Can a Texas city let charities solicit donations from drivers in the roadway while banning other roadside solicitation?

Plain-English summary

Texas has long had a law that bars people from standing in a roadway to solicit a ride, contributions, employment, or business from the occupants of vehicles. In 1989 the Legislature carved out one exception: a person may stand in a roadway to solicit charitable contributions if a local authority with jurisdiction over the road authorizes it. That is the legal basis for the familiar "fill the boot" style fundraising at intersections. Representative Fred Hill, chair of the House Committee on Urban Affairs, asked the Attorney General whether that exception is unconstitutional, because it allows one kind of roadside solicitation (charity) while banning others.

The Attorney General's answer turned on a single feature of the law: it sorts solicitation by its subject. Solicitation for a charity is allowed (if locally permitted); solicitation for anything else is banned. Under the First Amendment, a rule that allows or forbids speech based on what the speech is about is "content-based." Streets are a traditional public forum, where content-based restrictions face the most demanding review. The office concluded the exception is content-based as a matter of law, so it cannot be defended as a neutral "time, place, and manner" rule (the kind of rule that regulates speech without regard to its message, such as a flat ban on standing in traffic lanes).

That left only one way the law could be valid: it had to satisfy strict scrutiny, meaning the discrimination against all non-charitable solicitation had to be narrowly drawn and necessary to serve a compelling state interest. Here the office stopped. Whether the charitable exception is narrowly drawn and necessary to a compelling interest depends on facts, for example, evidence about traffic safety and whether a narrower rule would serve the State's interest. The Attorney General is not authorized to decide fact questions in an opinion, so the office did not declare the statute unconstitutional. It held only that the exception is a content-based restriction that is invalid unless it survives strict scrutiny, and that resolving that question is for a court with a factual record.

The office was careful about what it was not deciding. It did not question the general prohibition on roadway solicitation itself (it assumed that ban was valid), and it noted that federal and Texas courts had upheld flat, content-neutral bans on roadway solicitation as valid place restrictions in cases like the Krishna Consciousness case, ACORN v. City of Phoenix, and (on overbreadth) the Houston Chronicle newspaper-sales case.

Currency note

This opinion was issued in 1995. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

This opinion analyzed a 1989 amendment that had just been recodified, without substantive change, from V.T.C.S. article 6701d, section 81(c) into Transportation Code section 552.007 (effective September 1, 1995). The statute and the First Amendment case law governing content-based speech restrictions have developed since 1995. Read this page for the office's 1995 reasoning, and check the current text of Transportation Code section 552.007 and current Supreme Court doctrine before relying on any specific rule here.

What the opinion meant at the time

For legislators and the Legislature: The opinion told the requesting committee that the charitable-solicitation exception was constitutionally vulnerable because it singled out speech by subject matter. It signaled that a content-based carve-out would have to survive strict scrutiny, and that a content-neutral approach (such as the flat bans courts had upheld in the Krishna and ACORN cases) rested on firmer ground.

For cities and local authorities issuing roadway permits: At the time, the opinion meant that a local government acting under the 1989 amendment to permit charitable solicitation was operating under a statute the office viewed as content-based and therefore subject to strict scrutiny. The office did not tell local authorities the law was void; it identified the constitutional standard the exception would have to meet if challenged.

For charities and other groups that solicit at intersections: The opinion treated charitable roadway solicitation as protected speech, but it placed the charitable exception's validity in doubt by classifying it as content-based. It did not resolve whether the exception was enforceable; that depended on a court's factual findings about safety and tailoring.

For courts: The office framed the unresolved question for judicial decision: whether the discrimination in favor of charitable solicitation is narrowly drawn and necessary to serve a compelling state interest, a determination the office said requires the kind of fact-finding an AG opinion cannot perform.

Common questions

Why is letting only charities solicit in the roadway a constitutional problem?
Because the line is drawn by the subject of the speech. The law permits soliciting for charity but bans soliciting for a ride, employment, business, or other contributions. The office concluded that a rule allowing speech based on what it is about is content-based under the First Amendment, and streets are a traditional public forum where content-based rules get the most exacting review.

