Ninth Circuit Says Washington Man Can Continue To Sue CBP Agent For First, Fourth Amendment Violations

from the stock-up-on-the-redress-while-you-can! dept

The Ninth Circuit Court of Appeals continues to do what other circuits far too often won't: protect citizens from their government. The Ninth Circuit is the best place to bring allegations of rights violations. It only grants immunity in 42% of cases it handles, compared to the Fifth Circuit, where cops and their qualified immunity triumph 64% of the time.

This seems to irritate the Supreme Court, which often finds itself overturning decisions bubbling up from the Ninth. But every win for Americans is another chance to establish precedent making it easier for future victims to obtain redress from courts anywhere in the nation.

This recent decision [PDF] by the Ninth will probably once again raise the hackles of the Supreme Court. This one allows a plaintiff to sue federal officers for rights violations -- something the Supreme Court has repeatedly made more difficult to accomplish. In 2017, the Supreme Court said non-US persons couldn't sue federal officers for violating their rights. It reinforced this decision in 2019, rejecting a lawsuit brought by the family of a Mexican teen who was shot ten times by a Border Patrol agent in response to some alleged rock throwing. The Border Patrol agent was on the US side of the border. His bullets traveled across the border and into the Mexican teen, killing him in Mexico. The Supreme Court shrugged and said it was unfortunate the teen died where he did. If he had only managed to die on the US side of the border, he might have had a case.

This case doesn't end in death. But it does involve federal border security and violated rights. Here's the summary of the events leading to the lawsuit:

[Robert] Boule is a United States citizen. He owns, operates, and lives in a small bed and breakfast inn in Blaine, Washington. The back property line of the land on which the inn is located touches the United States-Canada border. On March 20, 2014, Customs and Border Patrol Agent Erik Egbert stopped Boule while he was running errands “in town” and asked him about guests staying at the inn. Boule told Egbert that he had a guest arriving that day from New York who had flown in from Turkey the day before. Boule told him that two of his employees were en route to pick up the guest at SeattleTacoma (“Sea-Tac”) International Airport, about 125 miles south of Blaine. Later that day, Egbert waited in his border patrol vehicle near the inn. The entrance to the inn is on a road at the front of the property. When the guest arrived, Egbert followed the car carrying the arriving guest into Boule’s driveway.

Egbert got out of his vehicle and approached the car. From the front porch of the inn, Boule asked Egbert to leave. When Egbert refused, Boule stepped between Egbert and the car and again asked him to leave. Boule recounts that Egbert then shoved him against the car. When Boule still did not move away from the car, Egbert grabbed him and pushed him aside and onto the ground.

Egbert then opened the car door and asked the guest about his immigration status. Boule made a 911 call to request a supervisor, which Egbert also relayed over dispatch. A supervisor and another agent arrived in response to the call. After concluding that the guest was lawfully in the country, the three officers departed. Boule later sought medical treatment for injuries to his back.

That's the Fourth Amendment violation. There's also a First Amendment violation.

After Boule complained to Egbert’s superiors about the incident, Egbert retaliated against Boule. Among other things, Egbert contacted the Internal Revenue Service, asking the agency to look into Boule’s tax status.

Bringing a Bivens case against a federal officer is tricky. Federal officers are given an extra level of protection from lawsuits. Qualified immunity is pretty tough to dodge, given the reliance on (ever-decreasing) precedential rulings declaring specific actions to be rights violations. In the federal context, the small crack in the immunity door disappears almost completely. More matching specifics are needed to move a case past the immunity roadblock and only certain rights violations are recognized in the Bivens context.

Here's how the Supreme Court sees it: allegations that fall into this broad set of variances may be considered "new" and an impermissible extension of Bivens.

Without endeavoring to create an exhaustive list of differences that are meaningful enough to make a given context a new one . . . [:] A case might differ in a meaningful way because of the rank of the officers involved; the constitutional right at issue; the generality or specificity of the official action; the extent of judicial guidance as to how an officer should respond to the problem or emergency to be confronted; the statutory or other legal mandate under which the officer was operating; the risk of disruptive intrusion by the Judiciary into the functioning of other branches; or the presence of potential special factors that previous Bivens cases did not consider.

Good luck with that, plaintiffs. But this plaintiff's case will move on, greatly aided by the fact that he's a US citizen. Unlike the cases cited by the government, Boule is a legal resident of the United States. There's only one factor that separates this from other successful Bivens lawsuits, the court points out.

