Parole and Probation Violators Account for 45% of State Prison Admissions: Study

Leading state corrections chiefs say a new report showing that 45 percent of prison admissions nationwide  are driven by violations of parole or probation is forcing them to rethink their approach to community supervision.

The report released Tuesday by the Council of State Governments (CSG) Justice Center represents the first state-by-state analysis of the issue. According to the report, the high numbers of individuals sent back behind bars either for new crimes or simply for breaking supervision rules adds a huge burden for taxpayers and conflicts with the goal of reducing recidivism.

“This has forced us to look at our rules,” said John Wetzel, Secretary of the Pennsylvania Department of Corrections.

Wetzel noted that the CSG report showed Pennsylvania spent over $100 million on tracking parole violators.

”If we need to spend $100 million to ensure that the citizens of Pennsylvania were safe we would do that,” he said in a conference call in advance the report’s release.

“But the reality of it is that often times, these technical parole violations—when they result in incarceration—really lead to further crime and further violations.”

The report, Confined and Costly: How Supervision Violations are Filling Prisons and  Burdening Budgets, found that 25 percent of prison admission nationally were the result of technical violations such as failed drug tests or missed curfews.

“No one thinks people should be sent to prison for a missed curfew or faulty paperwork, and yet this report shows these kinds of minor technical violations are contributing significantly to state prison populations,” said Julienne James, director of criminal justice for Arnold Ventures, which provided funding for the analysis.

“This should serve as a wakeup call that our probation and parole systems are not healthy, not functioning as intended, and need to be reformed.

In Tuesday’s conference call, Anne Precythe, director of the Missouri Department of Corrections, said her state plans to implement this month a  “behavior matrix” which refines the tools used by community supervision authorities to assess whether a given violation merits a return to prison.

“(The CSG ) report is really going to help us get our story out there.”

In Missouri more than half of prison admissions are due to technical violations, Precythe said.

Taxpayers are footing a huge bill, according to the report, froim a practice that, on any given day, leaves nearly 280,000 people in prison as a result of supervision violations—and costs over $9 billion annually.

For a copy of the report, including a tool that allows numbers to be broken down by state, please click here.

TCR News Intern Brian Demo contributed to this summary. 

via The Crime Report

June 19, 2019 at 10:11AM

Celebrated Cop Was Robbing Drug Dealers

Baltimore police officer Wayne Jenkins was living a double life. He was an admired leader of aggressive street squads and would head the elite Gun Trace Task Force, one of the Baltimore Police Department’s go-to assets in the fight against violent crime. He was also the ringleader of a criminal enterprise of police officers who robbed people and sold drugs, reports the Baltimore Sun. The indictment of Jenkins and six of his officers on federal racketeering charges rocked Baltimore in 2017. A squad of veteran cops stood accused of committing numerous robberies, as well as extortion and overtime fraud. Many Baltimore residents had long distrusted the police, and more so after the death of Freddie Gray. The scope and breadth of these allegations were staggering.

Inside the police department, the Gun Trace Task Force was known for its success in capturing suspected drug dealers, their stashes and their illegal firearms. Jenkins was celebrated as a leader with an uncanny knack for delivering the goods. If his arrest was stunning, the depiction of his crimes wasn’t news to everyone. Some drug dealers told their lawyers that Jenkins made stuff up to arrest them and had kept a good chunk of their money and drugs. A Sun investigation found warning signs that Jenkins wasn’t such a good cop. His supervisors either failed to see the red flags or chose to ignore them. From 2006 to 2009, Jenkins was the subject of at least four lawsuits alleging misconduct. The plaintiffs prevailed in three of them, but they  triggered no internal punishment. Jenkins’ supervisors failed to scrutinize arrests he was making. He was getting suspects off the street, but his cases weren’t holding up in court. Reporter Justin Fenton spent a year investigating Jenkins and his officers. He is writing a book about the case.

via The Crime Report

June 18, 2019 at 11:26AM

Trump Won’t Apologize for Central Park Five Role

President Trump doubled down on his controversial stance on the Central Park Five, a group of black and Latino teenagers who were wrongly convicted of an assault on a white female jogger in Central Park in 1989, USA Today reports. Trump was asked by American Urban Radio Networks reporter April Ryan whether he’d apologize to the men for taking out newspaper ads calling for their execution. All five were exonerated in 2002 after Matias Reyes confessed to raping the woman, a statement backed up by DNA evidence.