Did the Attorney General say the law is unconstitutional?
No. The office concluded the exception is content-based and so cannot be saved as a neutral time, place, and manner rule, but it expressly declined to decide whether the law is unconstitutional. That final question turns on whether the exception is narrowly drawn and necessary to a compelling state interest, which depends on facts an AG opinion is not authorized to resolve.

Is a flat ban on standing in the road to solicit money also unconstitutional?
The office did not question the general prohibition and assumed it was valid. It noted that courts had upheld content-neutral bans on roadway solicitation as reasonable place restrictions, citing the Krishna Consciousness case from the Fifth Circuit and ACORN v. City of Phoenix from the Ninth Circuit, both grounded in traffic-safety findings.

What is the difference between a "content-neutral" rule and a "content-based" rule here?
A content-neutral rule regulates the time, place, or manner of speech without regard to its message (for example, no one may stand in a traffic lane to solicit anyone). A content-based rule turns on the message itself (charitable solicitation is allowed, other solicitation is not). The office held the 1989 exception was content-based because it described permissible solicitation by its subject, charitable contributions.

Does panhandling or begging get First Amendment protection under this analysis?
The opinion treated solicitation of funds, including begging, as protected expression, quoting the Second Circuit's decision in Loper v. New York City Police Department that even a person holding out a hand or cup conveys a message of need. The point in the opinion was that solicitation is speech, which is why a subject-based distinction among solicitations raises First Amendment concerns.

Background and statutory framework

Before 1989, V.T.C.S. article 6701d, section 81(c) flatly prohibited standing in a roadway to solicit "a ride, contributions, employment or business from the occupant of any vehicle." The 1989 amendment (Act of May 18, 1989, 71st Leg., R.S., ch. 342) added an exception allowing a person to stand in a roadway to solicit charitable contributions if authorized by the local authority with jurisdiction over the roadway, and it tied the definition of charitable organizations to the federal Internal Revenue Service standards (see 26 U.S.C. § 170(c)). When the opinion issued, the provision had just been recodified, without substantive change, as Transportation Code section 552.007(a) (with the charitable-contribution definition at section 552.007(c)), effective September 1, 1995.

The constitutional framework the office applied comes from the public-forum line of First Amendment cases. Streets are a quintessential public forum (United States v. Grace; Hague v. CIO). In such a forum, government may impose content-neutral time, place, and manner restrictions that are narrowly tailored to serve a significant interest and leave open ample alternative channels (Perry Education Ass'n v. Perry Local Educators' Ass'n), but a content-based exclusion must be necessary to serve a compelling state interest and narrowly drawn to achieve it (Perry; Cornelius v. NAACP Legal Defense & Educational Fund, Inc.). The office noted the equal-protection standard for discrimination among speech-related activities in a public forum mirrors that strict standard (Carey v. Brown; Dunn v. Blumstein).

Applying those standards, the office held the 1989 exception failed the content-neutrality prong as a matter of law because it describes permissible solicitation by its subject (charitable contributions). It reasoned that the only justification for the charitable exception, that the benefit of collecting charitable funds outweighs the traffic risk, rests on the value of the message rather than on any content-neutral secondary effects, comparing City of Renton v. Playtime Theatres, Inc. (the secondary-effects doctrine for adult-theater zoning). Because the exception is content-based, the office turned to strict scrutiny and concluded that whether the law is narrowly drawn and necessary to a compelling interest involves questions of fact it could not decide in an opinion. The office assumed, without deciding, that the general prohibition on roadway solicitation was valid, citing decisions upholding content-neutral roadway-solicitation bans (the Krishna Consciousness case and ACORN v. City of Phoenix) and one striking a newspaper-sales ban as overbroad (Houston Chronicle Publishing Co. v. City of Houston).

Citations

Statutes and authorities discussed:

• V.T.C.S. article 6701d, § 81(c) (former roadway-solicitation prohibition; 1989 amendment adding the charitable exception)
• Transportation Code § 552.007(a) (recodified prohibition and charitable exception); § 552.007(c) (definition of charitable contribution)
• 26 U.S.C. § 170(c) (federal definition of charitable contribution)

Key cases discussed:

