Who Cares Who Killed Roger Ackroyd?

I've told this story three years ago.  (Actually, I've told it since then, most recently Friday night over a couple of beers, but I digress.)

Friday night, June 11, 1965. I was at Shea Stadium. Mets-Dodgers game. Warren Spahn was pitching for the Mets, Don Drysdale for the Dodgers. Dodgers won 2-1. Both Dodgers runs were on homers by Drysdale. The Mets run was on a homer by Spahn. Incredible. Etched in my memory. I'll never forget it. Except, of course, it didn't happen that way.

Oh, I was at the game, and it was one hell of a game. A real pitching duel between Spahn and Drysdale. And Drysdale did win it with a home run in the 8th. But the Dodgers other run was on a homer by John Roseboro in the 5th. The Mets run, also in the 5th, came when Joe Christopher singled in Johnny Lewis. Spahn went 0 for 3. Helluva game, like I said. As Casey used to say, you could look it up. (I did. I'll save you the trouble. Here's the link.) Close enough to my memory so you can see how the story got better over time. Until . . . . Like I said, I'm mistaken. I know I'm wrong about just how the game unfolded. But I remember it as three homers - two by Drysdale and one by Spahn. It's not a lie to say I remember it that way. And if I hadn't looked it up, I wouldn't know I was wrong.  And even though I know, know for sure, my memory hasn't changed.

You don't care about the game unless you were there or you're some sort of baseball geek.

On the other hand, you probably care (at least lots of people do) about wether Woody molested Dylan. Just as at one time everyone seemed to care about whether Fatty Arbuckle raped and killed Virginia Rappe. (A total aside to note surprise that my younger son knew who Fatty Arbuckle was - that was a scandal célèbre 80 years ago, one generally forgotten except among scandalistas, silent-film buffs, and those well past a certain age.)  

Dahlia Lithwick says that you're actually kind of obligated care about Woody and Dylan - at least if you want to avoid water-cooler ostracism.   But, she adds, we have no evidence.  No standards, no burden of proof, no nothing to resolve "the case."  Which is true enough.  But then, we don't have a case, either.

What we have is a salacious (that's the point, isn't it) allegation involving a celebrity (the other part of the point).  It's gloriously tawdry (another part of the point, I guess).  And a whole lot of belief one way or the other.  

Those who are sure - Dylan wouldn't, Dylan couldn't have made it up; it's too detailed, too ugly. Anyways, kids don't lie and nobody would lie about this sort of thing and of course Woody denies it. Those who are sure - Woody didn't, Woody couldn't; the allegations are too bizarre.  Anyway, he's been cleared and Mia hate him and of course there are false memories so Dylan's absolute certainty is irrelevant to whether it happened.  

I take a perhaps jaundiced view of all this.  I am, after all, a criminal defense lawyer.   I don't like trial by newspaper and twitter feed.  We're not well-served by declarations of faith on the part of the general public.  

More, I don't care.  Woody's an artist.  Maybe you like his films, maybe not.  But they're the same films, as good or as bad - but ultimately they're the same - whatever did or did not happen to Dylan.  In that way, at least, this is differs from what you do or don't believe about A-Rod's steroid use.  (Though I guess almost everyone believes the same thing in that case.)  The steroids, at least this was the idea, made him a different player, changed his performance.  

As I say, I don't care.  I don't get the culture of celebrity that finds these things fascinating.  Or, and really more to the point, feels a personal involvement.  On the other hand, I'm not inclined to slow down to eyeball an accident on the other side of the highway.  Amanda Knox?  Raw deal.  But the deal was raw from a legal perspective (applying U.S. standards, anyhow) whether or not she killed Meredith. Kercher.  Did she?  Don't know.  Don't care.   Casey Anthony?  Ditto.

The hordes - Robert Blecker, Thane Rosenbaum, Nancy Grace - they apparently care deeply about these things.  It's important for them to hate the bad guys, which means they have to know who the bad guys are.  Even when there's no way to know and no actual need to know.

Maybe the problem is that I don't watch enough television.  

Maybe the problem is that everyone else watches too much.

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If you're wondering about the title here, "Who Cares Who Killed Roger Ackroyd?" was a New Yorker piece by Edmund Wilson from 1945 explaining why all detective fiction since Sherlock Holmes was appalling drivel and those who found pleasure in it were literarily, intellectually (and by implication at least), morally bankrupt.   You can read it here.  The Murder of Roger Ackroyd is, if you don't know, a mystery novel by Agatha Christie.

