[Cite as State v. Haas, 2021-Ohio-4346.]
IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT FULTON COUNTY
State of Ohio Court of Appeals No. F-20-011
Appellee Trial Court No. 20CR000009
v.
Shannon L. Haas DECISION AND JUDGMENT
Appellant Decided: December 10, 2021
*****
Scott A. Haselman, Fulton County Prosecuting Attorney, for appellee.
Karin L. Coble, for appellant.
DUHART, J.
{¶ 1} This is an appeal filed by appellant, Shannon Haas, from the August 12,
2020 judgment of the Fulton County Court of Common Pleas, denying her motion to
suppress. For the reasons that follow, we affirm the trial court’s judgment. {¶ 2} Haas sets forth one assignment of error:
[Haas]’s statements made to both her supervisor and a sheriff’s
deputy were compelled in violation of the Fifth Amendment, pursuant to
Garrity v. New Jersey.
Background
{¶ 3} At all times relevant, Haas was a social worker at Fulton County Job and
Family Services (“FCJFS”), employed as an ongoing worker responsible for Fulton
County Children’s Services (“FCCC”) cases.
{¶ 4} On February 12, 2018, Haas signed a form entitled Confidentiality
Agreement (“Agreement”). By signing the Agreement, Haas acknowledged that she read
and understood FCJFS’s procedure for confidentiality. The Agreement provided, inter
alia, “[y]ou may not operate or permit operation of ODJFS [Ohio Department of Job and
Family Services] or State Data Center equipment for personal business * * * [and] * * *
[y]ou must report violation of confidentiality to their [sic] immediate leader.”
{¶ 5} On May 7, 2019, Haas signed a form entitled Ohio Department of Job and
Family Services Code of Responsibility (“Code”), representing that she had “read,
underst[ood] and will comply with this ODJFS Code.” The Code provided, inter alia:
Security and confidentiality are a matter of concern for all users of the * * *
(ODJFS) information systems and all other persons who have access to
ODJFS confidential data. Each person that is entrusted with an authorized
2. ID to access ODJFS systems, holds a position of trust relative to this
information and must recognize the responsibilities entrusted to him/her in
preserving the security and confidentiality of this information. * * *
An authorized user’s conduct either on or off [of] the job may threaten the
security and confidentiality of this information. It is the responsibility of
every user to know, understand and comply with the following:
***
2. I will not make or permit unauthorized uses of any information
maintained by ODJFS, regardless of the medium in which it is kept.
3. I will only access information about recipients of ODJFS benefits or
services, or about ODJFS employees, that is collected and maintained on
ODJFS or state computer systems for those purposes authorized by ODJFS,
and as directly related to my official job duties and work assignments for,
and on behalf of, ODJFS * * *.
8. I will not violate rules and/or regulations concerning access and/or
improperly use security entry cards or codes for controlled areas.
10. I will immediately report any violation of this code of responsibility to
my supervisor and/or the OIS Access Control Unit.
3. ***
In addition to applicable sanctions under federal and state regulations,
violations of this policy will be reviewed on a case-by-case basis and
may result in disciplinary action up to and including removal.
{¶ 6} In December 2019, Amy Metz-Simon, the Director of FCJFS, was contacted
by the Director of Lucas County Children’s Services (“LCCS”). Simon was advised
Haas may have used the Job and Family Services computer system to access an allegation
in an open case made against Haas and her family. Simon called Maurine Clymer,
Haas’s supervisor, and told Clymer to bring Haas to the conference room at FCCC for a
meeting.
{¶ 7} Simon met with Haas and Clymer. Simon asked Haas if she had accessed
her own children’s services case through the State Automated Child Welfare Information
System (“SACWIS” or “state system”). Haas denied doing so. Simon informed Haas
that, according to Lucas County, Haas accessed the state system eight times. Haas then
admitted she might have accessed the state system once.
{¶ 8} Clymer had not known Haas had an open investigation or that Haas had
accessed the system. Clymer asked why Haas had not made her aware that there was an
open investigation, and Haas responded she was afraid she would be fired and she knew
the allegation was not true.
4. {¶ 9} Simon stated she would follow up with administration in order to determine
how to proceed. Simon was told county breaches of the state system had to go through
local law enforcement, so ultimately, the Fulton County Sheriff’s Office was notified.
