Do Social Workers Have a Duty to Report Alleged Illegal Activity?

Written by Haley A. Lingelbach, Lawyer at McKercher LLP*

*DISCLAIMER: This article is not to be construed as legal advice. For more information on this topic, please contact the Executive Director of the Saskatchewan Association of Social Workers. For a legal opinion on the applicability of the above principles to a specific set of facts or circumstances, please contact a lawyer.

Introduction

 

The Saskatchewan Association of Social Workers (“ SASW”) has received questions from several of its members about what the duty of a social worker is when a client has divulged information to him or her about alleged illegal activity. Various situations that social workers claim they have found themselves in include the following:

 

• A social worker who works in mental health has a client who has said he or she did “something really bad” some time ago and is tortured by it.
• A social worker has a client who disclosed he or she killed someone in a hit and run.
• A social worker has a client who revealed that he or she is selling stolen property.

 

This article discusses the duties that social workers may have when information, such as that described above, is disclosed to them by their clients in the course of their jobs. More specifically, the questions addressed in this article are as follows:

 

1. When is a social worker legally required to provide information about his or her client to the police?
2. When a client tells a social worker about alleged illegal activity, should the social worker contact the police?
3. If a client tells a social worker about alleged illegal activity and the social worker does not report it to the police, will the social worker in some way be faced with criminal consequences?
4. What steps should a social worker take when faced with an ethical dilemma regarding disclosure of alleged illegal activity?

 

 

Brief Summary of the Article’s Conclusions

 

There is a duty imposed on social workers to report confidential information shared by their clients (1) when a child is in need of protection, or (2) when it is necessary to prevent serious, foreseeable, and imminent harm. There is no duty imposed on social workers to report when a client discloses alleged illegal activity that has already taken place.

A social worker should not contact the police simply because a client has told him or her about alleged illegal activity previously committed by the client. This principle stems from (1) the fact that there is no duty to report when a client discloses alleged illegal activity that has already taken place, and (2) the fact that social workers must abide by their duty of confidentiality.

A social worker who merely obtains information from a client that illegal activity has occurred in the past and fails to disclose the information likely will not be charged under the Criminal Code. However, if the social worker somehow aids, abets, or counsels the client into committing illegal activity, assists in such a way that makes him or her an accessory after the fact, or otherwise acts offside the Criminal Code, the social worker may find himself or herself being charged criminally. Whether such charges are appropriate will depend on the individual facts of each case.

A list of suggested steps to take when a social worker finds himself or herself facing an ethical dilemma regarding disclosure of alleged illegal activity by a client is provided towards the end of this article.

 

 

Discussion and Analysis

 

The documents that specifically govern social workers in Saskatchewan and their duties are listed below:

 

• The Social Workers Act (Saskatchewan) [1]
• The SASW General Bylaws [2] and The SASW Administrative Bylaws [3] (collectively, the “ SASW Bylaws”)
• The SASW Standards of Practice for Registered Social Workers in Saskatchewan [4]
• The Canadian Association of Social Workers (“ CASW”) Code of Ethics [5]
• The CASW Guidelines for Ethical Practice [6]

 

These documents, among others, have been reviewed and discussed in the research that follows below.

• (1) When is a Social Worker Legally Required to Provide Information About His or Her Client to the Police?

The following section of this article discusses situations where there is and is not a duty imposed on social workers to report/disclose certain information to the police.

---------------------------

[1] SS 1993, c S-52.1 [SWA].

[1] The Saskatchewan Association of Social Workers – General Bylaws (2017), online: .

[1] The Social Workers Administrative By-laws (2018), online: .

[1] The Saskatchewan Association of Social Workers Standards of Practice for Registered Social Workers in Saskatchewan (2017), online: [SASW Standards].

[1] The Canadian Association of Social Workers Code of Ethics (2005), online: [CASW Code].

[1] The Canadian Association of Social Workers Guidelines for Ethical Practice (2005), online: [CASW Guidelines].

