New Books in Law

In this episode of International Horizons, John Torpey speaks with Joshua Colangelo-Bryan, special counsel at Human Rights First and author of Through the Gates of Hell: American Injustice at Guantanamo Bay (Humanitas Media, 2025). Drawing on his work representing detainees at Guantanamo Bay, Colangelo-Bryan recounts the legal battles, harsh detention conditions, and personal relationships that shaped his experience. He also reflects on the legacy of Guantanamo, the erosion of due process, and the troubling parallels between the post-9/11 response to terrorism and the Trump administration’s treatment of migrants today. Their conversation explores what Guantanamo reveals about the fragility of human rights and the enduring importance of legal protections against government abuse.

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The national parks are loved by many Americans and visitors from around the world. Yet, few realize how often these landscapes and their history have been shaped by questions answered in the courts. With more than 3,500 lawsuits involving the National Park Service, litigation has shaped and defined the character of the parks. Litigation has determined how land can be added to national parks, answered questions about treaty and free speech rights on park land, and settled numerous other disputes that have helped determine what the parks look like today. In her new book National Parks and the Supreme Court: Groundbreaking Legal Battles (University of Nevada Press, 2026), Carla Chung Mattix examines five landmark Supreme Court cases involving national parks over the course of nearly a century. These cases provide readers with a new lens to understanding the parks and help them understand the role of the courts in the nation's public lands. In this episode, Mattix, who was an attorney for the National Park Service in the U.S. Department of the Interior's Office of the Solicitor for 25 years, discusses her new book and the Court's influence on the national parks.

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How reading the Declaration of Independence as a document of history explains its intended meaning Thomas Jefferson chose his words carefully. Few could have been more deliberate than “When in the Course of human events,” the phrase with which he opened the Declaration of Independence. As Steven Sarson shows in The Course of Human Events: The Declaration of Independence and the Historical Origins of the United States(U Virginia Press, 2025) , the original Declaration moved through the ages of human history from Creation to American independence, assessing it according to “the Laws of Nature and of Nature’s God.” The Declaration’s history and historical consciousness therefore help answer one of American history’s great questions: How did the founders reconcile their lofty views on equality and liberty with the inequities and iniquities that they maintained in their time? The contingencies of history and the complexities of natural law, Sarson demonstrates, meant that the Declaration’s eloquent promises of equality and liberty only applied partially to women and poor men, and not at all to Loyalists, Indigenous Americans, and enslaved people. The Declaration’s assertion that “all men are created equal” has since become a promise of universal equality and liberty. As we reach its 250th anniversary, it is important to understand its original context as well as to continue the mission of making its promises a lived reality for all.

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What underpins the legitimacy of the prison system in the twenty-first century? Despite numerous challenges and setbacks, there is still a widespread belief that prisons can be improved in a socially progressive way. Even today, 'model prisons' are being built that seek to fix the shortcomings and failures of their predecessors, as if past failures were due to a lack of imagination, determination, or resources.

The aim of creating model prisons is not new: it dates back to the early nineteenth century. Ranging from England to Switzerland and Spain, from Russia to China and India, Carceral Utopia: A Global History of Modern Prisons(Polity, 2026) by Dr. Gregory Salle documents a rich, global history of ambitious efforts to create model prisons – places of confinement initially lauded for their progressive ideals but later revealed as fiascos.

At the end of this journey through time and space, it will not suffice merely to highlight the gap between plans and realities, or even to dispel the illusion that model prisons could not live up to their claims. We need to ask why, despite so many failures, these institutions are still being built today. Might their many obvious shortcomings conceal a covert success?

This interview was conducted by Dr. Miranda Melcher whosebook focuses on post-conflict military integration, understanding treaty negotiation and implementation in civil war contexts, with qualitative analysis of the Angolan and Mozambican civil wars. You can find Miranda’s interviews on New Books with Miranda Melcher, wherever you get your podcasts.

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When American churches face financial difficulties, a disproportionately high number of Black churches reorganize under chapter 11 bankruptcy. There are no easy explanations for this distinction: not location, denomination, leadership structure, or the reasons for the loans. In Forgive Us Our Debts: How Black Churches Use Bankruptcy to Survive(U Chicago Press, 2026), legal scholar Pamela Foohey asks why, then, Black churches account for two-thirds of all congregations that file for chapter 11 bankruptcy every year.

