‘Prudent remedy' for veto error is special session, Legislative Council advises
Gov. Kelly Armstrong speaks during a meeting of the Senate Appropriations Committee on March 27, 2025. (Michael Achterling/North Dakota Monitor)
Legal staff for North Dakota's legislative branch concluded the 'prudent remedy' to correct an error with Gov. Kelly Armstrong's line-item veto would be for the governor to call a special session, according to a memo issued Friday.
But Attorney General Drew Wrigley, who is working on a separate opinion, maintains that Legislative Council has no role in determining the execution of the governor's veto.
Armstrong announced May 22 a 'markup error' with a line-item veto that crossed out $35 million for a state housing development fund. The red X over the funding did not match what Armstrong indicated in his veto message that explained his reasoning.
North Dakota governor unintentionally vetoes $35 million for housing programs
A Legislative Council memo distributed to lawmakers Friday concluded that legal precedent supports the marked-up bill as the official veto document. 'Engaging in interpretive gymnastics' to disregard the markings on the bill could lead to unintended consequences in the future, Legislative Council concluded.
Emily Thompson, legal division director for Legislative Council, said the Legislature needs to have an objective document to clearly illustrate what was vetoed, such as the specific veto markings on the bill, so lawmakers can exercise their veto override authority effectively.
Lawmakers have six days remaining in their 80-day limit and could call themselves back into session to address the veto. However, the memo cautions that the Legislature may need those days to reconvene to respond to federal funding issues or other unforeseen reasons. Legislative Council recommends the governor call a special session, which would not count against the 80-day limit.
A special session of the Legislature costs about $65,000 per day, according to Legislative Council.
Armstrong is waiting for an attorney general's opinion to determine the next steps, according to a statement from his office. He previously said he would call a special session if necessary.
Wrigley said Friday it's up to his office to assess the situation and issue an opinion on the governor's question.
'The power in question is strictly the governor's power and it has to be in compliance with the constitution and laws of North Dakota,' Wrigley said. 'That's the only assessment here. There's no role for this in Legislative Council. They have no authority in this regard.'
Armstrong on May 19 issued two line-item vetoes in Senate Bill 2014, the budget for the state Industrial Commission. His veto message explained his reasons for objecting to a $150,000 one-time grant for a Native American-focused organization to fund a homelessness liaison position. But the marking also crossed out $25 million for housing projects and programs and $10 million to combat homelessness, which he later said he did not intend to veto.
Chris Joseph, general counsel for Armstrong, wrote in a request for an attorney general's opinion that the markings served as a 'color-coded visual aid,' and the veto message should control the extent of the veto.
Wrigley said his office is working on the opinion and aware that resolution of the issue is time sensitive.
Bills passed by the Legislature with appropriations attached to them, such as the Industrial Commission budget, go into effect July 1.
'I look forward to publishing my opinion on that at the earliest possible time,' he said.
The Legislative Council memo states, 'It would not be appropriate to allow the governor and attorney general to resolve the ambiguity by agreement.'
In addition, Legislative Council concluded that if the governor's veto message is to be considered the controlling document for vetoes in the future, more ambiguities would likely be 'inevitable and frequent' and require resolution through the courts.
The memo cites a 2018 North Dakota Supreme Court opinion involving a case between the Legislature and then-Gov. Doug Burgum that ruled 'a veto is complete and irrevocable upon return of the vetoed bill to the originating house,' and further stated the governor does not have the power to 'withdraw a veto.'
'Setting a precedent of the attorney general issuing a letter saying we can just go ahead and interpret the governor's veto message to mean what was, or was not, vetoed, that's a really concerning precedent to set,' Thompson said in an interview.
Wrigley said any issues resulting from the opinion could be addressed by the courts.
'I sincerely hope that they (Legislative Council) are not trying to somehow publicly advocate, or attempt to influence a process for which they have no role,' Wrigley said.