• Village of Schaumburg v. Citizens for a Better Environment, 444 U.S. 620 (1980) (solicitation of funds is protected speech)
• Perry Education Ass'n v. Perry Local Educators' Ass'n, 460 U.S. 37 (1983) (public-forum standards for time, place, and manner versus content-based restrictions)
• Cornelius v. NAACP Legal Defense & Educational Fund, Inc., 473 U.S. 788 (1985) (compelling-interest standard for content-based exclusions)
• Carey v. Brown, 447 U.S. 455 (1980) (equal-protection scrutiny of speech discrimination in a public forum)
• City of Renton v. Playtime Theatres, Inc., 475 U.S. 41 (1986) (content-neutrality and secondary effects)
• ACORN v. City of Phoenix, 798 F.2d 1260 (9th Cir. 1986); International Society for Krishna Consciousness of New Orleans, Inc. v. City of Baton Rouge, 876 F.2d 494 (5th Cir. 1989) (content-neutral roadway-solicitation bans upheld)
• Loper v. New York City Police Department, 999 F.2d 699 (2d Cir. 1993) (begging is protected expression)
• Valenzuela v. Aquino, 853 S.W.2d 512 (Tex. 1993); Houston Chronicle Publishing Co. v. City of Houston, 620 S.W.2d 833 (Tex. Civ. App.-Houston [14th Dist.] 1981, no writ)

Source

• Landing page: https://www.texasattorneygeneral.gov/opinions/dan-morales/dm-0367
• Original PDF: https://www.texasattorneygeneral.gov/sites/default/files/opinion-files/opinion/1995/dm0367.pdf

Original opinion text

Best-effort transcription from a scanned PDF. Minor errors may remain (including footnote numbering) — the linked PDF is authoritative.

Office of the Attorney General
State of Texas

DAN MORALES
ATTORNEY GENERAL

December 4, 1995

The Honorable Fred Hill
Chair
Committee on Urban Affairs
Texas House of Representatives
P.O. Box 2910
Austin, Texas 78768-2910

Opinion No. DM-367

Re: Constitutionality of the statute that permits local authorities to authorize persons to stand in roadways to solicit certain charitable contributions but not other contributions (RQ-794)

Dear Representative Hill:

You ask whether the 1989 amendment to what then was section 81(c) of V.T.C.S. article 6701d and now is Transportation Code section 552.007(a)[1] (the "1989 amendment" or the "amendment") is unconstitutional. See Act of May 18, 1989, 71st Leg., R.S., ch. 342, 1989 Tex. Gen. Laws 1310. You wish to know specifically whether a local regulation or permit authorizing a person, pursuant to the 1989 amendment, to stand in a roadway to solicit certain charitable contributions would violate free speech or equal protection guarantees by permitting certain expressive conduct based on its content while the statute prohibits other similar expressive conduct.

Before the amendment of section 81(c) in 1989, see id., the provision prohibited all solicitation of contributions as follows: "No person shall stand in a roadway for the purpose of soliciting a ride, contributions, employment or business from the occupant of any vehicle." V.T.C.S. art. 6701d, § 81(c) (Vernon 1977). The 1989 amendment changed section 81(c) as follows: "A [No] person may not [shall] stand in a roadway for the purpose of soliciting a ride, contributions, employment or business from the occupant of any vehicle, except that a person may stand in a roadway to solicit charitable contributions if authorized to do so by the local authority having jurisdiction over the roadway." Act of May 18, 1989, 71st Leg., R.S., ch. 342, § 1, 1989 Tex. Gen. Laws 1310, 1310 (additions italicized; deletions struck over and bracketed). The amendment also provided that "[t]he definition of charitable organizations shall meet those established by the federal Internal Revenue Service." Id. § 2(c)[2]; see 26 U.S.C. § 170(c) (defining charitable contribution). The 1989 amendment thus permits certain charitable solicitations if they are authorized by the local authority.

For the following reasons, we are of the opinion that the amendment is not valid under the First and Fourteenth Amendments of the Constitution unless the amendment's discrimination against all other solicitation is narrowly drawn and necessary to serve a compelling state interest. Because this determination involves questions of fact, we are unable to decide in an attorney general opinion whether the statute is unconstitutional.