{¶ 10} Deputy Matt Smithmyer of the Fulton County Sheriff’s Office called Haas
at FCJFS, and explained to her that he was made aware of the situation where
information was accessed from the state system. He told Haas that he would like her to
come and talk to him. On January 6, 2020, Haas arrived at the sheriff’s office and
Deputy Smithmyer advised her she was not under arrest, she was free to leave and she
did not have to answer any questions. Haas was interviewed for twenty-five to thirty
minutes by the deputy.
{¶ 11} On January 14, 2020, Haas was indicted by the Fulton County Grand Jury
on two counts of unauthorized use of computer, cable, or telecommunication property in
violation of R.C. 2913.04(B), fifth degree felonies. Thereafter, she pled not guilty.
{¶ 12} On June 8, 2020, Haas filed a motion to suppress statements. On July 27,
2020, the state filed a response. A hearing on the motion was held on August 5, 2020,
and three witnesses were called to testify: Director Simon; Supervisor Clymer; and
Deputy Smithmyer. On August 12, 2020, the trial court denied the motion to suppress.
{¶ 13} On August 20, 2020, Haas pled no contest to one count of unauthorized use
of computer, cable, or telecommunication property in violation of R.C. 2913.04(B), a
fifth degree felony. The trial court accepted the plea and found Haas guilty. On
5. November 4, 2020, Haas was sentenced. Haas appealed the denial of her motion to
suppress.
Motion to Suppress
{¶ 14} In Haas’s motion, she sought to have the trial court suppress the statements
she made to her employer and to law enforcement, as she claimed the statements were
taken in violation of her rights under Garrity v. State of N.J., 385 U.S. 493, 87 S.Ct. 616,
17 L.Ed.2d 562 (1967). She claimed her confessions were improperly secured in
violation of the Fifth, Sixth and Fourteenth Amendments to the United States
Constitution, as the confessions were not voluntary. In support, Haas cited to State v.
Sess, 136 Ohio App.3d 689, 692, 737 N.E.2d 969 (1st Dist.1999), where the court stated:
As recognized by the Supreme Court of the United States in Garrity v. New
Jersey, if a public employee is forced to make the Hobson’s choice of
answering questions that may incriminate him or of forfeiting his job,
statements made pursuant to such questioning are not voluntary and cannot
be used in a subsequent prosecution against the public employee.
{¶ 15} Haas argued she was told, when she met with and was questioned by
Director Simon, that if she did not cooperate, she would be placed on administrative
leave and criminal charges were likely. Haas asserted she was never advised of her
Garrity rights. Haas maintained she was directed by FCJFS to meet with Deputy
Smithmyer and discuss the matter, and the deputy questioned her upon Simon’s request.
6. {¶ 16} Haas contended all of her statements to FCJFS should be suppressed and
“all statements to law enforcement made upon direction by and with cooperation with her
employer should be suppressed.” Haas also cited to State v. Gideon, 3d Dist. Allen No.
1-18-27, 2019-Ohio-2482, 130 N.E.3d 357, ¶ 23-27 and 30 (“Gideon I”).
Trial Court’s Decision and Order
{¶ 17} In its August 12, 2020 decision and order, the trial court set forth the
following findings and conclusions.
{¶ 18} Haas was a public employee with Job and Family Services who stood
accused of illegally accessing secured files.
{¶ 19} At the hearing on the motion to suppress, Haas presented no witnesses and
the state presented three witnesses. The witness testimony indicated a Lucas County Job
and Family Services representative conducted an investigation involving Haas, and Haas
provided information to Lucas County which she could not have known without
inappropriately accessing files while at work. Lucas County alerted Director Simon, who
was concerned Haas had violated protocol in accessing the files or someone may have
accessed Haas’s computer or password, which was a breach of security.
{¶ 20} Simon testified she met with Haas and Supervisor Clymer, and Haas
admitted she accessed the file once. Simon testified she did not indicate at any time that
Haas was required to answer questions or that Haas would lose her job or be disciplined.
Simon did not know the proper procedure for an infractions of rules and indicated there
7. may be some disciplinary action, but the discussion was not made with any threat relating
to Haas’s cooperation
{¶ 21} Clymer testified she was not told why Haas needed to be in the office.
Clymer did not indicate to Haas that Haas needed to talk about what happened or Hass
would lose her job.