Drawing on case studies of six Black churches and one white church, and 150 interviews with church leaders, members, and attorneys, Foohey finds answers in a long history of predatory lending. Unable to negotiate with recalcitrant loan officers, Black churches turn to the legal system to force reasonable concessions from lenders to prevent the stripping of their wealth and the destruction of their communities. While the structural discrimination remains, these churches have found in the bankruptcy system a refuge and some power to fight back.

This interview was conducted by Dr. Miranda Melcher whosebook focuses on post-conflict military integration, understanding treaty negotiation and implementation in civil war contexts, with qualitative analysis of the Angolan and Mozambican civil wars. You can find Miranda’s interviews on New Books with Miranda Melcher, wherever you get your podcasts.

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In this episode, Salman Sayyid and Claudia Radiven were joined by Deana Heath to discuss her work Colonial Terror: Torture and State Violence in Colonial India (Oxford UP, 2026). Heath’s work explores the legacies of colonial violence in India, Britain’s colonial amnesia in reckoning with it’s past and how torture was facilitated and systemized. Deana is a scholar of British Imperialism and colonialism, and is also Chair in Indian and Colonial History at the University of Liverpool.

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In Human Rights in Psychiatry: Prospects and Dilemmas of Abolishing Coercion in Mental Health Care (Springer, 2025), Professor Dirk Richter describes the ethical lines of conflict, shows why coercion can no longer be justified and analyzes the consequences and dilemmas of a possible abolition of coercive measures in psychiatric care. The use of coercion in mental health care is one of the most controversial topics in psychiatric nursing and psychiatry. The conflict line centers around the UN-Convention in the Rights of People with Disabilities (CRPD). Advocates of the CRPD are pushing for the complete abolition of coercion while opponents see central medical and legal aspects of care for people with mental health problems at risk. Clinicians in conventional psychiatry, including many mental health nurses, primarily justify these measures because of the assumed benefits of coercion-associated care and with the argument that many people affected are unable to make appropriate decisions for their own health in a crisis situation. This argument also applies to human rights, for example by basing coercive measures in the event of suicidality on the right to life. Three central topics are developed in the book. First, it is shown that psychiatric coercion can no longer be justified because the current practice of psychiatric care does not meet the ethico-legal requirements for the use of coercion. Second, a human rights-based approach of psychiatric care is outlined, which is fundamentally based on the will and preferences of people with mental health problems. Third, the consequences and dilemmas are indicated, e.g., the issue of how to deal with suicidality or dementia without the use of coercion. This book is aimed to receive a specific attention from the psychiatric nursing community. It is also relevant to lawyers, human rights practitioners, and mental health professionals more broadly.

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Before Ruth Bader Ginsburg persuaded the Supreme Court to strike down sex discrimination, Dorothy Kenyon drew the legal blueprint. Justice Was Her Calling: The Fierce and Fascinating Life of Dorothy Kenyon(U California Press, 2026) by Jennifer Brinkley is the first full-length biography of the New York judge, lawyer, and civil liberties champion whose litigation strategies helped transform the Equal Protection Clause into a powerful tool for women’s rights. Across decades, from the Progressive Era through the New Deal and into the rise of second-wave feminism, Dorothy Kenyon stood at the forefront of reform.

A longtime ACLU national board member, the only woman appointed by the League of Nations to study women’s legal status worldwide, and a US delegate to the United Nations Commission on the Status of Women, Kenyon pushed equality onto the global stage long before it was widely embraced. Her career was nearly undone when Senator Joseph McCarthy named her first on his list of alleged communists, a spurious accusation that cast a lasting shadow.

Drawing on letters, speeches, and fresh archival research, Brinkley restores Kenyon to her rightful status as a legal pioneer and reminds us that civil liberties endure only when defended.

This interview was conducted by Dr. Miranda Melcher whosebook focuses on post-conflict military integration, understanding treaty negotiation and implementation in civil war contexts, with qualitative analysis of the Angolan and Mozambican civil wars. You can find Miranda’s interviews on New Books with Miranda Melcher, wherever you get your podcasts.