• (a) There is a Duty to Report When a Child is in Need of Protection or When it is Necessary to Prevent Serious, Foreseeable, and Imminent Harm

There are various instances where a social worker is required to provide information about his or her client to the police, including the following circumstances:

 

1. where a social worker has reasonable grounds to believe that a child is in need of protection; [7] and
2. where a social worker has “reason to believe” [8] that “disclosure [of a client’s confidential information] is necessary to prevent serious, foreseeable, and imminent harm to a client or others”. [9]

 

The SASW has advised that social workers are typically clear about breaking confidentiality when exercising their duties under the two sets of circumstances above. However, whether a duty is imposed on social workers in circumstances where a client informs the social worker about alleged illegal activity that has already taken place is not as clear. The remainder of this article attempts to address this latter issue.

 

 

• (b) There is No Duty to Report When a Client Discloses Alleged Illegal Activity that has Already Taken Place

 

The SWA, SASW Bylaws, SASW Standards, CASW Code, and CASW Guidelines are all silent as to whether social workers have a duty to report alleged criminal activity that has already taken place to the police.

 

However, we have some guidance about whether such information must be reported to the police, located in The Health Information Protection Regulations [10] . The HIPR, which have application to social workers [11] , provide the following circumstances when “trustees” are required to provide confidential information to the police:

 

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[1] The Child and Family Services Act, SS 1989-90, c C-7.2 at s 12(1) [CFSA].

[1] CASW Guidelines, supra note 6 at s 1.6.2.

[1] CASW Guidelines, ibid at s 1.5.

[1] RRS c H-0.021 Reg 1 [HIPR].

[1] See the definition of “trustee” under section 2(t)(xii)(A) of The Health Information Protection Act, SS 1999, c H-0.021 [HIPA].

To summarize, there is no obligation under the HIPR for a social worker to report information about alleged criminal activity that has already occurred to the police. However, a social worker may disclose personal health information where the police request information from a social worker in conducting an investigation under the Criminal Code (Canada) [12] or the Controlled Drugs and Substances Act (Canada) [13] . Since section 5.1(1) of the HIPR states that “personal health information may be disclosed” (emphasis added), it is suggested that there is a discretionary element present that allows the social worker to exercise some judgment in whether he or she will disclose information about a client in such circumstances.

 

Therefore, where a police officer does not request information relating to a social worker’s client from a social worker during an investigation, it appears that the social worker does not have a duty to disclose/report information about the client that was provided by the client to the social worker. Nevertheless, if a police officer does request information, it is arguable that the social worker will be permitted to exercise discretion in whether he or she will disclose such information, at least under the HIPR.

 

 

• (2) When a Client Tells a Social Worker About Alleged Illegal Activity, Should the Social Worker Contact the Police?

 

Unless a police officer requests information from a social worker about a client that pertains to an investigation (as described above), the social worker should not disclose information about the client to the police. This principle stems from the duty of confidentiality that social workers must abide by.

The definition of confidential information includes any “information obtained by a social worker in the context of a professional relationship or in other circumstances when there was a reasonable expectation by the client that a social worker would not disclose that information”. [14] This definition is quite broad, and therefore, it would likely encompass information that a client discloses to a social worker about alleged illegal activity committed by the client in the past.

 

The duty of confidentiality imposed on social workers is outlined in the SASW Standards [15] , the CASW Code [16] , and the CASW Guidelines [17] . This duty requires social workers to refrain from disclosing confidential information about the client unless required to do so by law. Since it was established above that social workers are not required to disclose information to police unless the information is requested by an officer for an investigation—and even then, the social worker is permitted to exercise his or her discretion—social workers should not contact the police simply because a client has told him or her about alleged illegal activity committed by the client.

 

Notwithstanding the above, social workers should disclose information to the police where they would otherwise be charged with a criminal offence. A discussion of this point can be found in the next section of this article.

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[1] RSC 1985, c C-46 [Criminal Code].

[1] SC 1996, c 19.

[1] SASW Standards, supra note 4 at clause B(c).

[1] Ibid at clause D.1.

[1] Supra note 5 at 7-8 and 10.

[1] Supra note 6 at s 1.4, 1.5, and 6.3.

• (3) If a Client Tells a Social Worker About Alleged Illegal Activity and the Social Worker Does Not Report it to the Police, will the Social Worker in Some Way Be Faced with Criminal Consequences?

 

There are various provisions under the Criminal Code where it is possible that a person may be found guilty of an offence for failing to report a crime. These provisions, along with the likely applicability to social workers, are discussed below. 