The First Amendment's free speech guarantee protects solicitation of funds. E.g., Village of Schaumburg v. Citizens for a Better Environment, 444 U.S. 620, 629 (1980).[3] Even begging or panhandling is sufficiently communicative to warrant First Amendment protection:

Begging frequently is accompanied by speech indicating the need for food, shelter, clothing, medical care or transportation. Even without particularized speech, however, the presence of an unkempt and disheveled person holding out his or her hand or a cup to receive a donation itself conveys a message of need for support and assistance. We see little difference between those who solicit for organized charities and those who solicit for themselves in regard to the message conveyed. The former are communicating the needs of others while the latter are communicating their personal needs. Both solicit the charity of others. The distinction is not a significant one for First Amendment purposes.

Loper v. New York City Police Dep't, 999 F.2d 699, 704 (2d Cir. 1993) (citation omitted).

Protected speech is subject, however, to a government's "power to preserve the property under its control for the use to which it is lawfully dedicated." Greer v. Spock, 424 U.S. 828, 836 (1976). The permissible extent of governmental regulation of access to its property for speech purposes varies depending on the nature of the forum. Cornelius v. NAACP Legal Defense & Educ. Fund, Inc., 473 U.S. 788, 800 (1985).

The Supreme Court has developed three categories to analyze expressive conduct in varying public forums, namely: 1) the traditional public forum; 2) the quasi-public forum; and 3) the non-public forum. Traditional public forums include those places historically devoted to assembly and debate; quasi-public forums consist of places the state has designated for open public discourse. A state may regulate expressive conduct occurring in either of these forums if the state demonstrates a compelling interest or implements a valid time, place, and manner restriction. The third category involves non-public forums, such as municipal buses or military bases, within which the state may regulate expressive conduct if the regulation is rationally based and content neutral.

Valenzuela v. Aquino, 853 S.W.2d 512, 516-17 (Tex. 1993) (Gonzalez, J., dissenting) (citations omitted).

It is settled law that streets are traditional public forums. E.g., United States v. Grace, 461 U.S. 171, 177 (1983). A governmental authority has the responsibility to impose nondiscriminatory restrictions necessary to promote movement on streets, and such restrictions "cannot be disregarded by the attempted exercise of some civil right which, in other circumstances, would be entitled to protection." Cox v. Louisiana, 379 U.S. 536, 554-55 (1965). The Supreme Court has set forth the constitutional standards applicable to regulation of speech in streets and parks as follows:

In places which by long tradition or by government fiat have been devoted to assembly and debate, the rights of the state to limit expressive activity are sharply circumscribed. At one end of the spectrum are streets and parks which "have immemorially been held in trust for the use of the public and, time out of mind, have been used for purposes of assembly, communicating thoughts between citizens, and discussing public questions." In these quintessential public forums, the government may not prohibit all communicative activity. For the state to enforce a content-based exclusion it must show that its regulation is necessary to serve a compelling state interest and that it is narrowly drawn to achieve that end. The state may also enforce regulations of the time, place, and manner of expression which are content-neutral, are narrowly tailored to serve a significant government interest, and leave open ample alternative channels of communication.

Perry Educ. Ass'n v. Perry Local Educators' Ass'n, 460 U.S. 37, 45 (1983) (quoting Hague v. CIO, 307 U.S. 496, 515 (1939)) (citations omitted).

The first standard quoted above from Perry, the one applicable to content-based exclusions, appears to be essentially the same as the standard applicable under the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court held in Carey v. Brown, 447 U.S. 455, 461-62 (1980): "When government regulation discriminates among speech-related activities in a public forum, the Equal Protection Clause mandates that the legislation be finely tailored to serve substantial state interests, and the justifications offered for any distinctions it draws must be carefully scrutinized." If the State classifies persons in a manner that discriminatorily affects their exercise of fundamental rights, it must show a compelling interest to justify the classification. See Dunn v. Blumstein, 405 U.S. 330, 335-36 (1972). Free speech rights are fundamental; therefore the compelling-interest test applies to classifications based on speech. City of Angeles Mission Church v. City of Houston, 716 F. Supp. 982, 986 (S.D. Tex. 1989); Houston Chronicle Publishing Co. v. City of Houston, 620 S.W.2d 833, 838 (Tex. Civ. App.-Houston [14th Dist.] 1981, no writ). To pass muster under the Equal Protection Clause, the State must also show that the classification is necessary to promote the compelling interest. City of Angeles Mission Church, 716 F. Supp. at 986; Houston Chronicle Publishing Co., 620 S.W.2d at 838; see Dunn, 405 U.S. at 337.