{¶ 22} Deputy Smithmyer testified he was informed of Haas’s action and
conducted at investigation. He requested that Haas come to his office to make a
statement. Before she made a statement, the deputy told Haas she could leave at any
time, and at no time did the deputy indicate that she would be subject to any discipline if
she failed to cooperate with the investigation.
{¶ 23} During cross-examination of the witnesses, Haas introduced as exhibits the
Agreement and the Code.
{¶ 24} The trial court set forth Haas’s “arguments during the hearing seem to
suggest as [Haas] signed [the Agreement and the Code], she must have been aware of the
potential for disciplinary action, including termination, if she did not cooperate.
Therefore, her statements were coerced and should be suppressed.” The court observed
that Garrity requires that statements made by public employees under duress must be
suppressed, and if no express threat was made, statements are considered compelled by
threat of discharge if a person subjectively believed she would be fired for asserting the
8. privilege, and that belief must be objectively reasonable under the totality of the
circumstances.
{¶ 25} The trial court found there was no express threat in Haas’s case. The court
further found it had no way of knowing whether Haas was aware of the potential for
disciplinary action, including termination, if she did not cooperate when she made any of
her statements because Haas exercised her right not to testify at the motion hearing.
Thus, the court examined the totality of the circumstances to determine whether Haas’s
statements were coerced. The court set forth:
If the Court were to determine the mere signing of [the Agreement
and the Code] constituted grounds for a subjective belief by any Defendant
that they would be terminated if they did not make a statement, then every
statement by a public employee would be subject to suppression under
Garrity. That is not the ruling in Garrity.
The mere signing of the documents by [Haas] at the time she began
her employment with this agency does not provide the Court with
circumstances sufficient to form an opinion [that] * * * [Haas] had a
subjective belief she would be terminated if she did not cooperate in an
investigation. There was no other evidence presented to assist the court in
that regard.
{¶ 26} The trial court denied the motion to suppress.
9. Assignment of Error
{¶ 27} Haas argues her statements to Director Simon and Deputy Smithmyer were
compelled in violation of the Fifth Amendment, pursuant to Garrity.
{¶ 28} Haas cites to State v. Graham, 136 Ohio St.3d 125, 2013-Ohio-2114, 991
N.E.2d 1116, ¶ 21, in support of the assertion that if a public employer compels
statements from an employee through threat of termination if the employee does not
cooperate, the statements cannot be used in a subsequent criminal case.
{¶ 29} Haas observes the trial court denied her motion to suppress, finding her
statements were not compelled or coerced. And, the court found no one had expressly
threatened her with job termination if she did not cooperate. Haas notes the court found
it could not know her subjective state of mind because she did not testify, and the court
also found, considering the Agreement and the Code, she could not have had a subjective
belief that she would be terminated.
{¶ 30} Haas argues the trial court misconstrued the law, as “[a] threat of
employment termination need not be expressly communicated. Garrity still applies if the
employee had a subjective belie[f] that was objectively reasonable considering the
totality of the circumstances. Graham at ¶ 24; State v. Gideon, 165 Ohio St.3d 156,
2020-Ohio-6961,” ¶ 15 (“Gideon II”). Haas contends “[i]n Graham, as here, the
defendant did not testify at the suppression hearing,” and the Graham court “found a
notice given to defendants dispositive * * * and sufficient for the Court to conclude that
10. defendants had a subjective belief they would be terminated for non-cooperation, and that
belief was objectively reasonable.”
{¶ 31} Haas submits “Graham dictates a conclusion that the trial court erred in
finding [the Agreement] and [the Code] were insufficient to cause Haas’ [sic] to believe
that she ‘could’ be fired for refusing to cooperate.” And, the trial court erred in
concluding Haas’s subjective state of mind could not be ascertained because she did not
testify, as the Graham defendant did not testify. Haas also claims “as in Graham, [the
Agreement] and [the Code] represent ‘some demonstrable state coercion above the
general directive to cooperate.’”
{¶ 32} Haas maintains the Agreement and the Code should suffice to find she had
a subjective belief that she could be terminated for refusing to cooperate, “especially in
light of Clymer’s testimony that Haas said that she believed she would be fired.” Haas
insists “her belief was objectively reasonable under the circumstances. ODJFS directly
communicated to her that job termination may result from violations.”