At first, Trump was defensive, asking Ryan, “Why would you bring that question up now? It’s an interesting time to bring it up.” The reporter responded that there were “movies and everything about them,” referring a new Netflix TV series about the Central Park Five. “You have people on both sides of that. They admitted their guilt,” Trump said. “If you look at Linda Fairstein and if you look at some of the prosecutors, they think that the city should never have settled that case. So we’ll leave it at that.” Fairstein, the top New York City sex crimes prosecutor at the time, has come under scrutiny in the Netflix series, entitled, “When They See Us.” Trump spent $85,000 to take out a newspaper ad calling for the teenagers’ executions.

via The Crime Report

June 19, 2019 at 08:45AM

Lawyer bitten by shark endures the inevitable jokes

By Debra Cassens Weiss

Georgia personal injury lawyer Gene Brooks is hearing lawyer shark jokes from colleagues and friends as he recovers from a shark bike that sent him to the emergency room.

Brooks, a Savannah lawyer, says a shark bit him as he was swimming in the Wilmington River on Sunday, report Savannah Now and the State. He received 23 stitches, 20 of them in his arm and three in his chest.

Experts say the likely culprit was a bull shark that can survive in fresh and salt water, according to the State. The shark may have mistaken Brooks for food because of murky waters caused by heavy rain.

“It all happened so fast. I was about 20 feet away from the dock when it hit me,” Brooks told Savannah Now. “I felt like I got punched, which is what I’ve always heard a shark does. I hollered and skedaddled over to my boat, which was tied to the dock. I pulled the ladder down and climbed in.”

Brooks told the State that the shark likely decided it didn’t want Brooks after discovering he was too bony. “It wasn’t a full bite, but the teeth hit me in the chest and underneath my arm,” he said.

He told Savannah Now that he’s grateful that his injuries weren’t more serious.

“It scared me, but I feel real lucky,” Brooks said, a day after the run-in with the shark. “It didn’t hit muscle, bone or blood vessels so I’m good to go.”

According to Savannah Now, a picture on social media shows Brooks bandaged up, smiling and holding a Landshark beer provided by a neighbor. The Savannah Now story also referenced a song by Jimmy Buffett called “Fins” from the late 1970s—“he saw no fins to the left or fins to the right,” the story said. Brooks is taking the jokes in stride.

via ABA Journal Daily News

June 19, 2019 at 01:50PM

Sandy Hook families say Alex Jones’ lawyers sent discovery materials with embedded child porn

By Debra Cassens Weiss

Lawyers representing Sandy Hook families in a defamation suit against “Infowars” radio host Alex Jones say several emails turned over in discovery contained embedded images of child pornography.

The lawyers said in a court filing this week that the initial discovery was made by consultants reviewing the files, report the New York Times, Courthouse News Service, BuzzFeed News, the Hartford Courant and the Connecticut Post. The families are suing Jones over his claims that the elementary school shooting that killed 26 people was a giant hoax.

The emails were among more than 56,000 documents turned over in discovery that included “Infowars” emails that referenced the Sandy Hook shooting.

According to the court filing, the lawyers contacted the FBI after consultants found one image of child pornography while loading files into a document review database. The FBI reviewed the documents and found numerous additional images that had apparently been sent to “Infowars” email addresses, according to the filing.

“It is worth noting that if the Jones defendants had engaged in even minimal due diligence and actually reviewed the materials before production, they would have found the images themselves,” the filing said.

After the FBI review, lawyers for the plaintiffs contacted Jones’ defense lawyer, Norm Pattis. Jones responded angrily in a broadcast of his show on Friday.

The court filing says Jones’ rant amounted to threats and asks the judge to review the video. The court filing includes some quotes from Jones, including this offer of a reward:

“You’re trying to set me up with child porn, I’ll get your ass. One million dollars, you little gang members. One million dollars to put your head on a pike. One million dollars, bitch. I’m going to get your ass, you understand me now?”

Jones also pounded a picture of plaintiffs’ lawyer Chris Mattei, according to the filing. “Chris Mattei. What a good American. What a good boy,” Jones said. “You think you’ll put on me, what—[under his breath]. I’m gonna kill … [growls]. Anyway, I’m done! Total war! You want it, you got it! I’m not into kids like your Democratic Party, you [expletive]!”