With these principles in mind, we now proceed to analyze the amendment's exception of certain charitable contributions from its general prohibition against solicitation of contributions.[4] Transportation Code section 552.007(a) restricts both the place ("in a roadway") and the manner ("from the occupant of any vehicle") of speech. Therefore, the contribution-solicitation portion of section 552.007(a) can be valid only if it passes one of two tests: (1) it is "content-neutral, [is] narrowly tailored to serve a significant government interest, and leave[s] open ample alternative channels of communication," Perry Educ. Ass'n, 460 U.S. at 45 (collecting authorities), or (2) it "is necessary to serve a compelling State interest and . . . is narrowly drawn to achieve that interest," Cornelius, 473 U.S. at 800; Perry Educ. Ass'n, 460 U.S. at 45.

For purposes of the first test, "content-neutral" speech restrictions are "those that 'are justified without reference to the content of the regulated speech.' Virginia Pharmacy Bd. v. Virginia Citizens Consumer Council, Inc., 425 U.S. 748, 771, 96 S. Ct. 1817, 1830, 48 L. Ed. 2d 346 (1976) (emphasis added)." City of Renton v. Playtime Theatres, Inc., 475 U.S. 41, 48 (1986). Thus, for example, an ordinance that prohibits adult movie theaters from locating within a certain distance from homes, churches, parks, or schools may pass muster if the restriction is aimed at preventing crime, protecting retail business, maintaining property values, and dealing with other secondary effects of the theaters rather than suppressing the showing of adult movies because they are controversial or objectionable. See id.

We believe the 1989 amendment fails the first test as a matter of law because it is content-based. The amendment describes permissible solicitation in terms of the subject of the solicitation, that is, charitable contributions. Furthermore, although the question of content-neutrality will usually involve factual analysis, we believe that the discrimination between charitable solicitation and other solicitation simply cannot be justified under any set of facts without reference to the content of the solicitation. Generally, solicitation of contributions from vehicle occupants poses substantial traffic safety concerns:

Unlike oral advocacy of ideas, or even the distribution of literature, successful solicitation requires the individual to respond by searching for currency and passing it along to the solicitor. Even after the solicitor has departed, the driver must secure any change returned, replace a wallet or close a purse, and then return proper attention to the full responsibilities of a motor vehicle driver. The direct personal solicitation from drivers distracts them from their primary duty to watch the traffic and potential hazards in the road, observe all traffic control signals or warnings, and prepare to move through the intersection.

ACORN v. City of Phoenix, 798 F.2d 1260, 1269 (9th Cir. 1986). These concerns are no less substantial when the solicited contribution is intended for a qualified charitable organization under section 552.007(a). The only justification for the exception for charitable contributions—that the benefit accruing from collection of charitable funds outweighs the risk of harm from allowing solicitors to stand in traffic lanes—is based on the primary impact of the solicitation, not on any relatively more adverse secondary effects of other solicitation. Put another way, such a justification is based on impermissible discrimination between subjects of speech based on perceived differences in the value of the messages themselves. Because the 1989 amendment fails the content-neutrality prong of the test for time, place, and manner restrictions, we need not consider the other two prongs of the first test: whether the restriction is narrowly tailored to serve a significant government interest and leaves open ample alternative channels of communication.

We therefore now consider whether the 1989 amendment passes the second test set forth above. As a content-based prohibition on solicitation, the amendment must be narrowly drawn and necessary to achieve a compelling state interest. See Perry Educ. Ass'n, 460 U.S. at 46; Widmar v. Vincent, 454 U.S. 263, 269-70 (1981); Dunn, 405 U.S. at 337; City of Angeles Mission Church, 716 F. Supp. at 986. The Supreme Court has engaged in "the most exacting scrutiny in cases in which a State undertakes to regulate speech on the basis of its content." Widmar, 454 U.S. at 276. Questions of fact are integral to the determination of the necessity of this discriminatory prohibition to achieve a compelling interest and of its tailoring in achieving that interest. Because we are not authorized to determine questions of fact in an attorney general opinion, we may not decide whether the amendment passes the second test of its constitutionality.