 

 

• (a) Aiding and Abetting an Offence

 

• (i) The Law

 

Under the Criminal Code, a person may be charged criminally if he or she aids or abets another person to commit a crime. [18] The relevant provisions are reproduced below for reference:

 

 

After searching for cases that cite the above provisions in the context of social workers, it became apparent that there has been little to no discussion in the case law of a duty on social workers to report crimes they have been told about. Nevertheless, the portions of the above that could possibly apply to the instance of failing to report a crime would be section 21(1)(b) (i.e., aiding) and section 21(1)(c) (i.e., abetting).

 

To aid an offence means exactly what it sounds like; a social worker assists the client in committing a crime. In order to be convicted for aiding an offence, a social worker must act or omit to act for the purpose of aiding the client to commit an offence. [19] In other words, if the social worker acted or omitted to act, but he or she did not intend to aid the client to commit the offence, the social worker will not be found guilty of aiding in the commission of the offence even if the act or omission had the effect of aiding the client. [20] To intend to aid in committing the offence means that the social worker either (1) knew that the act or omission would aid in the commission of the offence, or (2) was wilfully blind to the fact that the act or omission would aid in the commission of the offence (e.g., the signs were present, but the social worker chose to ignore them and/or refrain from inquiring further). [21]

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[1] Supra note 12 at s 21(1)(b) and (c). See also s 241(1) regarding aiding or abetting a person to commit suicide.

[1] Edward L. Greenspan, Q.C., Marc Rosenberg, and Marie Henein, Martin’s Annual Criminal Code 2019, (Toronto: Thomson Reuters, 2018) at 70 [Martin’s].

[1] Martin’s, ibid at 70.

To abet an offence means that the social worker assists, instigates, promotes, or procures the client to commit an offence. [22] Similarly to aiding, in order to be convicted for abetting an offence, a social worker must encourage, etc. the client with the intent to abet the client to commit an offence. [23] To intend to abet the offence means that the social worker either (1) knew that the abetting would encourage the client to commit the offence, or (2) was wilfully blind to the fact that the abetting would encourage the client to commit the offence (e.g., the signs were present, but the social worker chose to ignore them and/or refrain from inquiring further). [24]

 

The following comments address some of the situations a social worker might find himself or herself in that could trigger the application of section 21 of the Criminal Code:

 

1. If the social worker knew that the client intended to commit some act of violence, but nothing more, the social worker will not be guilty of aiding or abetting. [25] If the social worker has some knowledge of the “essential nature of the offence” committed by the client, but does not know the details of the specific crime committed (e.g., the social worker knows the client has an intention to kill, but does not know how the murder will be committed), the social worker may be guilty of aiding or abetting. [26]
2. Where there is a legal duty to act, a failure to act can constitute aiding and abetting. [27] This rule would apply where an act or omission occurs before or during the commission of a crime, not after the crime has already been committed—unless the specific law states otherwise.
3. Mere presence at the scene of a crime is not sufficient to ground liability under aiding or abetting. [28]

 

 

• (ii) Analysis

 

The application of section 21 of the Criminal Code to social workers has been grouped in with the application of section 22 in the next portion of this article.

 

 

• (b) Counselling an Offence

 

• The Law

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[1] Martin’s, ibid at 71, citing R v Roach (2004), 192 CCC (3d) 557 (Ont CA).

[1] Martin’s, ibid at 70.

[1] Martin’s, ibid at 71, citing R v Curran (1997), 38 CCC (2d) 151 (Alta SC App Div), motion for leave to appeal to SCC dismissed 20 NR 180n.

[1] Martin’s, ibid at 71, citing R v Roach (2004), 192 CCC (3d) 557 (Ont CA).

[1] Martin’s, ibid at 70, citing R v Adams (1989), 49 CCC (3d) 100 (Ont CA).

[1] Martin’s, ibid.

[1] Martin’s, ibid at 71, citing R v Dooley (2009), 249 CCC (3d) 449 (Ont CA), leave to appeal to SCC refused [2010] 2 SCR vi.

[1] Martin’s, ibid at 70, citing R v Dunlop and Sylvester, [1979] 2 SCR 881.

Under the Criminal Code, a person may also be charged criminally if he or she counsels another person to commit a crime. [29] Again, the relevant provisions are reproduced below:

 

Again, a case law review of the above provisions in the context of social workers does not provide any guidance regarding a duty on social workers to report crimes they have been told about.