Legislative Council memo
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Hamilton Spectator
20 minutes ago
- Hamilton Spectator
A US territory's colonial history emerges in state disputes over voting and citizenship
WHITTIER, Alaska (AP) — Squeezed between glacier-packed mountains and Alaska's Prince William Sound, the cruise-ship stop of Whittier is isolated enough that it's reachable by just a single road, through a long, one-lane tunnel that vehicles share with trains. It's so small that nearly all its 260 residents live in the same 14-story condo building. But Whittier also is the unlikely crossroads of two major currents in American politics: fighting over what it means to be born on U.S. soil and false claims by President Donald Trump and others that noncitizen voter fraud is widespread. In what experts describe as an unprecedented case, Alaska prosecutors are pursuing felony charges against 11 residents of Whittier, most of them related to one another, saying they falsely claimed U.S. citizenship when registering or trying to vote. The defendants were all born in American Samoa , an island cluster in the South Pacific roughly halfway between Hawaii and New Zealand. It's the only U.S. territory where residents are not automatically granted citizenship by virtue of having been born on American soil, as the Constitution dictates. Instead, by a quirk of geopolitical history, they are considered 'U.S. nationals' — a distinction that gives them certain rights and obligations while denying them others. American Samoans are entitled to U.S. passports and can serve in the military. Men must register for the Selective Service. They can vote in local elections in American Samoa but cannot hold public office in the U.S. or participate in most U.S. elections. Those who wish to become citizens can do so, but the process costs hundreds of dollars and can be cumbersome. 'To me, I'm an American. I was born an American on U.S. soil,' said firefighter Michael Pese, one of those charged in Whittier. 'American Samoa has been U.S. soil, U.S. jurisdiction, for 125 years. According to the supreme law of the land, that's my birthright.' Confusion over voting is not just an Alaska problem The status has created confusion in other states, as well. In Oregon, officials inadvertently registered nearly 200 American Samoan residents to vote when they got their driver's licenses under the state's motor-voter law. Of those, 10 cast ballots in an election, according to the Oregon Secretary of State's office. Officials there determined the residents had not intended to break the law and no crime was committed. In Hawaii, one resident who was born in American Samoa, Sai Timoteo, ran for the state Legislature in 2018 before learning she wasn't allowed to hold public office or vote. She had always considered it her civic duty to vote, and the form on the voting materials had one box to check: 'U.S. Citizen/U.S. National.' 'I checked that box my entire life,' she said. She also avoided charges, and Hawaii subsequently changed its form to make it more clear. Is U.S. citizenship a birthright? Amid the storm of executive orders issued by Trump in the early days of his second term was one that sought to redefine birthright citizenship by barring it for children of parents who are in the U.S. unlawfully. Another would overhaul how federal elections are run, among other changes requiring voters to provide proof of citizenship. Courts so far have blocked both orders . The Constitution says that 'all persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States.' It also leaves the administration of elections to the states . The case in Whittier began with Pese's wife, Tupe Smith. After the couple moved to Whittier in 2018, Smith began volunteering at the Whittier Community School, where nearly half of the 55 students were American Samoan — many of them her nieces and nephews. She would help the kids with their English, tutor them in reading and cook them Samoan dishes. In 2023, a seat on the regional school board came open and she ran for it. She was the only candidate and won with about 95% of the vote. One morning a few weeks later, as she was making her two children breakfast, state troopers came knocking. They asked about her voting history. She explained that she knew she wasn't allowed to vote in U.S. presidential elections, but thought she could vote in local or state races. She said she checked a box affirming that she was a U.S. citizen at the instruction of elections workers because there was no option to identify herself as a U.S. national, court records say. The troopers arrested her and drove her to a women's prison near Anchorage. She was released that day after her husband paid bail. 'When they put me in cuffs, my son started crying,' Smith told The Associated Press. 'He told their dad that he don't want the cops to take me or to lock me up.' A question of intent About 10 months later, troopers returned to Whittier and issued court summonses to Pese, eight other relatives and one man who was not related but came from the same American Samoa village as Pese. One of Smith's attorneys, Neil Weare, grew up in another U.S. territory, Guam, and is the co-founder of the Washington-based Right to Democracy Project, whose mission is 'confronting and dismantling the undemocratic colonial framework governing people in U.S. territories.' He suggested the prosecutions are aimed at 'low-hanging fruit' in the absence of evidence that illegal immigrants frequently cast ballots in U.S. elections. Even state-level investigations have found voting by noncitizens to be exceptionally rare. 