The claim against Egbert is a conventional Fourth Amendment claim, indistinguishable from countless such claims brought against federal, state, and local law enforcement officials, except for the fact that Egbert is a border patrol agent.

The court says the fact that Egbert is a border patrol agent does not excuse him from this lawsuit, even if a comparable case involved an FBI agent. The plaintiff can continue suing Egbert over his Fourth Amendment violations.

But the court goes further, extending Bivens to cover both the Fourth Amendment violation and an alleged First Amendment violation.

Boule also alleges that Egbert retaliated against him for exercising his First Amendment right to complain to Egbert’s superiors about his conduct at the inn. We have previously recognized a Bivens claim in the First Amendment context, see Gibson v. United States, 781 F.2d 1334, 1342 (9th Cir. 1986), but the Supreme Court has not yet done so.

[...]

However, we find no special factors that counsel hesitation in extending a Bivens remedy to this new context. There is even less reason to hesitate in extending Bivens here than in the context of Boule’s Fourth Amendment claim. Retaliation is a well-established First Amendment claim, available against governmental officers in general.

And, while Egbert may find a way to prevail on the Fourth Amendment allegations by discussing the latitude granted to him as a nominal securer of the nation, he's going to have to get really creative to explain why he decided to retaliate against a citizen's protected speech.

With respect to [the Fourth Amendment] claim, Egbert can legitimately argue that his actions at the inn were performed in connection with his official duties. He cannot say the same thing here, for his retaliation had no relation to, or justification based on, his duties as a border patrol agent.

This ruling increases the chances of success in lawsuits brought against federal agents and officers, and expands the minimal coverage to include rights violations that haven't previously been addressed in this circuit. But, because it does this, there's no chance this won't be appealed. The Supreme Court doesn't like lower courts expanding the narrow Bivens confines, so this has a good chance of getting overturned if the top court picks it up. Until then, it's still a win for Boule and other US citizens. And maybe this win will remain on the books if the Supreme Court feels it's been cutting the government way too much slack in cases like these.

Filed Under: 1st amendment, 4th amendment, 9th circuit, bivens claim, border patrol, cbp, erik egbert, qualified immunity, robert boule, washington

'Tis The Season: Congress Looks To Sneak In Unconstitutional Copyright Reform Bill Into 'Must Pass' Spending Bill

from the if-you-have-to-sneak-around... dept

If you have to sneak your transformational copyright bill into a "must pass" government spending bill, it seems fairly evident that you know the bill is bad. Earlier we talked about how the White House is trying to slip a Section 230 repeal into the NDAA (military appropriations) bill, and now we've heard multiple people confirm that there's an effort underway to slip the CASE Act into the "must pass" government appropriations bill (the bill that keeps the government running).

What does keeping the government running have to with completely overhauling the copyright system to enable massive copyright trolling? Absolutely nothing, but it's Christmas season, and thus it's the time for some Christmas tree bills in which Senators try to slip in little favors to their funders by adding them to must-pass bills.

We've detailed the many problems with the CASE Act, including how it would ratchet up copyright trolling in a time when we should actually be looking for ways to prevent copyright trolling. But the much larger issue is the fact that the bill is almost certainly unconstitutional. It involves the executive branch trying to route around the courts to set up a judicial body to handle disputes about private rights. That's not allowed.

At the very least, however, there are legitimate concerns about the overreach of the CASE Act, and, as such, those supporting it should at least be willing to discuss those issues honestly and debate them fairly. Slipping them into a must-pass government spending bill certainly suggests that they know that they cannot defend the bill legitimately, and need to cheat to make it law.

Filed Under: appropriations, case act, christmas tree bill, copyright, copyright troll, must pass, spending

World's Worst Copyright Troll, Richard Liebowitz, Suspended From Practicing Law

from the revealed-in-a-new-benchslap dept

I had meant to write an update on the never ending clusterfuck that is copyright troll Richard Liebowitz last month, as things appeared to be going badly in the two cases where the judges had clearly grown completely tired of the games he was playing with the court: Usherson v. Bandshell and Chevrestt v. Barstool. In both cases, judges had gotten very, very angry at Liebowitz for continuing to lie, play games, mislead and so on. In the Chevrestt case, the judge actually let him off kind of easy last month, saying that for the next two years, any time that he is ordered to show cause for why he shouldn't be sanctioned again (basically, any time he gets in trouble with a judge), he has to share the details of what happened in the Chevrestt case (in which he does not come out of it looking good).