Pattis said on the radio show that Jones and his staff never opened the emails, some of which were “very hostile,” according to a review by Courthouse News Service.

“Clearly they were intended as malware,” Pattis said. He also said the FBI had cleared Jones of any wrongdoing, according to the New York Times.

Jones apologized for bad language a day after the show, according to BuzzFeed News. “I’m not saying that the lawyers for Sandy Hook families set this up or did this,” Jones said. “Whoever sent this, for whatever reason, this shows the escalation and the insanity of all of this.”

Pattis told the Connecticut Post that Jones was upset but there was no threat.

via ABA Journal Daily News

June 18, 2019 at 05:07PM

Supreme Court refuses to change double jeopardy rule in case with implications for federal pardons

By Debra Cassens Weiss

Developing: The U.S. Supreme Court on Monday declined to change the long-standing rule that allows federal and state prosecutions for the same offense.

The Supreme Court ruled against Terance Gamble, who was charged with being a felon in possession of a firearm by both the federal government and the state of Alabama. NBC News and SCOTUSblog have early coverage.

Justice Samuel A. Alito Jr., wrote the majority opinion. He was joined by Chief Justice John G. Roberts Jr. and Justices Clarence Thomas, Stephen G. Breyer, Sonia Sotomayor, Elena Kagan and Brett M. Kavanaugh. Justices Ruth Bader Ginsburg and Neil M. Gorsuch filed dissenting opinions.

A contrary decision by the Supreme Court could have made it more difficult for a state to try someone who is pardoned by the president after federal trial proceedings have begun.

The case is Gamble v. United States.

via ABA Journal Daily News

June 17, 2019 at 11:13AM

Justices Rule States and Feds Can Prosecute Someone for ‘Same Crime’

The U.S. Supreme Court on Monday refused to overrule a 170-year-old exception to the constitutional prohibition against prosecuting someone more than once for the same offense.

The exception to the Constitution’s double jeopardy clause, known as the “dual sovereignty doctrine,” allows a state to prosecute a defendant under state law even if the federal government has prosecuted him or her for the same conduct under federal law.

“We have long held that a crime under one sovereign’s laws is not ‘the same offence’ as a crime under the laws of another sovereign,” wrote Justice Samuel Alito Jr. for the 7-2 majority in Gamble v. United States. “We see no reason to abandon the sovereign-specific reading of the phrase ‘same offence,’ from which the dual-sovereignty rule immediately follows.”

Alito said that fidelity to the double jeopardy clause’s text “does more than honor the formal difference between two distinct criminal codes. It honors the substantive differences between the interests that two sovereigns can have in punishing the same act.”

Justices Ruth Bader Ginsburg and Neil Gorsuch wrote separately in dissents.

“A free society does not allow its government to try the same individual for the same crime until it’s happy with the result. Unfortunately, the court today endorses a colossal exception to this ancient rule against double jeopardy,” Gorsuch wrote in his dissent.

Alito rejoined: “The United States is a federal republic; it is not, contrary to Justice Gorsuch’s suggestion, a unitary state like the United Kingdom.”

Ginsburg said in her dissent: “Different parts of the ‘WHOLE’ United States should not be positioned to prosecute a defendant a second time for the same offense. I would reverse Gamble’s federal conviction.”

Terance Gamble is an Alabama man who was convicted and sentenced in state and federal prosecutions for the same crime: felon in possession of a firearm. Gamble, represented by Jones Day partner Louis Chaiten had asked the justices to overrule a doctrine known as the “separate sovereigns” exception to the Fifth Amendment’s double jeopardy clause.

Gamble’s case initially drew considerable attention because of its potential import for Special Counsel Robert Mueller III’s possible federal prosecutions of Russian interference in the 2016 election and involvement of the Trump campaign. Without the separate sovereigns exception, states would be barred from pursuing parallel prosecutions under their state laws.

The outcome of the case was being closely watched for its potential impact on state prosecutions of Paul Manafort, the former Trump campaign manager convicted in federal court in Washington and Virginia on various financial and lobbying crimes. Separately, state prosecutors have brought charges in New York.

During arguments in December, a number of justices appeared skeptical of Chaiten’s position. Chaiten emphasized that the separate sovereigns exception was inconsistent with the original meaning of the double jeopardy clause as well as its text and purpose.