'There is no question that Ms. Smith lacked an intent to mislead or deceive a public official in order to vote unlawfully when she checked 'U.S. citizen' on voter registration materials,' he wrote in a brief to the Alaska Court of Appeals last week, after a lower court judge declined to dismiss the charges. Prosecutors say her false claim of citizenship was intentional, and her claim to the contrary was undercut by the clear language on the voter application forms she filled out in 2020 and 2022. The forms said that if the applicant did not answer yes to being over 18 years old and a U.S. citizen, 'do not complete this form, as you are not eligible to vote.' A dispute entangled with a colonial past The unique situation of American Samoans dates to the 19th century, when the U.S. and European powers were seeking to expand their colonial and economic interests in the South Pacific. The U.S. Navy secured the use of Pago Pago Harbor in eastern Samoa as a coal-refueling station for military and commercial vessels, while Germany sought to protect its coconut plantations in western Samoa. Eventually the archipelago was divided, with the western islands becoming the independent nation of Samoa and the eastern ones becoming American Samoa, overseen by the Navy. The leaders of American Samoa spent much of the late 19th and early 20th centuries arguing that its people should be U.S. citizens. Birthright citizenship was eventually afforded to residents of other U.S. territories — Puerto Rico, the U.S. Virgin Islands, Guam and the Northern Mariana Islands. Congress considered it for American Samoa in the 1930s, but declined. Some lawmakers cited financial concerns during the Great Depression while others expressed patently racist objections, according to a 2020 article in the American Journal of Legal History. Supporters of automatic citizenship say it would particularly benefit the estimated 150,000 to 160,000 nationals who live in the states, many of them in California, Hawaii, Washington, Oregon, Utah and Alaska. 'We pay taxes, we do exactly the same as everybody else that are U.S. citizens,' Smith said. 'It would be nice for us to have the same rights as everybody here in the states.' Legal questions over status to be tested anew But many in American Samoa eventually soured on the idea, fearing that extending birthright citizenship would jeopardize its customs — including the territory's communal land laws. Island residents could be dispossessed by land privatization, not unlike what happened in Hawaii , said Siniva Bennett, board chair of the Samoa Pacific Development Corporation, a Portland, Oregon-based nonprofit. 'We've been able to maintain our culture, and we haven't been divested from our land like a lot of other indigenous people in the U.S.,' Bennett said. In 2021, the 10th U.S. Circuit Court of Appeals declined to extend automatic citizenship to those born in American Samoa, saying it would be wrong to force citizenship on those who don't want it. The Supreme Court declined to review the decision. Several jurisdictions across the country, including San Francisco and the District of Columbia, allow people who are not citizens to vote in certain local elections. Tafilisaunoa Toleafoa, with the Pacific Community of Alaska, said the situation has been so confusing that her organization reached out to the Alaska Division of Elections in 2021 and 2022 to ask whether American Samoans could vote in state and local elections. Neither time did it receive a direct answer, she said. 'People were telling our community that they can vote as long as you have your voter registration card and it was issued by the state,' she said. Finally, last year, Carol Beecher, the head of the state Division of Elections, sent Toleafoa's group a letter saying American Samoans are not eligible to vote in Alaska elections. But by then, the voting forms had been signed. 'It is my hope that this is a lesson learned, that the state of Alaska agrees that this could be something that we can administratively correct,' Toleafoa said. 'I would say that the state could have done that instead of prosecuting community members.' ___ Bohrer reported from Juneau, Alaska, and Johnson from Seattle. Claire Rush in Portland, Oregon, and Jennifer Sinco Kelleher in Honolulu contributed to this report. Error! Sorry, there was an error processing your request. There was a problem with the recaptcha. Please try again. You may unsubscribe at any time. By signing up, you agree to our terms of use and privacy policy . This site is protected by reCAPTCHA and the Google privacy policy and terms of service apply. Want more of the latest from us? 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San Francisco Chronicle
27 minutes ago
- San Francisco Chronicle
A US territory's colonial history emerges in state disputes over voting and citizenship