But the bigger story is in the Usherson case, where this week, Judge Jesse Furman mentions in passing that the Southern District of New York's Grievance Committee had issued an order suspending Liebowitz "from the practice of law before this Court." This is temporary, pending "final adjudication of the charges against [him]" so it's likely to get worse. Also, it only applies to SDNY, but that's where he's filed so many of his cases, and the stink over his practically non-stop sketchy behavior in court will follow him everywhere else. It's not clear exactly which of the many problems that Liebowitz has brought upon himself resulted in the Grievance Committee acting, but the list is very long.

In fact, it's rather convenient that it's Judge Furman who is revealing the suspended license, given that he was the one who catalogued the dozens upon dozens of times that Liebowitz had been caught lying to courts or has been sanctioned for lying to courts.

As you may recall, Judge Furman laid out those details in an order telling Liebowitz to file a copy of that order with every case that he was involved with. Liebowitz, in true Liebowitz fashion, waited until the last minute to whine that this was unfair and a violation of his rights. The judge was not impressed and neither was the appeals court.

Liebowitz then had one day to send a copy of Judge Furman's order to every one of his clients and to every court in which his cases were being heard. At the time, we pointed to at least one case where the order had not been filed, but we had heard from a few lawyers in other cases that no such filing had been made either. And those lawyers weren't just telling me: they told Judge Furman as well. At the beginning of October, Judge Furman asked Liebowitz to file a declaration addressing why he hadn't filed the order in some cases (and why he had filed it late in others). Liebowitz then filed quite an amazing declaration on October 15th, explaining how and why he had failed to file the order in 113 different cases. In typical Liebowitz fashion, he had excuses for all of them. He blamed PACER (which we agree is a terrible service), but he also admits that he never thought to use his case management system -- the one he'd been forced to install a year earlier as part of sanctions in another case (the one where he blamed the death of his grandfather for failing to appear in court, and then lied about the actual date of his grandfather's death). That case also involved the judge referring Liebowitz to the Grievance Committee.

Other excuses Liebowitz gave for not filing the order in cases was that he thought some cases were completely over and just missed that they had motions pending. Some cases he closed out between the time the original order was made and his attempted compliance with them. And then there were some cases which he argued he was more peripherally than directly involved in them.

Either way, Judge Furman, finds this literally unbelievable.

Had Mr. Liebowitz failed to file the Opinion and Order in a handful of cases, the failure to comply might have been understandable and excusable. But the failure to file it in 113 cases is astonishing and suggests contumaciousness, an egregiously disorganized case management system, or both. It is all the more astonishing in light of Mr. Liebowitz’s record, set forth in painstaking detail in the Court’s Opinion and Order, and his repeated representations to Judges — in this District and beyond — that he had taken steps to improve his case management practices.

Contumaciousness is a good word. Look it up.

Basically, Judge Furman notes that Liebowitz has not shown any real evidence that he's changed. At all. And thus, it's clear that the judge believes that Liebowitz deserves further sanctions. However, as he notes, the sanctions should be designed to lead to correction of the bad behavior -- and thanks to the Grievance Committee's suspension of Liebowitz's license, there's not a current threat of this behavior continuing.

That said, the ultimate purpose of sanctions is deterrence... and, as Mr. Liebowitz’s extraordinary record of both sanctions and noncompliance with court orders demonstrates, it is far from clear that there is any additional sanction that would serve to deter him. Moreover, on November 30, 2020, this Court’s Grievance Committee — noting Mr. Liebowitz’s “repeated disregard for orders from this Court and his unwillingness to change despite 19 formal sanctions and scores of other admonishments and warnings from judges across the country” — entered an Amended Order immediately suspending Mr. Liebowitz “from the practice of law before this Court pending final adjudication of the charges against [him].” In re Liebowitz, No. M-2-238, at 1-2 (S.D.N.Y. Nov. 30, 2020). Thus, for the time being, there will be nothing to deter when it comes to Mr. Liebowitz.

Accordingly, and in light of the Grievance Committee’s Order of November 25, 2020, the Court, exercising its discretion, determines that additional sanctions are not appropriate at this time.