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Offshore Oildom: America’s Energy Expansion into the Ocean (LSU Press, 2026) tells the riveting story of the United States’ quest to secure the oil riches of the sea. Drawing on a wealth of untapped sources, Tyler Priest reveals how the offshore oil industry emerged from an ambitious project to incorporate the ocean’s submerged lands into the territory of the United States. These lands were frontier spaces, beyond traditional jurisdiction and control. Efforts to commandeer them for oil and gas extraction thus required new institutions of governance. From the titanic struggle over the tidelands starting in the 1930s to Project Independence in the 1970s, the process of establishing an offshore dominion of oil provoked intractable conflicts over money, values, and power. It pitted coastal states against their land-locked counterparts and captains of industry against federal civil servants and coastal communities. It stoked partisan and internecine warfare. It set off an international race to annex offshore territory, complicating U.S. foreign-policy objectives. It weighed on the minds of Supreme Court justices and troubled every occupant of the White House from Franklin Roosevelt forward. The modern environmental movement was born in opposition to offshore oil just as the 1970s energy crisis compelled the acceleration of drilling in the ocean. Creating and governing an offshore oildom involved nothing less than redrawing the territorial borders of the nation, rebuilding the political foundations of the U.S. energy system, and testing the environmental limits of resource extraction. This history is essential to understanding the tension between energy security and environmental protection in modern America.

Tyler Priest is associate professor of history at the University of Iowa. He is the author of the award-winning book The Offshore Imperative: Shell Oil’s Search for Petroleum in Postwar America and has published in the Journal of American History, Environmental History, Enterprise & Society, the Wall Street Journal, Politico, and Science. In 2010 he served as a senior policy analyst on the President’s National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling.

Filippo De Chirico is a PhD candidate in History and Politics of Energy at Roma Tre University (Italy). His research focuses on the history of the natural gas sector in Italy.

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Despite there being more than 16 million disabled people in the UK today, disability rarely features in mainstream accounts of our past. That absence is not down to a lack of evidence: it is a forgotten, suppressed history – the result of deliberate choices about whose histories matter. This remarkable book rectifies this.

Disability: A History of Resistance (Random House, 2026) is a story of resistance and ingenuity, full of people who refused to be silenced or pitied. We meet the labourer who fights accusations in court that he’s faking his disability, and wins; the painter who signs her royalty miniatures ‘without hands’; and the one-armed textile worker who turned his injury into reform. We see how disabled people have rallied together to demand equality – fighting for their right to lead ordinary lives like everybody else.

This is a story not of progress led by doctors or philanthropists, but an extraordinary ground-up history of ordinary people demanding dignity and justice. By putting disabled people back into our national story, David Turner reveals a fuller and richer history of modern Britain than ever before.

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Why was the Japanese Army so brutal before and during World War Two? This haunting question anchors a sweeping investigation into the moral universe of Imperial Japan’s soldiers, tracing their path from the twilight of the samurai age to the ashes of Manila in 1945.

Punishment: Behind Japanese Military Brutality(Hurst, 2026) by Professor Danny Orbach uncovers a world in which war was conceived not merely as combat, but also as justice. Officers and soldiers learned to navigate two rival visions of war: one restrained by the ‘foreign gaze’ of the Western world, the other rooted in older traditions that cast adversaries as ‘rebels’ and ‘bandits’ deserving exemplary punishment. However, these competing strategies were intertwined, in an interplay of mutual mitigation and brutalisation. Drawing on archival material in six languages and fieldwork conducted across Asia—from Taiwan’s indigenous highlands to Manchuria’s sorghum fields and the streets of Nanjing—Professor Orbach reveals how ambiguity, obedience, fear and ideology converged on the battlefield. Vague orders could become massacres, and the boundary between necessity and cruelty became perilously thin.

Part detective story, part moral history, Punishment illuminates how a modern state slid into devastating violence—and why that descent was neither inevitable nor easily explained.

This interview was conducted by Dr. Miranda Melcher whosebook focuses on post-conflict military integration, understanding treaty negotiation and implementation in civil war contexts, with qualitative analysis of the Angolan and Mozambican civil wars. You can find Miranda’s interviews on New Books with Miranda Melcher, wherever you get your podcasts.