Justice Brett Kavanaugh, himself a self-described originalist, said that argument conflicted with “another part of the original understanding—stare decisis” (standing by precedent). Justice Elena Kagan told Chaiten that his argument seemed “a little bit one note” and that he needed to offer more in order to persuade her to overrule the exception.

At oral argument, Ginsburg told Assistant to the Solicitor General Eric Feigin that the separate sovereigns doctrine has been “widely criticized” by federal judges and academics.

Feigin responded that many of those critical comments also recognized that “some exceptions are necessary, and that successive prosecutions and separate prosecutions are sometimes necessary to vindicate particular sovereign interests.”

Eliminating the exception, Feigin warned, would create a host of practical problems, including deterring cooperation, encouraging aggressive prosecutions, a race to the courthouse, and defendants trying to play each sovereign against the other.

Chaiten, in rebuttal, told the court that at least 20 states do not have the separate sovereigns exception, and at least 37 with respect to certain crimes. “It also seems to have worked out okay,” he said.

Texas Solicitor General Kyle Hawkins shared argument time with Feigin on behalf of a coalition of 36 states.

Read more:

Staring Down ‘Stare Decisis’: How to Ask SCOTUS to Overturn Precedent

Breyer Denounces Ruling That Strikes Precedent, Questions Which Cases Are Next

via – Newswire

June 17, 2019 at 03:36PM

Floridians Are Suing a Cop Fired for Planting Drugs in Their Vehicles

Thanks to the diligence of one assistant state attorney, 119 cases were thrown out and the officer is under state investigation.

In October 2017, Derek Benefield was driving in the Florida Panhandle’s Jackson County when he was pulled over for allegedly swerving into the opposite lane. Once at the car, sheriff’s deputy Zachary Wester claimed to smell marijuana and conducted a search of the vehicle, which, he reported, turned up methamphetamine and marijuana. Despite insisting the drugs weren’t his, Benefield, who was already on probation, was arrested, charged $1,100 in fines and court fees, and sentenced to one year in county jail.

Benefield was seven months into his sentence when, in September 2018, the state attorney’s office dropped his case and those of 118 others. Largely thanks to the diligence of one assistant state attorney, Wester was suspected of routinely planting drugs during traffic stops over his two years in the department.

Last month, Benefield and eight others filed a federal lawsuit accusing Wester and two other deputies of planting drugs and making illegal arrests, and the Jackson County sheriff’s office of negligence. The suit accuses all the defendants of violating the individuals’ civil and constitutional rights through illegal search, seizure, detention, prosecution, and incarceration. The plaintiffs’ attorney, Marie Mattox, told The Appeal the suit represents “only the tip of the iceberg,” and she plans to add another 18 to 20 plaintiffs. At least 37 people have filed lawsuits against Wester at the state level. The sheriff’s office declined to comment on the lawsuit.

A criminal investigation into Wester’s behavior was opened last August by the Florida Department of Law Enforcement, but no charges have been filed. Mattox said that, for the first time, three of her clients were subpoenaed for interviews in connection with that investigation in early June.

It didn’t take Christina Pumphrey long to become familiar with Zachary Wester’s name. When she was hired as an assistant state attorney at the 14th Judicial Circuit in May 2018, her duties included reviewing evidence before filing charges in several categories of arrests, including drug possession. “This is an exaggeration, but it felt like his name was on half the cases,” Pumphrey told The Appeal. “It was seriously disproportionate.”

As she watched the body camera footage from Wester’s arrests, Pumphrey grew concerned: His vehicle searches were not always conducted legally, and his written affidavits didn’t always match what she saw in the videos. People’s reactions to their arrests also seemed unusual. “It wasn’t, ‘OK, crap, I’m busted,’” she said. “It was, ‘What do you mean?’” Pumphrey began looking more closely at Wester’s arrests.

When the internal affairs division of the sheriff’s office heard she was looking into Wester’s arrests and asked for more information, she shared several body camera videos and explained what to look for. Within weeks, the sheriff’s office pulled Wester off the road and asked the law enforcement department to investigate.

More than 100 people who Wester had arrested during his two years on the force were still out on bond or—if their arrest had violated probation—behind bars. Yet the state attorney’s office did not immediately move to drop the cases. At the time, Pumphrey said, she was “getting an explicit instruction to not dismiss the cases.”