However, just in case, Judge Furman clarifies that when he said that Liebowitz had to file the order in all of his cases, he did mean all of them, and amends the original order to make that abundantly clear and to make sure that Liebowitz cannot wriggle free from complying.

All in all, there seems to be a decent chance that Richard Liebowitz will no longer be practicing law.

Filed Under: copyright, copyright troll, grievance committee, jesse furman, richard liebowitz, sdny

Utter Insanity: Trump Lawyer Suggests Former Trump Cybersecurity Official Should Be 'Taken Out And Shot' For Saying The Election Was Secure

from the what-is-wrong-with-these-people? dept

Every day that I think I can't be shocked and horrified by anything being done in the name of politics today, I end up being more shocked and more horrified. The latest is that one of the President's campaign lawyers, Joe diGenova, who has been involved in a wide range of politically motivated conspiracy theory mongering, went on the Howie Carr show to say that fired CISA director Chris Krebs should be "taken out and shot."

There's a lot to unpack here. First off, we wrote about Krebs being fired by Trump for daring to contradict the narrative that the election was rigged. Krebs is one of a very few Trump appointees who was widely respected across the political spectrum. In his years running the newly created Cybersecurity and Infrastructure Security Agency (CISA), he'd been praised by many for the job he had done in actually dealing with cybersecurity threats, and coordinating information sharing about such threats to the private sector.

But him telling the truth and debunking the politically motivated nonsense the President and his dwindling team of supporters are trying to spew, apparently means that Krebs has been cast out as the enemy. Making matters worse (for Trump and his supporters) was that on Sunday, 60 Minutes had Krebs on, in which he made a very credible case that the President was just making shit up in claiming that there was interference or malfeasance in the election. In fact, in that interview, Krebs highlighted the death threats that are being made against election officials, rightly calling it "a travesty" that public servants are put through this nonsense.

And it's, in my view, a travesty what's happening right now with all these death threats to election officials, to secretaries of state. I want everybody to look at Secretary Boockvar in Pennsylvania, Secretary Benson in Michigan, Secretary Cegavske in Nevada, Secretary Hobbs in Arizona. All strong women that are standing up, that are under attack from all sides, and they're defending democracy. They're doin' their jobs. Look at-- look at Secretary Raffensperger in Georgia, lifelong Republican. He put country before party in his holding a free and fair election in that state. There are some real heroes out there. There are some real patriots.

And now Krebs is facing the same nonsense.

Howie Carr, the host of the show is a long time, Boston-based, Trump-supporting talk show host and columnist. He had diGenova on his show, which was simulcast to Newsmax (one of the two Trump-loving TV networks trying to take over the insane conspiracy theory pushing crown from Fox News) and allowed diGenova to say that Krebs should be killed. Carr doesn't appear to have the video of it up on his own YouTube channel yet, but MediaMatters has the clip that you can see for yourself.

diGenova: This was not a coincidence. This was all planned. And anybody who thinks the election went well, like that idiot Krebs who used to be the head of cybersecurity for DHS.

Carr:: Oh yeah, the guy who was on 60 Minutes last night.

diGenova: That guy... that guy is a class A moron. He should be drawn and quartered. Taken out at dawn and shot,

Carr then chuckles for a bit before changing the subject.

Let's be totally clear: this is offensive and dangerous. It would be offensive and dangerous coming from anyone, but the fact that it's coming from a lawyer currently representing the President of the United States is completely and utterly terrifying. No, it almost certainly doesn't reach the "true threats" test of the Supreme Court to be speech not protected by the 1st Amendment, but that doesn't mean it's not wildly inappropriate and dangerous.

I understand that Trump's circle of grifters and hanger-ons will not let truth, accuracy, or common decency stand in the way of spreading their cult of bullshit, lies, FUD, and nonsense, but the rest of the country ought to speak up and make it clear that this is totally unacceptable. And that includes Republicans in Congress who have continued to try to look the other way or pretend that what Trump and his band of legal misfits are doing is totally normal and acceptable. It is not.

Filed Under: chris krebs, election security, elections, howie carr, joe digenova, rhetoric

Daily Deal: iMazing iOS Device Manager

from the good-deals-on-cool-stuff dept

iMazing calls itself the Swiss Army Knife of iOS device management because it lets you truly manage your mobile data the way you want to. This all-purpose tool lets you easily browse and manage your backups, extract and print your text messages, drag and drop songs to your iPhone - all without jailbreaking your device. Licenses are for sale for 2 devices at $20, 3 devices at $25, or 5 devices at $30.