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Social media giants like Meta and transnational regulators such as the European Union are transforming private governance by creatively emulating public law frameworks. Drawing on exclusive interviews and in-depth analysis of Meta's Oversight Board and the EU's Digital Services Act, Governance by Emulation: The Oversight Board, the Digital Services Act, and the Struggle for Platform Accountability (Cambridge UP, 2026) explores how these approaches blend European and American perspectives, bridging distinct legal traditions to address the challenges of platform governance. Analysis of content moderation practices and their implications uncovers a critical pattern in the evolution of governance for industries that will define the future, from digital platforms to emerging technologies. Combining public and private law in innovative ways, the book sheds light on bold governance experiments that will shape the digital world-for better or worse. This study offers crucial insights for understanding the next chapter of global governance in an increasingly interconnected and privatized world. This title is also available as Open Access on Cambridge Core.

Find Moritz here

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Why would a government bother to go after groups that carry no weapons and hold no power? Suparna Chaudhry argues that the answer says a lot about where politics is heading. In Civil Societies and Civil States: Government Repression of NGOs (Cornell University Press, 2026), she shows that states are targeting advocacy organizations less often with violence and more often with laws. These laws cap foreign funding, restrict advocacy, and bury groups in paperwork, to name just a few examples. Because the measures look like routine regulation, they rarely make headlines. Democracies have become as skilled at using them as dictatorships.

We discuss how the fading liberal international order has given governments more freedom to act. We also talk about why urgent threats draw violence while long-term ones draw bureaucracy, and how lawmakers copy each other's anti-NGO laws word for word. We then look at why China tolerates Greenpeace, how one Ethiopian law closed nearly 90 percent of the country's human rights groups, and what shrinking aid budgets mean for the sector.

Our guest is Suparna Chaudhry, an Associate Professor in the Department of International Affairs at Lewis & Clark College.

Our host is Eleonora Mattiacci, an Associate Professor of Political Science at Amherst College. She is the author of "Volatile States in International Politics" (Oxford University Press, 2023).

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Immoral Traffic: An Ethnography of Law, NGOs, and the Governance of Prostitution in India (Cambridge UP, 2025) delves into the complex intersection of India's anti-prostitution law and global anti-trafficking campaigns, and how they impact sex workers in both voluntary and involuntary situations. Immoral Traffic examines the role of legal actors and NGOs in implementing these interventions, revealing the mix of paternalism, humanitarianism, punitive care, bureaucracy, and morality in their efforts. Through a sequence of interventions prescribed by India's anti-prostitution law, the book follows the experiences of sex workers, from rescues to courts to carceral shelters. It sheds light on the ways in which donor-driven NGOs draw upon this law to implement anti-trafficking agendas, and how these interventions are navigated by women removed from the sex trade. Detailed and eye-opening, this book is a valuable resource for scholars and students of anthropology, law and society, gender and sexuality studies, South Asian studies, global studies, and critical studies of NGOs and humanitarianism.

Vibhuti Ramachandran is an anthropologist of law, gender and sexuality, and South Asia. She serves as an Associate Professor at University of California-Irvine's Department of Global and International Studies, School of Social Sciences.

Saumya Dadoo is a PhD Candidate at Columbia University's Department of Middle East, South Asian, and African Studies (MESAAS). Her dissertation focuses on the history of policing and punishment in colonial North India.

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Kelly Lytle Hernández joins Michael Stauch to discuss how the US immigration system has always been “racist by design.” Many Americans’ understanding of the immigration system begins with the Chinese Exclusion Act of the late nineteenth century. InRacist by Design: Two Centuries of U.S. Immigration Control (Norton, 2026), Lytle Hernández expands that history by a full century, showing how the Haitian Revolution of the 1790s inspired not only America’s first immigration bans (to prevent news of a free Black republic from reaching our shores) but also its first refugee resettlement program (to welcome and support Haiti’s evicted enslavers.) She explains how Chinese Exclusion led the Supreme Court to disconnect immigration laws from the constitution. She reveals how eugenicists and Jim Crow segregationists built much of our current immigration regime as expressly "whites-only," and shows how during the Civil Rights Movement, Congress amended this system but never abolished it, leaving many of the regime’s racist rules and rituals intact today.

Highlights include:

- How an “Exclusion Quartet” of rulings by the Supreme Court in the late 19th century “unhinged” the Constitution from immigration policy;

- How the “family reunification” clause of the 1965 Immigration and Nationality Act, meant to favor European migrants, combined with global instability in the 1970s and ‘80s to create an enormous wave of non-white immigrants to the United States;

- What changed (and didn’t change) in immigration policy during World War II and the Cold War;

- How guestworker programs, asylum restrictions, and the US “visa dome” contribute to the racist-by-design immigration regime;

- How immigrants and their advocates have long used cracks and loopholes in immigration legislation to create space for themselves in the United States.