 

To counsel an offence means that the social worker procures, solicits, or incites the client to commit an offence. Similarly to aiding and abetting, in order to be convicted for counselling an offence, a social worker must procure, solicit, or incite the client with the intent to counsel the client to commit an offence. [30] To intend to counsel the offence means that either the social worker intended (1) that the offence he or she counselled would be committed, or (2) that the result of his or her conduct was that the offence would actually be committed. If the social worker is merely reckless in counselling the offence, he or she will not have the requisite mental element of the offence, and therefore, will not be found guilty. [31]

 

 

• (ii) Analysis

 

It is unlikely that a person who has been told about a crime would be charged under section 21 or 22 of the Criminal Code for simply failing to report the crime to the police. However, if the person has been told that a crime occurred, and, by failing to report the crime, the person has somewhat aided, abetted, or counselled the crime to take place, the person may be charged under section 21 or 22 of the Criminal Code. [32] It is this extra act of doing something to aid in the commission of the offence or suggesting that a person should commit an offence that puts the social worker at risk for being charged criminally.

 

For example, if a social worker says or does something to a client that suggests he or she should commit an offence (such as suggesting that it will be fine if the client only steals one time), that would likely be aiding, abetting, or counselling.

 

Conversely, if a social worker merely listens to the information provided to him or her about a crime, it is likely that the social worker is not aiding, abetting, or counselling the crime. This is especially true if a crime was committed some time ago and the client is merely telling the social worker about it now. In these circumstances, there likely is not a risk that a crime will be committed in the future, and therefore, the social worker would not be aiding, abetting, or counselling an offence by failing to report since the social worker can not aid, abet, or counsel a crime that has already been committed.

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[1] Supra note 12 at s 22. See also s 241(1) regarding counselling a person to commit suicide.

[1] Martin’s, supra note 19 at 71, citing R v Curran (1997), 38 CCC (2d) 151 (Alta SC App Div), motion for leave to appeal to SCC dismissed 20 NR 180n.

[1] Martin’s, ibid at 76.

[1] Toronto Defence Lawyers,” Is it a Crime Not to Report a Crime in Canada?” (April 12, 2016) (blog) online: .

However, consider the following situation: a client tells a social worker about a crime he or she will commit and asks the social worker to tell him or her whether he or she should do it, and the social worker does not say anything. In these circumstances, it is possible that the failure to tell the client that he or she should not commit the crime could be considered aiding, abetting, or counselling the crime.

 

Whether a social worker aids, abets, or counsels a client to commit a crime by failing to report to the police when the client tells the social worker about a crime he or she has committed will depend on the individual facts of each specific case.

 

 

• (c) Accessory After the Fact

 

• (i) The Law

 

A person may also be charged under the Criminal Code if he or she becomes an accessory to a crime after the crime has been committed. [33] Again, the relevant provisions are reproduced below:

 

 

With regard to specific examples of acts a person may partake in, if a social worker merely fails to disclose the fact that an offence has been committed in his or her presence, he or she will not be guilty of being an accessory to the offence. [34] Furthermore, if a social worker merely fails to aid in the apprehension of the client who committed the offence, he or she will not be guilty of being an accessory to the offence. [35]

 

 

• (ii) Analysis

 

Since section 23(1) of the Criminal Code does not include reference to an omission, it would seem that failing to notify the police of a crime that has been committed by a client would not fall within this provision. This statement is strengthened by the fact that it is not an offence under section 23(1) to fail to disclose a crime that was committed in the social worker’s presence, which would seem to be more culpable than failing to commit a crime that was merely mentioned to the social worker but that he or she did not witness.

 

Conversely, if, for example, a client tells a social worker that he or she has committed a crime and needs a place to hide from the police, and the social worker allows the client to hide in his or her office to avoid arrest from the police, that act of assisting the client will almost certainly amount to the social worker becoming an accessory to the crime after the fact.

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[1] Supra note 12 at s 23(1).

[1] Martin’s, supra note 19 at 79, citing R v Dumont (1921), 37 CCC 166 (Ont CA).

[1] Martin’s, ibid at 79, citing R v Young (1950), 98 CCC 195 (Que CA).

Nevertheless, whether a social worker is an accessory to a crime committed by a client because he or she failed to report to the police when the client told him or her about a crime he or she has committed will depend on the individual facts of each specific case.