Law
Garrity v. New Jersey
{¶ 33} The appellants were police officers in New Jersey who were questioned by
the state’s attorney general during the course of an investigation concerning the alleged
fixing of traffic tickets. Garrity, 385 U.S. at 494, 87 S.Ct. 616, 17 L.Ed.2d 562. “Before
being questioned, each appellant was warned (1) that anything he said might be used
11. against him in any state criminal proceeding; (2) that he had the privilege to refuse to
answer if the disclosure would tend to incriminate him; but (3) that if he refused to
answer he would be subject to removal from office.” Id. Each appellant answered
questions and some of the answers were used in subsequent prosecutions, over
appellants’ objections that their statements were coerced “by reason of the fact that, if
they refused to answer, they could lose their positions with the police department.” Id.
Appellants were convicted, and on appeal, the voluntariness of the statements was at
issue. Id. at 495-496.
{¶ 34} Ultimately, the case reached the Supreme Court of the United States which
held “the protection of the individual under the Fourteenth Amendment against coerced
statements prohibits use in subsequent criminal proceedings of statements obtained under
threat of removal from office, and that it extends to all * * * members of our body
politic.” Id. at 500.
State v. Graham
{¶ 35} The appellants were employees of the Ohio Department of Natural
Resources (“ODNR”) who were interviewed during an investigation conducted by the
Ohio inspector general. Graham, 136 Ohio St.3d 125, 2013-Ohio-2114, 991 N.E.2d
1116, ¶ 2, 4. “Prior to the questioning, each appellant signed an oath [or notice] that
included the following statement: ‘I understand that by affirming my truthfulness under
oath, I am subject to criminal sanctions if I provide false information.’” Id. at ¶ 4. None
12. of the appellants was advised of the right to counsel before the interview. Id. Each
appellant was subsequently indicted and “filed motions to suppress or, alternatively,
dismiss, on the ground that their statements * * * were coerced by threat of job loss and
were therefore inadmissible under Garrity.” Id. at ¶ 10. The trial court suppressed the
statements finding they were compelled and thus, inadmissible. Id. at ¶ 14. The court of
appeals reversed and decided “in the absence of any express threat, appellants had not
been compelled within the meaning of Garrity.” Id. at ¶ 15.
{¶ 36} The Supreme Court of Ohio noted “[c]ompulsion within the meaning of
Garrity is obvious in cases in which, as in Garrity, the state has expressly confronted the
public employee with the inescapable choice of either making an incriminatory statement
or being fired.” Id. at ¶ 23. However, when there is no express threat, the court held “for
a statement to be suppressed under Garrity, the employee claiming coercion must have
believed that his or her statement was compelled on threat of job loss and this belief must
have been objectively reasonable.” Id. at ¶ 24. The court observed that “[d]etermining
whether an employee’s subjective belief was objectively reasonable requires a court to
examine the totality of the circumstances * * * [and] [t]he circumstances must show some
demonstrable coercive action by the state beyond ‘[t]he general directive to cooperate.’”
(Citation omitted.) Id. at ¶ 23. The court explained “‘ordinary job pressures, such as the
possibility of discipline or discharge for insubordination, are not sufficient to support an
objectively reasonable expectation of discharge.’” (Citation omitted.) Id.
13. {¶ 37} The Supreme Court further held “[i]n examining whether an employee’s
belief was objectively reasonable under the circumstances, evidence of an express threat
of termination or a statute, rule, or policy demanding termination will almost always be
sufficient to show coercion.” Id. at ¶ 24. The court concluded “the express threat in the
ODNR notice was sufficiently coercive so as to trigger the protections of Garrity * * *
[as] [a]ppellants answered questions after receiving a warning that they could be fired for
failing to do so. Statements extracted under these circumstances cannot be considered
voluntary within the meaning of Garrity.” Id. at ¶ 29-30.
Gideon I
{¶ 38} Gideon was a licensed physician who was investigated for inappropriately
touching patients. Gideon, 3d Dist. Allen No. 1-18-27, 2019-Ohio-2482, 130 N.E.3d
357, ¶ 2. The investigation was undertaken by a law enforcement officer and an
investigator with the State Medical Board, who agreed to cooperate with each other and
trade information. Id. at ¶ 2-3. Gideon denied the patients’ allegations when questioned
by the officer. Id. at ¶ 3. The investigator told the officer that he, the investigator, would
interview Gideon, and the investigator warned the officer against participating in the
interview because Gideon “was statutorily obligated to cooperate with his investigation -
so that any confession could be used in a criminal proceeding against [him].” Id. at ¶ 3.