Death for Sure. Ooops, Make That Life

Jared Lee Loughner took the deal and will spend the rest of his life in prison.

Wade Michael Page was shot to death by police.

Casey Anthony was found not guilty.

And Mumia's off the row.

There's still a chance for James Holmes, but it's far from a sure thing.

What's a death penalty supporter to do?

Oh, sure.  Texas killed Marvin Wilson tonight despite overwhelming evidence that by any measure endorsed by medicine or social science he has mental retardation and ineligible for execution under the 8th Amendment.* He's the 25th person executed this year, but at this pace we won't even get to 50.  As recently as 1999, we killed 98.

In fact, for all the bluster and all the bloodshed (we've executed 1302 men and women in this modern era of the death penalty in the US), we kill very few.  California has more than 700 people on death row.  It's executed 13.  Even in Texas where they've killed 484 now and where executions are almost commonplace, the reality is that few killers are sentenced to die and many who are don't actually die at the hands of the state.

In 1972, Supreme Court Justice Potter Stewart said that executions in this country were essentially random.  

[D]eath sentences are cruel and unusual in the same way that being struck by lightning is cruel and unusual.

It was true then, when murder wasn't the only capital crime, juveniles weren't categorically excluded from execution, and death row in this country was about one-fifth the size it is today.  It's just as true now. 

In 1972, the Supreme Court declared all the death penalty laws in the country unconstitutional.  In response, states rushed to enact new laws they hoped would comply.  The Court hasn't invalidated a state's death penalty law since 1978, but 5 states have abolished their own laws in recent years.

Erika Christakis, at Time. com, says that focusing on cases like Wilson's where there's a particularly powerful argument against execution misses the point.

Yet, the focus on extreme cases like Wilson’s — and whether he is legally and somehow “legitimately” executable despite his mental incapacity — prevents us from facing a larger truth that all state-sanctioned executions are a shameful relic of a bygone era along with the burning of witches and the use of child labor in mines.

Which is true.  But extreme cases, as the short list I proffered at the beginning of this post should make clear, are also cases where the case for death seems especially urgent.  (The cases that Jonah Goldberg falsely claims people like me won't talk about.)  And it's true of those cases, too.  The details are a distraction.

The cult of celebrity death penalty cases (none more than Mumia's) is a distraction because it allows us to get sidetracked.

Many years ago a prosecutor and I were debating the death penalty at the University of Toledo School of Law.  One of the students asked whether I'd be in favor of executing Hitler.

Hitler, Pol Pot, Stalin, Idi Amin, Bashar al-Assad, it's easy to toss out the names of those who oversaw the deaths of thousands if not millions.

Why not them?

Just as it's easy to toss out the iffy cases (Cameron Todd Willingham, say, or Troy Davis).

Why those guys?

Put aside the question of how we can tell who belongs in which camp.  Forget the broader moral issues.  Don't talk about slippery slopes or lowest common denominators.  And god knows these aren't questions about the wisdom of this or that public policy and of budgetary considerations in an age of reduced government resources.

Dump all that shit.

Instead, ask this question.

Who do we trust?

Who gets to make the call?

Nancy Grace?  She recently said that if she bumped into Casey Anthony she'd do something illegal because she's quite convinced Anthony is guilty and (although she didn't exactly say this part) must be punished and since the government won't, she would.

An opinion poll?

A jury?

A governor?

Obama thinks it's fine that he gets to decide which American citizens we can kill with drones.  After all, he's careful.  And maybe he is.

But it was John Roberts, no fan of my clients, who wrote this a couple of years ago in United States v. Stevens (citations silently excised).

Not to worry, the Government says: The Executive Branch construes §48 to reach only “extreme” cruelty, and it “neither has brought nor will bring a prosecution for anything less,” The Government hits this theme hard, invoking its prosecutorial discretion several times. But the First Amendment protects against the Government; it does not leave us at the mercy of noblesse oblige. We would not uphold an unconstitutional statute merely because the Government promised to use it responsibly.

What's true of the First Amendment is true of the others, too.  And it's certainly true of policy.

Ronald Reagan used to say that the most frightening words in the language were

I'm from the government and I'm here to help you.