 

 

• (d) Other Provisions Under the Criminal Code

 

The following is a list of other provisions in the Criminal Code that describe situations a social worker may find themselves in, but ultimately under which the social worker likely would not be charged criminally for failing to report a crime that has been mentioned to the social worker by his or her client:

 

1. An offence is committed where a person omits to assist an officer in the execution of his duty to arrest a person after being given reasonable notice that he or she is required to do so. [36] Because this provision requires that a person be given reasonable notice that he or she must assist a police officer, it is likely a social worker who merely refrains from reporting a crime he or she has been told about by his or her client would not fall within this provision unless an officer specifically asked the social worker about the crime.
2. An offence is committed where a person permits another person (whom the person had in lawful custody) to escape. [37] Because a social worker likely does not have his or her client in “lawful custody” when the client visits the social worker, it is likely a social worker who merely refrains from reporting a crime he or she has been told about by his or her client would not fall within this provision.

 

As always, whether a social worker is found to have committed a crime listed above—or any other crime for that matter—because he or she failed to report to the police when a client told him or her about a crime he or she has committed will depend on the individual facts of each specific case.

 

 

• (e) Summary of Criminal Offences Applicable to Social Workers

 

Generally, the mere failure to report a crime that a client has told a social worker about likely will not result in a criminal charge being laid against the social worker.

 

However, a social worker may be guilty of aiding, abetting, or counselling a client to commit a crime if, for example, the client asks the social worker whether he or she should commit a crime and the social worker remains silent.

 

Moreover, a social worker may be deemed an accessory after the fact if the social worker does not necessarily tell the client what he or she should do regarding the commission of an offence, but he or she assists in hiding the client from the police.

 

As previously noted, it is likely a social worker who merely refrains from reporting a crime he or she has been told about by his or her client would not be charged under any of the crimes in the “Other Provisions…” section above, because the facts simply do not fit within those provisions.

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[1] Criminal Code, supra note 12 at s 129(b).

[1] Criminal Code, ibid at s 146(a).

Unfortunately, we do not have case law or much other guidance on the appropriate steps to take as a social worker in these circumstances. A social worker nevertheless must remember (1) his or her duty of confidentiality to the client, and (2) his or her duty to report/warn in circumstances where a child is in need of protection or where disclosure will prevent serious, foreseeable, and imminent harm to the client or others.

 

Ultimately, although this article provides some guidelines about the risks a social worker may face when a client tells him or her about a crime, it is highly recommended that, when in doubt, social workers should always consult a lawyer with the exact circumstances for a complete analysis of what steps to take, as the individual facts of each circumstance will determine whether a social worker will be charged criminally for acting or omitting to act.

 

 

• (4) What Steps Should a Social Worker Take When Faced with an Ethical Dilemma Regarding Disclosure of Alleged Illegal Activity?

 

As a pre-emptive measure when engaging with a client, social workers should always have a frank conversation at the beginning of the client relationship—and even at the outset of each meeting if necessary—where he or she discusses what information will/may need to be shared with others if disclosed to the social worker by the client. This way, the client will be informed/reminded of the social worker’s obligations regarding his or her duty to report, and the client can make his or her own decision on what information, if any, to disclose to the social worker. In doing this, the social worker acknowledges the client’s right to confidentiality but also explains the limits of that right when compared to the social worker’s own ethical obligations. [38]

 

Despite taking the above action when meeting with a client, social workers may nevertheless find themselves faced with ethical dilemmas regarding situations where a client has disclosed alleged illegal activity. In such situations, social workers should consider the following steps in determining the best course of action to take: [39]

 

1. Review the rules and guidelines concerning confidentiality and the duty to report in the SWA, SASW Bylaws, SASW Standards, CASW Code, and CASW Guidelines.
2. Consult a lawyer for advice.
3. Discuss the situation with colleagues, consultants, and the SASW/CASW; these people will likely have insights on ethical dilemmas, or at least perspectives from similar situations they have found themselves in.
4. Keep records of all steps taken and decisions made regarding the ethical dilemma.

 

Ultimately, there are often no clear-cut answers regarding these ethical dilemmas. Nevertheless, social workers can protect themselves as much as possible by following the above steps.

Conclusion

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[1] Kathryn Krase, “Social Workers as Mandated Reporters: Conflicted Over Confidentiality? Part IV”(2014) online: .