The investigator interviewed Gideon at his medical office, and “[c]ommensurate with his
duty to cooperate and provide truthful answers to [the] [i]nvestigator[’s] questions,
14. Gideon provided [the] [i]nvestigator with an oral and written statement.” Id. at ¶ 4. The
investigator shared the statements with the officer. Id.
{¶ 39} Gideon was charged with several crimes. Id. at ¶ 5. He filed a motion to
suppress evidence, requesting his statements to the investigator be suppressed because
they were involuntary and elicited in violation of his due process right and privilege
against self-incrimination. Id. at ¶ 6. The trial court denied the motion finding Gideon
“‘made voluntary statements during a noncustodial interview.’” Id.
{¶ 40} The court of appeals reversed, concluding Gideon’s statements were not
voluntary as the investigator’s actions created the impression that Gideon’s “refusal to
cooperate with his investigation would result in the type of penalty prohibited under
Garrity.” Id. at ¶ 51. The appellate court further concluded Gideon’s “belief that his
medical license would be penalized if he did not cooperate with [the] [i]nvestigator[’s]
investigation was objectively reasonable.” Id.
Gideon II
{¶ 41} The Supreme Court of Ohio, in reversing the court of appeals, noted
“[u]nlike the officers in Garrity, Gideon is not a public employee. He was a medical
doctor in private practice * * * subject to licensure by the state medical board * * * [and
his] medical license constitutes a liberty and property interest subject to due-process
protections.” Gideon, 165 Ohio St.3d 156, 2020-Ohio-6961, ¶ 12. The court observed
“[t]he medical board has disciplinary authority over medical doctors and may ‘limit,
15. revoke, or suspend a license or certificate to practice * * *.’ R.C. 4731.22(B).” Id. at ¶
13. And “[a]mong the reasons listed for exercising the authority to impose such
sanctions is the ‘[f]ailure to cooperate in an investigation’ and the ‘failure to answer
truthfully a question presented by the board in an investigative interview * * *.’” Id.
And further “[t]he state’s threat to impose a legal penalty for the failure to give truthful
responses in a state-medical-board investigation is coercive.” Id. at ¶ 14.
{¶ 42} The court, citing Graham, noted Gideon was not “‘expressly confronted * *
* with the inescapable choice of either making an incriminatory statement or being
fired.’” Id. at ¶ 15. The court applied the Graham test and held Gideon “did not
establish through evidence that coercive action by the * * * investigator had occurred.
The trial court found no evidence that the * * * investigator informed Gideon that ‘he
must waive his rights against self-incrimination or subject himself to discharge or
revocation of his license.’” Id. at ¶ 18. Neither Gideon nor the investigator stated or
suggested during the interview that Gideon “could lose his medical license if he refused
to comply with the investigator’s questioning.” Id.
{¶ 43} The Supreme Court concluded:
Gideon’s medical license is a property right and that the threatened loss of
the license is a form of coercion that can compromise the * * * privilege
against self-incrimination. That said, in order for coercion to be sufficient
to warrant the suppression of statements Gideon made during a medical-
16. board investigative interview, his belief that he would lose his license if he
failed to participate in the * * * interview and answer questions truthfully
must be both subjectively believed and objectively reasonable. In this case,
based on our independent, de novo review of the facts and circumstances
under which the investigator interviewed Gideon, we conclude that
Gideon’s belief that a refusal to answer truthfully questions posed by the
medical-board investigator could lead to the loss of his medical license was
not objectively reasonable. We find, therefore, that Gideon has failed to
satisfy the legal standard established in Graham. Id. at ¶ 24.
Standard on Appeal
{¶ 44} Appellate review of a Crim.R. 12(C)(3) motion to suppress presents mixed
questions of law and fact. State v. Burnside, 100 Ohio St.3d 152, 2003-Ohio-5372, 797
N.E.2d 71, ¶ 8. When the trial court decides a motion to suppress, it assumes the role of
trier of fact and is in the best position to resolve questions of fact and to assess witness
credibility. Id. A reviewing court is bound to accept the trial court’s findings of fact if
they are supported by competent, credible evidence. Burnside at ¶ 8. An appellate court
must then independently decide as a matter of law whether the trial court’s conclusions
satisfy the appropriate legal standard. Id.