Not because of bad intentions.  Not even because the government wouldn't sometimes actually help.  But because it couldn't be trusted.

I'm not Reagan, not a Reaganite.  I believe in government.  But I don't trust it.  Nor do I trust the wisdom of the mob.  Even the mob that's trying hard to not be a mob but to get it right.

With blips here and there, the reality is that death sentences are down.  Executions are down. There are any number of reasons.  One is that I'm not the only one who knows better than to trust the government or the mob.

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*Kent Scheidegger disagrees.  It's only whores and charlatans and defense attorneys (pretty much the same group according to Kent) and deeply naive abolitionists who believe Wilson to have mental retardation.

 

Third Try on the Cult of Celebrity

I've obviously struck a nerve.

I'm taking one more shot at this, and then I'll just let the commentators have at it (and thank you, by the way, for reading and commenting - even if it's to tell me that I'm full of shit).

Mumia's not an empty celebrity, not a mere celebrity. But he is a celebrity. Like it or not, he gets far more attention than the overwhelming number of folks on death row in the U.S., and it isn't because his case is so much more outrageous.

Same for Troy Davis and Kenneth Foster and probably a couple of dozen others, by the way. Each of the small number of men and women who get international campaigns mounted on their behalf because they're articulate or attractive or caught the attention of someone or some group who gathered the time and money and organization and worked tirelessly on their behalf.

More power to them.

But don't tell me they aren't celebrities. They are. The particular attention they garner, that's garnered for them, the sheer quantity, virtually defines celebrity.

I'm not saying they should be ignored or that their supporters should stop. (Frankly, I'm not telling anyone what to do.) I'm not saying they do no good. They do. Sometimes the attention even saves, or helps save, their lives.

What I'm saying, simply, is that there are some 3,279 men and women on death row in the United States. Probably fewer than 100 - whatever the number it's a small percentage - have any sort of significant public or media attention. Their lawyers (if they have lawyers and if the lawyers are any good) struggle to find the resources they need to mount anything beyond the most cursory defense.

(In one case, I asked a federal court for the money for arson investigator since there was at least some question of whether my client actually committed arson. The judge said no. The state's arson investigators said it was arson, so mine would agree, so there was no point. That's how it really works, folks.)

I'm not suggesting that Mumia or his supporters don't care about that. I'm not suggesting that they aren't using his star power on behalf of all the condemned. I'm not criticizing anyone.

I'm just noting that, for instance, when the judge in Ohio yesterday declared that he didn't believe that the witnesses against Mark Brown who recanted their testimony and, therefore, saw no reason to do anything to prevent or delay Brown's execution 2 weeks from today, it didn't make the New York Times or CNN or Le Monde.

Pretty much nobody noticed. Pretty much nobody cares about Mark Brown, or even knows who he is.

I don't represent Brown, never have. I have no particular stake in his case. But he's the next guy up. Not just in Ohio, but in the U.S. And right now he needs all the help he can get. So does Alabama's Robert Bryant Melson due two weeks later. So did the guys in December. And all the rest of the ones you haven't heard of.

Mumia'd like to save them. So would his supporters. So would I.

But one way to help try to save them is to notice them. The focus on celebrity, makes it harder in some ways. The big trees obscure the shrubs. How many people know which is the ninth tallest mountain in the world? The seventh brightest star in the sky?

The focus on celebrity as a means of saving the ordinary folks is a hope for deus ex machina, and it rarely works that way.

The celebrities have powerful voices - hell, that's partly how they become celebrities. They address a big picture which needs to be addressed, but they model a false one.

Again, most of the men and women on the row aren't altogether innocent. Most aren't articulate, most aren't saintly. Most have nothing much to recommend them except that they are human. To take just a bit of a speech from Shylock:

I am a Jew. Hath
not a Jew eyes? hath not a Jew hands, organs,
dimensions, senses, affections, passions? fed with
the same food, hurt with the same weapons, subject
to the same diseases, healed by the same means,
warmed and cooled by the same winter and summer, as
a Christian is? If you prick us, do we not bleed?
if you tickle us, do we not laugh? if you poison
us, do we not die?

And so they are, those men and women on the row.