Note: The Techdirt Deals Store is powered and curated by StackCommerce. A portion of all sales from Techdirt Deals helps support Techdirt. The products featured do not reflect endorsements by our editorial team.

Filed Under: daily deal

White House Still Pushing To Slip Section 230 Repeal Into 'Must Pass' Military Spending Bill

from the what-the-actual-fuck? dept

This was rumored a week and a half ago, and at the time I stated that there was no way in hell it was happening, and that it was all just performative nonsense... but yesterday Axios reported that the White House is still pushing Congress to insert a total repeal of Section 230 into the "must pass" National Defense Authorization Act (NDAA). At the time, the story was that Trump would make a trade: he wouldn't veto the bill over a provision that removed Confederate army names from US military bases if there was a full repeal of Section 230 in it.

This is silly for all sorts of reasons, including the idea that you're horse trading the law that helped create the open internet for racist military base names in a bill that has fuck all to do with internet/telecom policy. Of course, then Thanksgiving happened, and the President threw a total shitfit because #DiaperDon started trending on Twitter, making him declare that we had to repeal Section 230 for "national security." Seems more like it would be for dealing with the insecurity of the President of the United States.

And so it appears that the White House has decided to appease the whims of the mad child emperor, and is still pushing Congress to slip the repeal into the NDAA and hoping that the confused, misplaced, and somewhat contradictory bipartisan hatred for Section 230 will cause them to go with it. Incredibly, Axios notes that it's the Republicans in the Senate trying to talk the White House out of this plan -- though they're pushing a bunch of nonsense 230 reform bills as an "alternative." The article's only comment on Democrats is that they "are sure to object." And I think that will still doom this entire effort. But, the real goal seems to be to try to sneak through some terrible bills that are short of a full repeal.

But Senate Republicans are instead trying to negotiate an alternative that would combine multiple bills aimed at reforming the law, including the bipartisan Platform Accountability and Consumer Transparency Act and Wicker's Online Freedom and Viewpoint Diversity Act, a Hill source familiar with the matter told Axios.

We've gone through the details of why all of those bills are garbage and/or unconstitutional, and even if there were legitimate movement on getting those bills through Congress, lighting up the NDAA with them is the exact wrong thing to do. Bills like these, that would fundamentally change the very nature of the internet, are not something you just hang on an appropriations bill at the last minute.

I'm still mostly confident that none of this is actually going to happen and that it's still all just insane posturing and performative nonsense. But it's still 2020, and crazy, unprecedented shit still keeps happening, so I'll back down slightly from my "no way in hell" statement, and note that we're in hell right now, and so there's still a small chance that something horrific would happen here. It's still very, very unlikely. But it's just not going away.

Filed Under: confederate bases, donald trump, horse trading, intermediary liability, names, ndaa, section 230, white house

Verizon, NYC Settle Lawsuit Over Verizon's Empty Fiber Promises

from the day-late-dollar-short dept

Like AT&T, Frontier, and other U.S. telcos, Verizon has a long, rich history of taking tax breaks, regulatory favors, and taxpayer subsidies in exchange for networks it only half deploys. That was the case in the 90s when Verizon took a several billion tax breaks from the state of Pennsylvania in exchange for networks it never deployed. It was also the case in New York City, where Verizon was sued by the city for promising to deploy fiber universally to all five boroughs, and then, well, not doing that.

In 2017, NYC sued Verizon, stating a 2014 deal to deploy fiber to the entire city fell well short of the full goal. As some local reporters had warned at the time (and were promptly ignored), the city's deal with Verizon contained all manner of loopholes allowing Verizon to wiggle over, under and around its obligations. And wiggle Verizon did; a 2015 city report found huge gaps in deployment coverage -- particularly in many of the less affluent, outer city boroughs.

Last week during the holiday bustle the city quietly announced it had settled its lawsuit with Verizon. Under the confidential settlement, the city claims Verizon will expand fiber deployment to an additional 500,000 low income homes across the city:

"This settlement will make sure that Verizon builds out its fiber footprint more equitably throughout New York City — especially in low-income communities that have historically been underserved by internet service providers,” said DoITT Commissioner and Citywide CIO Jessica Tisch. “This agreement attacks that unfair imbalance, and recognizes that high-quality internet is a necessity, not a luxury."