“I know these people are sitting in jail. I know that the particular charges they’re in jail on they’re either innocent of, based on the information I see, or there’s no way I could take this in front of a jury. But I’m being told, ‘Just let them sit in jail.’”

Pumphrey continued pulling Wester’s earlier arrest videos for the sheriff’s office, including ones from closed cases that had been assigned to other attorneys in her office.

In August, she flagged a February 2018 video of Wester pulling over Teresa Odom for a faulty brake light, and allegedly finding a baggie of methamphetamine in her truck. Looking closely, Pumphrey had noticed something hidden in Wester’s hand as he initiated the search.

The Odom video could not be ignored. Within weeks of Pumphrey’s discovery, the sheriff’s office fired Wester, and late September, the state attorney’s office dropped 119 cases that relied on his arrests or testimony.

Internally, however, Pumphrey said the chief assistant state attorney, Larry Basford, chastised her for sharing the videos with the sheriff’s office. “He starts yelling over the phone. What was I doing looking through all the videos? Why in the world did I find the Teresa Odom video? Why was I looking for it? And just having an absolute fit.” Basford did not respond to comment on Pumphrey’s characterization of this conversation. Pumphrey turned in her resignation the following day. She filed a whistleblower complaint, but later dropped it because she said she didn’t want it to affect her ability to represent her clients at her new state job in public defense at the Office of Criminal Conflict and Civil Regional Counsel for the First DCA Region of Florida.

The law enforcement department investigation remains open, according to a spokesperson. “Whether or not criminal charges will ever be filed, I don’t know,” said Pumphrey. “I’m not holding my breath.”

The nine plaintiffs in the federal lawsuit, and dozens of others, continue to live with the lingering effects of their arrests, and in some cases, incarceration. “One of the things that, routinely, every one of them has asked me is, ‘What is going to happen to Zach Wester out of all of this?’” said Mattox of her clients. “They’re not calling me, asking me, ‘How much money am I going to get?’ The question is, ‘What are they going to do to Zach Wester because of what he did to us?’ … They want to make sure that he’s not going to be a law enforcement officer so that he can’t do this to somebody else.”

The recently filed federal lawsuit seeks damages in excess of $75,000, as well as prospective injunctive relief, and alleges that Benefield and the others have suffered “grave mental anguish, pain and suffering, loss of capacity for the enjoyment of life, embarrassment, humiliation, loss of reputation, lost employment opportunities, lost wages, and the loss of other emoluments.”

“People still had consequences. It wasn’t like this was just all erased,” Pumphrey said. Dropped charges still remain on a person’s criminal record. And “even though the charges got dropped, there were people sitting in jail for six months on no bond because of this case. Or you’ve got people who have to spend money on supervision fees; they have to spend money paying for their own urine analysis test; they’ve done community service hours; they paid cost of bond—like $1,500. … You’re not getting back six months of your life. Or you’re not getting back the job that you lost because you sat in jail for a week before your girlfriend could get the bond money.”

For instance, Benefield’s co-plaintiff Darrell Watkins was arrested and charged with a felony after Wester claimed to find 26.4 grams of methamphetamine in his car in March 2018. He was released after paying a $5,100 bond but was arrested and searched by another officer named in the lawsuit, Trevor Lee (with Wester as backup), just four days later—which again allegedly turned up meth. Watkins lost six days of work at a tax preparation service during the height of tax season, and his employment was phased out for the year. His name and charges were on the local news, “creating tremendous obstacles for his employment prospects,” according to the suit.

Many of those Wester arrested had prior drug charges, which amplified the consequences of an arrest and likely hurt their chances of being believed over an officer. “It’s a small town, it’s a small community,” Pumphrey said. When she started the job, “I had some names I knew that I was seeing coming up in my caseload. And a lot of them, you see the name, and you know the reputation, and you think, I know he’s guilty.”

She said a culture of wanting to rack up conviction statistics—which are sent out to voters on postcards—incentivizes prosecutors to seek misdemeanor plea deals, instead of dismissing cases when the evidence doesn’t add up.