It used to be (I'm going back 10 or more years now, I think) that the on-line abolitionists engaged in constant, too often mean-spirited debate about the proper arguments to be used in advocating for abolition. You must argue religion, some said. No, you must deny religion. You must argue only morality. No, ignore morality and argue only innocence. Or only cost.

I was part of the cadre saying there was no single right approach. You argue whatever will move this or that audience. What matters is ending the killing and saving the lives, not insisting that those things should only be done by a world that shares a single motivation for it. "Let a hundred flowers bloom," I said, quoting Mao and looking to the announced idea if not the down and dirty reality.

I was wary then of the cult of celebrity and I'm wary of it now. I don't want to stop Mumia and his supporters. I just want to spread the energy about. To Mark Brown, to Robert Bryant Melson, to the 3278 other individuals, each of whom shares collective reasons, but also has individual ones, why he or she ought not be murdered by the government.

So I guess the charge that mine is an old point is right.

Mumia, Jesus, and Bortella Philisten

An anonymous commentator was put off by my comments about Mumia.

I don't understand the anti-Mumia resentment. Seems more grounded in hostility to his supporters than anything else. I have worked on behalf of many people on death row, not really on Mumia's, but I respect and admire his supporters and their efforts. They should keep up the good work.

I started to write a responsive comment, but decided to do this instead.

I suppose I wasn't as clear as I might have been.

I'm neither anti-Mumia, nor anti-his supporters. I have enormous respect for both. They're articulate, passionate. They raise important issues of race, class, and social justice. Of course they should keep up their work.

But I'm troubled that the cult of celebrity drowns out the cases of those less charismatic. They, those without charisma, without followings, are after all the vast majority. Singularity, exceptionalism, can be rallying points. But they can also be distractions.

Give us the resources and energy that have been pumped into Mumia's case over the past 28 years or so and see what we can do for numbers of others. I don't mean that exactly the way it may sound. But why him? Or, more precisely, why not, say, Bortella Philisten? He's also on Pennsylvania's death row, also for the killing of a police officer. He's been there for about 15 years now.

Do you know anything about the case? Probably not. Ever heard of him before? Probably not. Are the international forces of nobility out marching and rallying on his behalf? Probably not.

Did he get a fair trial? Probably not. Is there evidence that he might be innocent? I have no idea, but it wouldn't shock me. Why aren't the glamorous folks out there holding fund-raisers for him?

I just pulled Philisten's name off a list. I don't believe I've ever heard of him before, either. And that's the point.

I'm not suggesting, have not suggested, that Mumia doesn't deserve attention. But so do all the others. Philisten and Ohio's Mark Brown and the rest. All of them. Mumia's no more important than they.

Jesus was not the only one the Romans crucified just then. But the only one of the others we know is Barabas - who received clemency. And for that Jesus preached about social justice, his celebrity took root a whole lot more than his message. And, of course, he and the others (except Barabas) were executed.

I don't mean to denigrate Jesus, either. But look at all the anonymous others who got killed while the focus was on him. Then ask:

What would he do?

Death Row Celebrity

I've always been wary of death-row celebrities.

I'm talking Mumia Abu-Jamal, and if you don't know the tale, well, here is the very short version.

Daniel Faulkner, a Philadelphia police officer was shot and killed in December 1981. Mumia, a part-time cab driver, radio journalist, Black Panther Party member, and general pain in the ass was convicted of the killing and sentenced to die.

Because the trial was so ostentatiously unfair, and because Mumia himself is so damned articulate, and because he insists on his innocence and there's a fair amount of evidence to support that claim, he's become an international cause célèbre, the most famous person on death row.

His supporters, and there are many, insist he was railroaded. Many have resolved the case for themselves: He's innocent, they proclaim.

But his detractors, including the government, the cops, and the Faulkner family, insist that he is guilty and should have been killed years ago.

Mumia's been litigating this mess for close to 30 years now, through loss after loss. And then, in March 2008, the Third Circuit affirmed his conviction but said his sentencing was unconstitutional and needed to be redone. Everyone was unhappy. Mumia's supporters insisted he should have had his conviction reversed. After all, he was innocent. And his trial was unfair. His detractors were livid that he might not be killed. So both sides asked the Supreme Court to hear the case.

In April last year, the Court refused to hear Mumia's appeal. No new trial. But still, there was that life rather than death sentence. Where there's life there's hope. Who knew what might happen down the road.