The problem, as usual, will be in the follow up. The original lawsuit (pdf) stated that Verizon had deployed fiber to 2.2 million out of the city's 3.3 million residences with FiOS, despite the original 2008 agreement with the city calling for "100%" FiOS availability. An additional 500,000 deployed homes sounds good, especially during a pandemic, but it's still a far cry from the company's original promise to the city. The city likely found the lawsuit to be too costly or unwinnable, and with so much else going on, agreed to settle and at least get something for its efforts.

Granted this isn't just some one-off problem. Telecom giants are so politically powerful (on both the state and federal level) that genuine accountability for failed promises is extremely hard to come by. One simply needs to look at the long list of cities and states that have accused the company of taking subsidies and tax breaks then failing to evenly deploy fiber, whether it's Philadelphia or a huge swath of New Jersey. And again, you'll find much the same story having played out with telco giants like AT&T and Frontier Communications from Mississippi to West Virginia.

As we've noted for a long time, policymakers act as if U.S. broadband mediocrity is just something that happens or is due to America just being really, really big. In reality, the reason U.S. broadband is patchy, expensive, with atrocious customer service? Plain old state and federal corruption we often refuse to even acknowledge, much less do anything about.

Filed Under: broken promises, digital divide, fiber, fios, internet access, new york city, promises, subsidies
Companies: verizon

GTA5: A Living World Eyeing A Decade Of Rabid Play Instead Of Just A 'Game'

from the ongoing-trends dept

A little over five years ago, I wrote about the seeming emergence of a new trend in the video game space: living and evolving game worlds instead of single-serving "games". While MMOs and other online games certainly weren't new even then, what with World of Warcraft having a decade under its belt at that point, the post did focus on several game publishers beginning to make noises about focusing on these breathing ongoing experiences rather than selling shiny discs, or even digital downloads of one-and-done games. And if that trend became the norm, it really would change the industry. Development cycles for the release of games wouldn't so much be a thing compared with the ongoing and time-spanning development that would go into consistently creating new experiences within an existing game. For those interested in the gaming industry, or those concerned with how traditional development cycles and "crunch" have impacted design labor, this really could be something of an inflection point.

Five years later, this trend has only gotten more prevalent. There are many examples of living, breathing game worlds out there to choose from, but the example I will use is Grand Theft Auto 5, which has been an active hit for so long that it literally passed by a console generation. The game was originally released in 2013 as a single-player game, only to have its online component launch shortly after, putting it in the ongoing development cycle.

Grand Theft Auto V, in case you forget, was first released on the Xbox 360 and PS3 in September 2013. It didn’t arrive on the PS4 and Xbox One until 2014.

Let that wash over you for just a second. A single video game that was released before the PS4 and Xbox One even hit the shelves has remained both culturally relevant and commercially successful throughout those console’s entire lifetimes, and will now see an even longer shelf-life once it is released on the PS5 and Xbox Series X.

To give you an idea of just how long ago that was, the game was released with a trailer that spoke to America’s attempts to recover from its last financial meltdown, and there’s been time to have had another since. Other games on the best-selling list for September 2013 include Diablo III, Disney Infinity and Saints Row IV.

And, again, the game is still in active development, both on the online and first-person side of things. There will be an updated version of the game that comes out on the next generation of consoles, while the online community is still actively involved and playing in all of the new updates and releases Rockstar has continued to create.

The success of the game has far-reaching implications. Rockstar Games, with its own notorious reputation of putting its developers through so-called "crunch" periods, notably isn't suffering from a ton of stories of crunch when it comes to the developers of the ongoing GTA5 world. Which makes sense: the deadlines are more squishy than getting out a AAA single-player game. It also means potentially less individual games coming out, which may be a good or bad thing depending on your perspective. For reference, The PS2-era of consoles saw three GTA games get released, while the PS3 had 2 and the PS4's only GTA game was the port of GTA5.

All of that is because the development efforts are going into a lasting game with a ton of gaming participation, even seven-plus years after its release. If the gaming public is happy enough with that, then so be it. But it's going to change the industry as this trend continues.

Filed Under: evolving worlds, gta5, trends, video games, world building