Guest: Kelly Lytle Hernández is a Professor in the Departments of History, African American Studies, and Urban Planning at UCLA where she also holds the Thomas E. Lifka Endowed Chair of History. She is one of the nation’s leading experts on race, immigration, and mass incarceration, and the author of the award-winning books Migra! A History of the U.S. Border Patrol (University of California Press, 2010), City of Inmates: Conquest, Rebellion, and the Rise of Human Caging in Los Angeles (University of North Carolina Press, 2017), and Bad Mexicans: Race, Empire, and Revolution in the Borderlands (W. W. Norton, 2022).

Host: Michael Stauch is an associate professor of history at the University of Toledo and the author of Wildcat of the Streets: Detroit in the Age of Community Policing, published by the University of Pennsylvania Press in 2025.

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The Real Pain of Punishment: Prison, Belonging, and the Quest for Humanized Justice (Cambridge UP, 2026) highlights the concept of 'belonging' as an unprecedented lens for critically interrogating the legitimacy of incarceration across penal theory, sentencing practice, and human rights frameworks. The chapters chart pathways for bridging the gap between the normative idea of punishment and the stark realities of prison life. The final chapter, written with scholars currently and formerly incarcerated in a New York State facility, reflects on how embracing belonging within penal approaches can inform responses to harm grounded in humanization, proximity, empowerment, and collaboration. With this chapter and more, the book, advances a call for deeper epistemic dialogue within legal discourse on crime, punishment, and justice.

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The Kurdish-populated Wan/Van Province is a major smuggling hub between Turkey and Iran. Kurdish smugglers cross this 180-mile-long land border, transporting everyday consumer goods—fuel, tobacco, sugar, and tea—as well as more illicit goods, and the province supports the financial, technical, and labor capacities that sustain these smuggling economies. As the Turkish state has enacted increasingly punitive anti-smuggling laws, smuggling has also become a site of contentious politics. Smuggling Law: Unsettled Sovereignties in Turkey’s Kurdish Borderlands (Stanford UP, 2025) explores anti-smuggling law enforcement and criminal prosecutions to reveal a key site—the criminal court—where borders and claims of sovereignty are simultaneously remade and disrupted.

Taking readers from border villages, mountain passes, and road checkpoints to courtrooms, law offices, and forensic laboratories, Fırat Bozçalı examines how Kurdish smugglers, with the help of their lawyers, legally disrupt state sovereignty in criminal courts. Kurdish smugglers and lawyers adopt and rework procedures, rules, and reasonings in ways that interrupt the courts' capacity to coopt, discipline, and oppress. Bozçalı theorizes this evasive engagement with the legal system as a strategy of techno-legal politics among marginalized and persecuted groups, one that extends beyond the Kurdish case. Smuggling Law holds profound relevance in today's world, where ever-expanding regimes of surveillance, oppression, and dispossession unfold in the broader contexts of the global war on terror and data-driven capitalism.

Fırat Bozçalı is Associate Professor of Anthropology at the University of Toronto.

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For those concerned with how city hall can shape the look and feel of a neighborhood, the mere mention of zoning may invite denunciation of zoning practices that contributed substantially to the housing crisis and so limited neighborhood development that you have to get in your car to pick up a quart of milk.

In her readable Key to the City: How Zoning Shapes Our World(Norton, 2024), Sara Bronin, the Freda Alverson Professor of Law at George Washington University, points out if you want to put up a single-family house of around 2,500 square feet, then at a minimum you may be required to purchase a 43,350 square foot (one acre) lot on which you but nobody else can build. No wonder we have a housing shortage. And after you move in, you will likely find yourself living in a neighborhood zoned “residential,” that is without stores or businesses within walking distance. So it will be necessary to own a car for shopping and just about everything else.

In this conversation and in Key to the City, Professor Bronin suggests addressing the housing shortage by amending local zoning to make it possible to build several houses per acre. Then too neighborhoods currently zoned “residential” might re-designated for “mixed uses” so that one might walk to stores and restaurants. But Bronin cautions that however inviting the notion of strolling over to the grocery, café or bookstore, how would you feel if a gas station, used car lot or strip joint opened in your neighborhood?

