...

I was at the end of my rope and profoundly desperate to turn my credit score around. After speaking with James Forshaw , I felt comfortable and was willing to give him the opportunity to assist me and truth be told, I am pleased with the results he provided. My credit score did increase speedily; the communication between myself and him was excellent, fast and to the point. Very focused on what’s important. YOUR CREDIT! He also offer various types of loans to individuals with either bad or good credit with low interest rate. I, my family and friends benefits immensely from his loan service. Utilize his services by contacting him at JAMESFORSHAWCYBEREXPERT@GMAIL.COM or text him on his number 720 800 8616.

Anonymous said...

After i got scammed online by a girl i met on tinder, she ripped me off my money and stole all my money on my credit cards, my credit score got decreased and i went online to search how i can fix it and saw good comments about James Dolan and decided to give it a try. Fortunately, he put a smile on my face by boosting up my credit score to 830 excellent and clear off all debts on my credit cards. You can contact him on his email; JAMESDOLANCREDITEXPERT@GMAIL.COM or via his number; 720 358 7042 if you need his services.