WHITTIER, Alaska (AP) — Squeezed between glacier-packed mountains and Alaska's Prince William Sound, the cruise-ship stop of Whittier is isolated enough that it's reachable by just a single road, through a long, one-lane tunnel that vehicles share with trains. It's so small that nearly all its 260 residents live in the same 14-story condo building. But Whittier also is the unlikely crossroads of two major currents in American politics: fighting over what it means to be born on U.S. soil and false claims by President Donald Trump and others that noncitizen voter fraud is widespread. In what experts describe as an unprecedented case, Alaska prosecutors are pursuing felony charges against 11 residents of Whittier, most of them related to one another, saying they falsely claimed U.S. citizenship when registering or trying to vote. The defendants were all born in American Samoa, an island cluster in the South Pacific roughly halfway between Hawaii and New Zealand. It's the only U.S. territory where residents are not automatically granted citizenship by virtue of having been born on American soil, as the Constitution dictates. Instead, by a quirk of geopolitical history, they are considered 'U.S. nationals' — a distinction that gives them certain rights and obligations while denying them others. American Samoans are entitled to U.S. passports and can serve in the military. Men must register for the Selective Service. They can vote in local elections in American Samoa but cannot hold public office in the U.S. or participate in most U.S. elections. Those who wish to become citizens can do so, but the process costs hundreds of dollars and can be cumbersome. 'To me, I'm an American. I was born an American on U.S. soil,' said firefighter Michael Pese, one of those charged in Whittier. 'American Samoa has been U.S. soil, U.S. jurisdiction, for 125 years. According to the supreme law of the land, that's my birthright.' The status has created confusion in other states, as well. In Oregon, officials inadvertently registered nearly 200 American Samoan residents to vote when they got their driver's licenses under the state's motor-voter law. Of those, 10 cast ballots in an election, according to the Oregon Secretary of State's office. Officials there determined the residents had not intended to break the law and no crime was committed. In Hawaii, one resident who was born in American Samoa, Sai Timoteo, ran for the state Legislature in 2018 before learning she wasn't allowed to hold public office or vote. She had always considered it her civic duty to vote, and the form on the voting materials had one box to check: 'U.S. Citizen/U.S. National.' 'I checked that box my entire life,' she said. She also avoided charges, and Hawaii subsequently changed its form to make it more clear. Is U.S. citizenship a birthright? Amid the storm of executive orders issued by Trump in the early days of his second term was one that sought to redefine birthright citizenship by barring it for children of parents who are in the U.S. unlawfully. Another would overhaul how federal elections are run, among other changes requiring voters to provide proof of citizenship. Courts so far have blocked both orders. The Constitution says that 'all persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States.' It also leaves the administration of elections to the states. The case in Whittier began with Pese's wife, Tupe Smith. After the couple moved to Whittier in 2018, Smith began volunteering at the Whittier Community School, where nearly half of the 55 students were American Samoan — many of them her nieces and nephews. She would help the kids with their English, tutor them in reading and cook them Samoan dishes. In 2023, a seat on the regional school board came open and she ran for it. She was the only candidate and won with about 95% of the vote. One morning a few weeks later, as she was making her two children breakfast, state troopers came knocking. They asked about her voting history. She explained that she knew she wasn't allowed to vote in U.S. presidential elections, but thought she could vote in local or state races. She said she checked a box affirming that she was a U.S. citizen at the instruction of elections workers because there was no option to identify herself as a U.S. national, court records say. The troopers arrested her and drove her to a women's prison near Anchorage. She was released that day after her husband paid bail. 'When they put me in cuffs, my son started crying," Smith told The Associated Press. "He told their dad that he don't want the cops to take me or to lock me up.' A question of intent About 10 months later, troopers returned to Whittier and issued court summonses to Pese, eight other relatives and one man who was not related but came from the same American Samoa village as Pese. One of Smith's attorneys, Neil Weare, grew up in another U.S. territory, Guam, and is the co-founder of the Washington-based Right to Democracy Project, whose mission is 'confronting and dismantling the undemocratic colonial framework governing people in U.S. territories.' He suggested the prosecutions are aimed at 'low-hanging fruit' in the absence of evidence that illegal immigrants frequently cast ballots in U.S. elections. Even state-level investigations have found voting by noncitizens to be exceptionally rare. 