By no means confined to the ivory tower, Professor Bronin, who served for seven years on Hartford’s Planning and Zoning Commission, recognizes that the underlying purpose of zoning––to protect the homeowner from unwanted intrusions––remains valid. And after showing how Hartford, Minneapolis, Tucson, and Baltimore went about revising their zoning ordinances, she concludes that zoning remains an essential tool for developing decent neighborhoods. She then implicitly invites us to take a walk around the block to consider what might be done to make our neighborhood all the better. 

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We Will Receive Justice: Native Histories of the Collapse of the California Missions (U Nebraska Press, 2026) by Dr. Lee M. Panich & Gustavo Flores explores how Native people in the southern San Francisco Bay Area—the ancestors of today’s Ohlone community—navigated the collapse of the California mission system. The volume spans from Mexican independence in 1821 through the region’s annexation by the United States in 1846, as Native people from Mission Santa Clara and Mission San José fought for emancipation and restitution amid rapidly changing colonial circumstances.

The narrative is driven by a reexamination of archives related to the Pueblo of San José, the territorial capital of Monterey, and early U.S. court cases regarding Mexican-era land grants, contextualized through an in-depth analysis of mission records that illuminate the complex social connections of Native individuals and families. We Will Receive Justice offers an ethnohistorical lens for viewing the Indigenous history of Mexican California, examining not simply the history of colonization but how Native people drew on cultural traditions and social relationships to create new lives for themselves in the wake of the Franciscan mission system.

This interview was conducted by Dr. Miranda Melcher whosebook focuses on post-conflict military integration, understanding treaty negotiation and implementation in civil war contexts, with qualitative analysis of the Angolan and Mozambican civil wars. You can find Miranda’s interviews on New Books with Miranda Melcher, wherever you get your podcasts.

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Professor Tom Hulme's second book reconstructs the erotic and romantic lives of queer men in Belfast across roughly seventy years, from the recriminalisation of sex between men in the 1880s to the emergence of a mainstream public debate about homosexuality in the 1950s. It follows men cruising the city centre, reading and passing around homosexual novels, forging relationships across the lines of class and religion, and navigating a world that was often more knowing and more tolerant than Northern Ireland's later reputation would suggest. Where we might expect only shame and fear, Hulme finds pride, defiance, and a guarded everyday acceptance, though one whose limits fell hard on those caught with much younger partners, and one that narrowed sharply after the Second World War.

Belfastmen: An Intimate History of Life Before Gay Liberation (Cornell UP, 2026) is built from two very different archives, the criminal record of some sixty Belfast court cases and shaped by the violence of policing, and the extraordinary personal diaries of David Strain, forty-three volumes and perhaps two million words, brought into scholarly use here for the first time. Out of that pairing Hulme develops the book's broader argument, a case for intimate, emotionally invested methods in the history of sexuality, and two organising ideas: the "intimate queer city," in which Belfast's very scale and familiarity shaped how men met and loved, and the "queer Irish world," which places sailors, the docks, and migration between Belfast, Liverpool, and New York at the centre of the story. Along the way the book takes up religion and respectability, masculinity on trial, and the entanglement of queerness with the ethnonational and sectarian order of Ulster.

Belfastmen is published open access by Cornell University Press and can be read for free through the Cornell Open initiative.

About the author

Tom Hulme is a professor at Queen's University Belfast and a cultural historian of modern Britain and Ireland. He is Principal Investigator of the Arts and Humanities Research Council project Queer Northern Ireland: Sexuality Before Liberation, run with Professor Leanne McCormick, and the author of After the Shock City: Urban Culture. His work on queer history has appeared in Irish Historical Studies, The History of the Family, and the Journal of the History of Sexuality, and his research has been covered in the Guardian and the Irish Times.

About the host

Niall Herron is a PhD researcher in Anthropology at Queen's University Belfast. His ethnographic work examines queer experience during the Northern Ireland Troubles, taking the everyday as a focal point for how queerness and space were assembled across the period, and how sexuality, gender, region, ethnonational identity, and class were bound up together. His writing has appeared in the anthropology journal Ethnos and the academic queer history blog NOTCHES.

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