Of course, the state had appealed the reversal of the death sentence. But the Court didn't act. The state's appeal languished. And languished. And languished. For nearly a year.

There was another case, out of Ohio, raising a similar similar sentencing issue, Smith v. Spisak. As with the jurors at Mumia's trial, the jurors at Frank Spisak's trial were not told that they did not have to agree unanimously about the existence of mitigating factors before they could be weighed in favor of life. Like the Third Circuit in Mumia's case, the Sixth Circuit reversed Spisak's death sentence. Just as Pennsylvania appealed the circuit court's decision in Mumia's case, so Ohio appealed the circuit court's decision in Spisak's.

Last week, Spisak lost. Today, the Supremes vacated the Third Circuit's decision in Mumia's case and sent it back for reconsideration in light of Spisak.

Another day, another loss.

According to the Death Penalty Information Center, which keeps careful records, there are today 3279 men and women (mostly men) on death row in this country. Mumia Abu-Jamal is just one of them, one of 225 in Pennsylvania. Most of them have cases in process in one or another court. And the decisions in those cases, especially the sort of look-at-it-again we're-not-even-bothering-with-an-opinion decision the Court issued today in Mumia's case, get almost no attention outside the local jurisdiction.

The decision in Mumia's case will be noted around the world.

Like I say, I've always been wary of death-row celebrity.

Their supporters ("fan club" is the term Kent Scheidegger used for Mumia's yesterday; one sometimes hears "groupies") claim innocence because they believe all exculpatory evidence and disbelieve all inculpatory. They insist somehow on heroic status. They trumpet too much. And if the case goes south (see Roger Coleman, for instance) it just provides ammunition for the retentionists.

Besides, celebrities are a distraction. Let's be honest about this for a minute.

The vast majority of the people on death row (and nobody knows the percentage) did something at least close to what they are there for. They killed someone. It wasn't justifiable by any reasonable calculus we might use. And there's nothing heroic about them.

They're sad cases: inarticulate, often nearly illiterate, frequently mentally ill, too often still with mental retardation. They were victims as children of physical abuse, sexual abuse, psychological abuse. They are, in the words of Ohio's Chief Justice Moyer (alas in dissent) describing one of my former clients, "destined for disaster."

They are the disposable children of disposable families. The dross, the waste

They are - even the smart, talented ones, the ones who love and are loved - they are all damaged goods by the time they get to the row, certainly after they've been there for a while.

These are our clients, those of us who do this work.

Mumia, Stanley "Tookie" Williams, Karla Faye Tucker, Shaka Sankofa: these are the oddities. They suck the energy from the movement. Their exceptionalism belies the reality of the rest. And as Tookie, Karla Faye, and Shaka learned all too well, exceptionalism doesn't save them either. And it doesn't end the killing.

So I've been wary of death-row celebrity.

And yet, Mumia's loss (and it seems clear that death is now for him the almost inevitable outcome) resonates. Not more than the others. Not with the personal force of the loss of one of my own clients or the client of a friend. But in other ways.

His voice has been an affront to the system. His supporters particularly committed to a political struggle on behalf of the dispossessed and downtrodden. He's been the figurehead of a social movement that's larger than death row. That's his weakness as an icon, but his strength, too.

When I was in college, earnest young socialists would come to town, spend the night in my living room writing manifestos and then go to the mills and try to organize the unionized workers. They expected great support. They routinely got the shit beaten out of them by those they saw as their natural allies. Socialist theory goes only so far before it butts up against the stark reality of workers who don't see the world as class struggle.

And so it is for Mumia and his supporters.

They have truths to tell. Big ones about racist society and power and corruption. Smaller ones about unfair trials and cursory rather than substantive judicial review. And questionable ones about, say, factual innocence.

Those are important truths, all of them. But they end up getting muddled around the question of innocence.

Death row is a symptom of social failure. But it's a lousy proxy for it.

Mumia's is a powerful voice crying out against injustice. But he's also just another of the men on the row who ought not be murdered by the government.

There are 3,278 others just like him. Except without the fan club.

Save Mumia. By all means, save him.

But the next man with an execution date (February 4) is Mark Brown, here in Ohio. Nobody much has heard of him. Two of the witnesses against him have recanted their testimony. Yet you see no international outcry. There are no headlines in London or Paris or Rome. Archbishop Tutu hasn't spoken. Bianc Jagger hasn't appeared. The Pope hasn't weighed in.