[1] Based off the article “Eye on Ethics: The Limits of Confidentiality” by Frederic G. Reamer dated April 14, 2002, online: .

Social workers generally do not have a duty to disclose information about crimes that a client has told them, and should not do so where the law does not permit them to break confidentiality. However, social workers should take care to ensure that, in discussing crimes with their clients, they are not aiding, abetting, or counselling the client to commit a crime, becoming an accessory to the crime, or otherwise falling within the provisions of the Criminal Code.

[1] SS 1993, c S-52.1 [SWA].

[2] The Saskatchewan Association of Social Workers – General Bylaws (2017), online: .

[3] The Social Workers Administrative By-laws (2018), online: .

[4] The Saskatchewan Association of Social Workers Standards of Practice for Registered Social Workers in Saskatchewan (2017), online: [SASW Standards].

[5] The Canadian Association of Social Workers Code of Ethics (2005), online: [CASW Code].

[6] The Canadian Association of Social Workers Guidelines for Ethical Practice (2005), online: [CASW Guidelines].

[7] The Child and Family Services Act, SS 1989-90, c C-7.2 at s 12(1) [CFSA].

[8] CASW Guidelines, supra note 6 at s 1.6.2.

[9] CASW Guidelines, ibid at s 1.5.

[10] RRS c H-0.021 Reg 1 [HIPR].

[11] See the definition of “trustee” under section 2(t)(xii)(A) of The Health Information Protection Act, SS 1999, c H-0.021 [HIPA].

[12] RSC 1985, c C-46 [ Criminal Code].

[13] SC 1996, c 19.

[14] SASW Standards, supra note 4 at clause B(c).

[15] Ibid at clause D.1.

[16] Supra note 5 at 7-8 and 10.

[17] Supra note 6 at s 1.4, 1.5, and 6.3.

[18] Supra note 12 at s 21(1)(b) and (c). See also s 241(1) regarding aiding or abetting a person to commit suicide.

[19] Edward L. Greenspan, Q.C., Marc Rosenberg, and Marie Henein, Martin’s Annual Criminal Code 2019, (Toronto: Thomson Reuters, 2018) at 70 [ Martin’s].

[20] Martin’s, ibid at 70.

[21] Martin’s, ibid at 71, citing R v Roach (2004), 192 CCC (3d) 557 (Ont CA).

[22] Martin’s, ibid at 70.

[23] Martin’s, ibid at 71, citing R v Curran (1997), 38 CCC (2d) 151 (Alta SC App Div), motion for leave to appeal to SCC dismissed 20 NR 180 n.

[24] Martin’s, ibid at 71, citing R v Roach (2004), 192 CCC (3d) 557 (Ont CA).

[25] Martin’s, ibid at 70, citing R v Adams (1989), 49 CCC (3d) 100 (Ont CA).

[26] Martin’s, ibid.

[27] Martin’s, ibid at 71, citing R v Dooley (2009), 249 CCC (3d) 449 (Ont CA), leave to appeal to SCC refused [2010] 2 SCR vi.

[28] Martin’s, ibid at 70, citing R v Dunlop and Sylvester, [1979] 2 SCR 881.

[29] Supra note 12 at s 22. See also s 241(1) regarding counselling a person to commit suicide.

[30] Martin’s, supra note 19 at 71, citing R v Curran (1997), 38 CCC (2d) 151 (Alta SC App Div), motion for leave to appeal to SCC dismissed 20 NR 180 n.

[31] Martin’s, ibid at 76.

[32] Toronto Defence Lawyers,” Is it a Crime Not to Report a Crime in Canada?” (April 12, 2016) (blog) online: .

[33] Supra note 12 at s 23(1).

[34] Martin’s, supra note 19 at 79, citing R v Dumont (1921), 37 CCC 166 (Ont CA).

[35] Martin’s, ibid at 79, citing R v Young (1950), 98 CCC 195 (Que CA).

[36] Criminal Code, supra note 12 at s 129(b).

[37] Criminal Code, ibid at s 146(a).

[38] Kathryn Krase, “Social Workers as Mandated Reporters: Conflicted Over Confidentiality? Part IV”(2014) online: .

[39] Based off the article “Eye on Ethics: The Limits of Confidentiality” by Frederic G. Reamer dated April 14, 2002, online: .