'There is no question that Ms. Smith lacked an intent to mislead or deceive a public official in order to vote unlawfully when she checked 'U.S. citizen' on voter registration materials,' he wrote in a brief to the Alaska Court of Appeals last week, after a lower court judge declined to dismiss the charges. Prosecutors say her false claim of citizenship was intentional, and her claim to the contrary was undercut by the clear language on the voter application forms she filled out in 2020 and 2022. The forms said that if the applicant did not answer yes to being over 18 years old and a U.S. citizen, 'do not complete this form, as you are not eligible to vote.' A dispute entangled with a colonial past The unique situation of American Samoans dates to the 19th century, when the U.S. and European powers were seeking to expand their colonial and economic interests in the South Pacific. The U.S. Navy secured the use of Pago Pago Harbor in eastern Samoa as a coal-refueling station for military and commercial vessels, while Germany sought to protect its coconut plantations in western Samoa. Eventually the archipelago was divided, with the western islands becoming the independent nation of Samoa and the eastern ones becoming American Samoa, overseen by the Navy. The leaders of American Samoa spent much of the late 19th and early 20th centuries arguing that its people should be U.S. citizens. Birthright citizenship was eventually afforded to residents of other U.S. territories — Puerto Rico, the U.S. Virgin Islands, Guam and the Northern Mariana Islands. Congress considered it for American Samoa in the 1930s, but declined. Some lawmakers cited financial concerns during the Great Depression while others expressed patently racist objections, according to a 2020 article in the American Journal of Legal History. Supporters of automatic citizenship say it would particularly benefit the estimated 150,000 to 160,000 nationals who live in the states, many of them in California, Hawaii, Washington, Oregon, Utah and Alaska. 'We pay taxes, we do exactly the same as everybody else that are U.S. citizens,' Smith said. 'It would be nice for us to have the same rights as everybody here in the states.' Legal questions over status to be tested anew But many in American Samoa eventually soured on the idea, fearing that extending birthright citizenship would jeopardize its customs — including the territory's communal land laws. Island residents could be dispossessed by land privatization, not unlike what happened in Hawaii, said Siniva Bennett, board chair of the Samoa Pacific Development Corporation, a Portland, Oregon-based nonprofit. 'We've been able to maintain our culture, and we haven't been divested from our land like a lot of other indigenous people in the U.S.,' Bennett said. In 2021, the 10th U.S. Circuit Court of Appeals declined to extend automatic citizenship to those born in American Samoa, saying it would be wrong to force citizenship on those who don't want it. The Supreme Court declined to review the decision. Several jurisdictions across the country, including San Francisco and the District of Columbia, allow people who are not citizens to vote in certain local elections. Tafilisaunoa Toleafoa, with the Pacific Community of Alaska, said the situation has been so confusing that her organization reached out to the Alaska Division of Elections in 2021 and 2022 to ask whether American Samoans could vote in state and local elections. Neither time did it receive a direct answer, she said. 'People were telling our community that they can vote as long as you have your voter registration card and it was issued by the state,' she said. Finally, last year, Carol Beecher, the head of the state Division of Elections, sent Toleafoa's group a letter saying American Samoans are not eligible to vote in Alaska elections. But by then, the voting forms had been signed. 'It is my hope that this is a lesson learned, that the state of Alaska agrees that this could be something that we can administratively correct,' Toleafoa said. 'I would say that the state could have done that instead of prosecuting community members.'
Yahoo
an hour ago
- Yahoo
1 Magnificent Pipeline Stock Down Nearly 20% to Buy and Hold Forever
At its current share price, Energy Transfer's distribution yields more than 7%, and the payouts have been growing. It has greatly improved its balance sheet and contract structure over the past few years. The master limited partnership has strong growth opportunities ahead of it. 10 stocks we like better than Energy Transfer › One of my favorite pipeline stocks to buy right now is Energy Transfer (NYSE: ET), and investors can pick up the master limited partnership (MLP) on sale, with shares trading down nearly 20% from their high as of this writing. In fact, the stock is one of my largest holdings. Here's why Energy Transfer is a great stock to buy and hold for the long term. Energy Transfer has built one of the largest integrated midstream systems in the U.S., handling the transport, storage, and processing of natural gas, crude oil, natural gas liquids (NGLs), and refined products. Its scale enables it to benefit from rising volumes across the energy value chain, as well as take advantage of price spreads across regions, seasons, and products. For instance, natural gas prices often rise in winter and can vary across the country. Energy Transfer can profit by storing gas ahead of periods of peak demand or by moving it from lower-priced to higher-priced markets. The company also upgrades certain hydrocarbons into more