Save Mumia. But save Mark Brown first.

Celebrity Justice. Or not.

Think about it another way.

Roman Polanski has spent the last 31 years or so living in France and Switzerland, making movies, winning an Oscar, and oh yeah, being a fugitive from justice. On his most recent trip to Switzerland - to attend a festival and pick up a prestigious award - he was arrested by Swiss authorities who have been, at last, asked to extradite him to the United States so that he can face whatever he might face for his crimes.

Perhaps we should be specific. He was charged with the drugging and multiple raping of a 13-year-old girl. He entered an agreed plea to something like unlawful sexual intercourse with a child under 14. He fled the country when word reached him that despite expectations when he entered the plea, the judge would impose some period of incarceration as part of the sentence. As is the case in all agreed pleas, the truth is murky.

In a plea bargain such as this one, the defendant (Polanski, here) admits to something less than the charges in return for the certainty that the sentence will be less than the potential sentence if found guilty at trial. The state obtains a guilty verdict and some sentence avoiding the risk that the defendant will prevail at trial and go free. Both the defendant and the state save the cost and stress of a trial. And when the alleged crime is a child rape, everyone avoids the public ugliness. The details of the allegation needn't come out. The child needn't suffer the stress of getting on the witness stand but also won't have to answer to cross examination.

The problem is that when everyone is willing to live with the bargain, nobody knows what actually happened. The reduction in risk and burden is also a reduction in accountability for the defendant and for the system.

[A brief aside here to note that the Duke lacrosse team did not rape Crystal Gail Mangum, and the Hofstra five did not rape Danmell Ndonye. Those cases never went to trial because the evidence that the allegations were false was clear and overwhelming and revealed and presented before things got that far. (And what is it about college students, anyway, that brings forth these false charges of gang rape?) There's no way of knowing how many false rape charges are prosecuted (but see here for an interesting discussion of the question). It's a certainty that it happens, though, and that some people are convicted of them - some even plead guilty.]

Polanski is now in his mid-70s. The girl now in her forties. He has been angling to get the prosecution dismissed. She has supported him in that effort, though she insists that he is guilty. The press, the arts communities (there's more than one) and the blogosphere are all in high dudgeon over Polanski's arrest and possible extradition.

It is, depending on who you listen to, an outrage or about time. Those who disagree are blinded by celebrity worship, wholly immoral, 21st Century Javerts chasing the noble Jean Valjean out of sheer vengence, Ashcroftian moral crusaders, or . . . . Enough. It's getting ugly out there.

Which brings us to that other celebrity rogue who's treatment has gotten attention lately, Andrew Sullivan. You remember, he's the friend of President Obama who got busted by the feds for blowing a bit of weed on federal property at Cape Cod. Unlike what happens to everyone else facing that charge, the local U.S. Attorney decided that the case against Sullivan should be dismissed because he'd suffer collateral consequences from a prosecution. The thing is most of those people who do get prosecuted suffer those same consequences, and nobody cares.

Yes, the government has discretion about who and when to prosecute. And yes the collateral consequences of prosecution are appropriate considerations to weigh when determining whether to exercise that discretion. (See commentary here, unearthed by Doug Berman here.) But when that discretion is only exercised in favor of the wealthy pal of the Pres with one of the most important political blogs in the country, well, you gotta wonder about abuse.

Don't misunderstand. Child rape is a vile act for which there's no excuse. Possession of marijuana (and this is in small amounts for personal use) shouldn't be a crime at all.

But the truth is that it looks a lot like Polanski got preferential treatment 31 years ago, and is being targeted now because he's charged the LA prosecutors with misconduct back then. And all of that is based on who he is. The ordinary child rape defendant wouldn't have been able to flee the jurisdiction in 1978. If he did, they'd have brought him back and nobody would have blinked. And if they hadn't found him for 31 years, they'd probably have forgotten all about it. Just as the public posturing on all sides is a consequence of his celebrity, so is every event in the case.

Same for Sullivan. What they did for him they should do for everyone. But anyone who spends even a brief time in the trenches of criminal law knows they don't.

Paris Hilton spent more time in custody than the typical drunk driver because of who she was. Michael Vick. OJ. The list goes on. Some do better for the celebrity, some do worse. What it never seems to be is irrelevant.