17. Analysis
{¶ 45} Upon review, we find the trial court did not err in denying Haas’s motion to
suppress. Our examination of the record, including the Agreement, the Code and the
witness testimony from the suppression hearing, supports a conclusion that the trial
court’s findings of fact are based on competent, credible evidence. The trial court found
there was no express threat of discharge, and the evidence supports this finding. Haas
was not advised that she would face termination if she refused to answer her supervisors
or law enforcement’s questions or failed to cooperate with them, nor did the Agreement
or the Code state that an employee would be fired if the employee failed to cooperate
with an investigation or declined to answer questions.
{¶ 46} Having accepted the trial court’s facts as true, we apply the Graham test to
determine whether Haas subjectively believed her statements were compelled on threat of
discharge, and whether this belief was objectively reasonable such that Haas’s statements
should be suppressed under Garrity.
{¶ 47} Upon review, we find Haas did not demonstrate, through evidence, that any
coercion occurred. While Haas asserted the Agreement and the Code “especially in light
of Clymer’s testimony” should suffice to establish that she had a subjective belief that she
could be terminated, we find none of the forgoing provides sufficient proof that Haas
subjectively believed she could be fired for refusing to cooperate with her supervisors
and law enforcement. We note the Code states that “violations of this policy will be
18. reviewed on a case-by-case basis and may result in disciplinary action up to and
including removal,” but neither the Agreement nor the Code mentions or alludes to the
subjects of investigations, questioning, cooperating or refusing to cooperate. Contra
Graham at ¶ 27 (“[a]lthough appellants did not testify at the suppression hearing, the
threat of discharge contained in the notice was sufficient proof that they subjectively
believed they could be fired for refusing to cooperate”).
{¶ 48} We further find Clymer’s testimony does not lend support to or reinforce
Haas’s assertion that she had a subjective belief that she could be fired for refusing to
cooperate. Clymer testified that “[w]e asked her [Haas] about, I was not even made
aware by her that she had an open investigation. So we asked, you know, why she didn’t
say anything, why she didn’t tell us? And she said she was afraid that she would be fired.
And that she knew it wasn’t true because she knew who -that it wasn’t even reported by
the school.” Clymer’s testimony, that Haas was afraid she would be fired, referred to
Haas having an open investigation with children’s services, not Haas refusing to
cooperate or answer questions regarding improperly accessing the state system.
{¶ 49} Upon review of the totality of the circumstances, we find no evidence that
Haas’s belief that her statements were compelled on threat of job loss was objectively
reasonable. The Agreement sets forth that violations of confidentiality must be reported
to a leader and the Code provides that violations must be reported to a supervisor. We
find these documents are not sufficient to support an objectively reasonable expectation
19. of discharge, as the clauses do not intimate that an employee would be disciplined or
removed if the employee did not cooperate with an investigation or answer questions.
Moreover, there is no witness testimony sufficient to support an objectively reasonable
expectation of discharge, as no witness testified that Haas was told she would be
reprimanded or fired if she refused to cooperate. Since the circumstances show no
demonstrable coercive action by the state, we conclude Haas’s statements were not
compelled under Garrity. Accordingly, Haas’s assignment of error is not well-taken.
{¶ 50} The judgment of the Fulton County Court of Common Pleas is affirmed.
Appellant, Shannon Haas, is ordered to pay the costs of this appeal pursuant to App.R.
24.
Judgment affirmed.
A certified copy of this entry shall constitute the mandate pursuant to App.R. 27. See also 6th Dist.Loc.App.R. 4.
Christine E. Mayle, J. ____________________________ JUDGE Gene A. Zmuda, P.J. ____________________________ Myron C. Duhart, J. JUDGE CONCUR. ____________________________ JUDGE
This decision is subject to further editing by the Supreme Court of Ohio’s Reporter of Decisions. Parties interested in viewing the final reported version are advised to visit the Ohio Supreme Court’s web site at: http://www.supremecourt.ohio.gov/ROD/docs/.
20.