valuable end products. This kind of integrated footprint is hard to replicate, and it makes growth opportunities easier to take advantage of. With a strong position in Texas and the Permian Basin, Energy Transfer has access to low-cost associated gas, putting it in a solid spot to benefit from trends like the country's rising liquefied natural gas (LNG) exports and growing electricity demand tied to the AI infrastructure build-out. Given the opportunities in front of it, Energy Transfer has transitioned into growth mode. It plans to spend around $5 billion in growth capital expenditures (capex) this year, up from $3 billion in 2024. One of its major projects is the Hugh Brinson pipeline, which will transport natural gas out of the Permian to help meet growing natural gas demand in Texas stemming from new AI data center construction. It also signed a deal with data center developer Cloudburst to directly provide natural gas to its AI-focused data center development in central Texas. The company has also received inquiries from more than 60 power plants regarding new connections in 14 states, and requests from more than 200 data centers. Energy Transfer also appears ready to make a final investment decision on its long-awaited Lake Charles, Louisiana, LNG facility. It signed a deal with MidOcean Energy to fund 30% of the project's construction costs in exchange for 30% of the facility's LNG production if the project goes through, while it has also signed several sale and purchase agreements with potential customers. Demand for LNG continues to grow rapidly, with much of the new demand coming from Asia. Shell recently projected that global LNG demand could climb by 60% by 2040, driven both by Asian growth and a broader push for lower-emission energy sources for segments like heavy industry and transportation. Energy Transfer is also in a strong financial position. Building pipelines and other midstream assets is a capital-intensive business, and in 2020, the company cut its distribution in half to reduce leverage and improve its balance sheet. However, its distribution is now above where it was before that cut, and its leverage ratio is toward the low end of its target range of 4 to 4.5 times its adjusted EBITDA (earnings before interest, taxes, depreciation, and amortization). In fact, the company recently said it was in the best financial shape in its history. On top of its solid balance sheet, the MLP is also in a good position from a contract standpoint. This year, it expects about 90% of its EBITDA to come from fee-based services, meaning it's largely insulated from swings in commodity prices and spread differentials. Additionally, the company said it now has its highest-ever percentage of take-or-pay contracts, which means it gets paid whether or not customers actually use its services. Fee-based contracts with take-or-pay provisions increase the stability of its cash flows and support its distributions. Currently, the company is paying a quarterly distribution of $0.3275 per share, which at recent share prices is good for a forward yield of 7.3%. Management has said it's looking to grow its distribution by 3% to 5% annually. The distribution is well covered. Its distributable cash flow (operating cash flow minus maintenance capex) was more than twice its distribution last quarter. In addition to Energy Transfer being in a strong financial position with growing opportunities, the stock is also cheap on both a historical and relative basis, trading at a forward enterprise-value-to-EBITDA multiple of just 8. Between 2011 and 2016 (before the pandemic), midstream MLPs traded at an average multiple of 13.7, and the stock currently trades at a lower valuation than most of its peers. Now, Energy Transfer is not a risk-free investment. The company carries debt, and falling commodity costs and macroeconomic headwinds can take a toll on fossil fuel volumes. However, given its improved contract structure and balance sheet, along with its current growth opportunities, Energy Transfer's stock should provide investors with both an increasing income stream and solid price appreciation potential. That makes it a magnificent stock to buy and hold for the long run. Before you buy stock in Energy Transfer, consider this: The Motley Fool Stock Advisor analyst team just identified what they believe are the for investors to buy now… and Energy Transfer wasn't one of them. The 10 stocks that made the cut could produce monster returns in the coming years. Consider when Netflix made this list on December 17, 2004... if you invested $1,000 at the time of our recommendation, you'd have $674,395!* Or when Nvidia made this list on April 15, 2005... if you invested $1,000 at the time of our recommendation, you'd have $858,011!* Now, it's worth noting Stock Advisor's total average return is 997% — a market-crushing outperformance compared to 172% for the S&P 500. Don't miss out on the latest top 10 list, available when you join . See the 10 stocks » *Stock Advisor returns as of June 2, 2025 Geoffrey Seiler has positions in Energy Transfer, Enterprise Products Partners, and Western Midstream Partners. The Motley Fool recommends Enterprise Products Partners. The Motley Fool has a disclosure policy. 1 Magnificent Pipeline Stock Down Nearly 20% to Buy and Hold Forever was originally published by The Motley Fool