“The state attorney’s office was just as bad and just as guilty as Zach Wester when we found this out and were not dropping these cases immediately, in my mind,” Pumphrey said. “When it was ignorance it was one thing, but as soon as we know there are innocent people sitting in jail and we don’t drop the charges, we’re as guilty as he is.”

via The Appeal

June 17, 2019 at 09:09AM

Philly Removes 72 Cops Over Social Media Posts

The Philadelphia Police Department pulled 72 officers off regular duties as authorities investigate inflammatory social media posts revealed in a database that found thousands of offensive postings by current and former officers, NPR reports. It was the largest removal of officers from the street in recent memory. “We are equally as disgusted by many of the posts that you saw and in many cases, the rest of the nation saw,” said Police Commissioner Richard Ross. It is the latest fallout since the advocacy group The Plain View Project this month released thousands of Facebook posts and comments by current and former police officers that range from racist memes, to celebrations of violence and messages containing Islamophobic themes. Police internal affairs officials in Phoenix, St. Louis and Dallas are probing whether the distasteful and sometimes violent material should warrant disciplinary action or terminations.

Ross said that at least “several dozen” of the 72 officers now on desk duty will be disciplined and others will be fired. Civil rights lawyer David Rudovsky called the decision to place 72 officers on desk duty “significant,” saying the social media posts appear to show conduct that is inconsistent with the department’s promise of fair and equal treatment for all residents. “More important will be the future decisions regarding sanctions or other measures to deal with this widespread problem in the police department,” he said. Criminal defense lawyer Paul Hetznecker cited “the underlining problems of implicit bias and explicit bias that these posts reflect that have existed for a long, long time.” The project tracking officers’ use of social media flagged offensive material posted by 2,900 current officers and hundreds of former police officers across eight police departments.

via The Crime Report

June 20, 2019 at 08:24AM

Facebook Must Face Class Action Over Unwanted Text Messages, Panel Says

A federal appeals court has revived a proposed class action lawsuit against Facebook Inc. brought on behalf of non-Facebook users who claim they’ve gotten unsolicited texts from the company in violation of a federal robocalling statute.

The U.S. Court of Appeals for the Ninth Circuit reversed a lower court decision that had tossed a lawsuit brought by Noah Duguid, a non-Facebook user who claimed the company violated the Telephone Consumer Protection Act (TCPA) by mistakenly sending him security messages meant to alert users when their account had been accessed from an unrecognized device or browser. Duguid claimed that Facebook failed to respond to his multiple text and email requests to stop sending him the texts.

“The messages Duguid received were automated, unsolicited, and unwanted,” wrote Judge M. Margaret McKeown, adding that the messages fell outside an exemption to TCPA liability for emergency messages that has been outlined by the Federal Communications Commission. “Duguid did not have a Facebook account, so his account could not have faced a security issue, and Facebook’s messages fall outside even the broad construction the FCC has afforded the emergency exception,” McKeown wrote.

The court, however, joined with the Fourth Circuit in finding that an exemption for calls “made solely to collect a debt owed to or guaranteed by the United States” added to the TCPA by Congress in a 2015 amendment violated the First Amendment. But also like the Fourth Circuit, the court found that the federal debt collection exemption was severable from the TCPA, refusing a request from Facebook and its lawyers at Latham & Watkins to find the entire statute unconstitutional.

Facebook representatives didn’t immediately respond to a request for comment Thursday. The company and its lawyers have argued that the statute, which has statutory penalties of $500 per violation and was initially aimed at curbing unwanted calls from telemarketers, was never meant to put companies in Facebook’s position on the hook potentially for millions in liability.

Duguid’s lawyer, Sergei Lemberg of Wilton, Connecticut-based Lemberg Law, said that Facebook has indicated that there are a significant number of people who, like his client, received unwanted texts.

“What’s important is the message: Man versus machine. Man wins. Privacy matters,” Lemberg said. “I think Facebook for years and years was pretty cavalier, to say the least, about individuals’ privacy and this case is different from some of the stuff that’s out there publicly, but it’s cut from the same cloth.”

Lawyers from the U.S. Department of Justice intervened in the case to defend the constitutionality of the statute, but took no position on whether Facebook violated the TCPA. The Chamber of Commerce, represented by counsel from Jones Day, filed an amicus brief asking the Ninth Circuit to invalidate the restriction on using an automatic telephone dialing system to call cellphones.

via – Newswire

June 13, 2019 at 03:06PM