SUMMARY

The 1989 amendment to what then was section 81(c) of V.T.C.S. article 6701d and now is Transportation Code section 552.007(a) (the "amendment"), which amendment permits local authorities to authorize persons to stand in roadways to solicit certain charitable contributions but prohibits solicitation of other contributions, Act of May 18, 1989, 71st Leg., R.S., ch. 342, 1989 Tex. Gen. Laws 1310, establishes a content-based speech restriction. The amendment therefore is not valid under the First and Fourteenth Amendments of the Constitution unless the provision's discrimination against all solicitation other than certain charitable solicitation is narrowly drawn and necessary to serve a compelling state interest.

DAN MORALES
Attorney General of Texas

JORGE VEGA
First Assistant Attorney General

SARAH J. SHIRLEY
Chair, Opinion Committee

Prepared by James B. Pinson
Assistant Attorney General

Footnotes:

[1] The Seventy-fourth Legislature has recodified section 81(c) as section 552.007(a) of the new Transportation Code. See Act of May 1, 1995, 74th Leg., R.S., ch. 165, sec. 1, § 552.007(a), 1995 Tex. Sess. Law Serv. 1025, 1698. The legislature intended no substantive change in the law by the enactment of the Transportation Code. Id. § 25, at 1871. The Transportation Code became effective on September 1, 1995. Id. § 27, at 1871.

[2] The Seventy-fourth Legislature has codified section 2(c) as Transportation Code section 552.007(c), which now reads as follows: "In this section, 'charitable contribution' means a contribution to an organization defined as charitable by the standards of the United States Internal Revenue Service." See sec. 1, § 552.007(c), at 1698.

[3] In Village of Schaumburg, Justice White wrote for the Court as follows regarding the expressive characteristics of solicitation of money:

Soliciting financial support is undoubtedly subject to reasonable regulation but the latter must be undertaken with due regard for the reality that solicitation is characteristically intertwined with informative and perhaps persuasive speech seeking support for particular causes or for particular views on economic, political, or social issues, and for the reality that without solicitation the flow of such information and advocacy would likely cease. Canvassers in such contexts are necessarily more than solicitors for money.

444 U.S. 620, 632 (1980).

[4] You do not question, and we do not consider, the constitutionality of the general prohibition of section 552.007(a) against standing in a roadway to "solicit[] a ride, contributions, employment or business from the occupant of any vehicle." We assume for purposes of your request that the prohibition is constitutionally valid. We note that the following cases deal with similar prohibitions:

In International Society for Krishna Consciousness of New Orleans, Inc. v. City of Baton Rouge, 876 F.2d 494 (5th Cir. 1989), the court upheld, as a valid place restriction under the First Amendment, a city and parish ordinance that completely banned solicitation of employment, business, or charitable contributions from occupants of vehicles by persons on streets or roadways or on shoulders or neutral grounds of streets or roadways. Disagreeing with the argument that the ordinance was not narrowly tailored because it applied to all streets and roadways without regard to traffic speed, width of neutral ground, or presence of stop signals, the court found that the evidence supported the trial court's finding that there was no way to make solicitation safe on any street or roadway. Id. at 498.

Likewise, in ACORN v. City of Phoenix, 798 F.2d 1260 (9th Cir. 1986), the court upheld, as a valid place restriction, a Phoenix ordinance that prohibited standing on a street or highway and soliciting employment, business, or contributions from vehicle occupants. The court concluded that the ordinance was narrowly tailored based on the trial court's finding that the cramping on the roadways of persons soliciting contributions and distributing literature posed a safety hazard. Id. at 1270. Although the city's evidence did not directly rebut all of ACORN's evidence that purportedly showed many specific intersections where solicitation could occur safely, the court found support in the record for the trial court's finding based on testimony that solicitation generally posed a traffic hazard. Id. at 1269-70.

Compare Houston Chronicle Publishing Co. v. City of Houston, 620 S.W.2d 833 (Tex. Civ. App.-Houston [14th Dist.] 1981, no writ), in which the court concluded that a Houston ordinance that banned sale of newspapers to occupants of vehicles located in a roadway or on any other public property was unconstitutionally overbroad under the First Amendment because it applied to all "motor vehicles located on public property, including residential neighborhoods regardless of the time of day or night and regardless of whether the cars are moving, standing, parked or even not in the traffic lanes." Id. at 837.