Morning Docket

  • Wait, did you think we were talking about strip clubs?

    Morning Docket

    Morning Docket: 11.12.15

    * Supreme Court hears argument about chicks and removing clothes for money, and it’s a lot less interesting than that sounds. [Law360]

    * Congratulations to Cristina Carvalho, the next managing partner of Arent Fox. [National Law Journal]

    * Federal government pushes “poor people aren’t real people” mantra a tad further: proposes rule banning smoking in your own home if you live in public housing. [New York Times]

    * The next time you think we have a do-nothing Congress, note that they’ve just passed a law to divvy up asteroids for mining! They’re really hard at work on the pressing issues of today. [KING5]

    * Chief counsel for the Pennsylvania Judicial Conduct Board pulled out of the investigation into Justice Michael Eakin’s troubling emails after someone pointed out that he played a lead role in the justice’s 2011 re-election campaign. Wha? How did anyone think this was OK? I repeat: What the hell is wrong with Pennsylvania’s justice system? [York Daily Record]

    * Checking in on Braeden Anderson, the Seton Hall basketball player balancing an NCAA season with his 1L year. [The Setonian]

    * “Facebook Sees 23% Spike In Law Enforcement Requests For Data.” JackBootThug37 Likes This. [TechCrunch]

    * Ted Cruz says there should be 700 miles of double fencing along the border. I’d welcome anything to keep dirty Canadians from coming down and running for president. [Real Clear Politics]

    56 Comments / / Nov 12, 2015 at 8:55 AM
  • No, you can't take pictures in that courtroom.

    Morning Docket

    Morning Docket: 11.11.15

    * A person of interest in the shooting of Texas Judge Julie Kocurek has been apprehended and arrested — not for the shooting, mind you, but for a completely unrelated crime. Judge Kocurek continues her steady recovery after being seriously injured not by a bullet, but by shrapnel and glass. [Austin American-Statesman]

    * Barnes & Thornburg partner Vincent “Trace” Schmeltz may be sanctioned for tweeting pictures that he took of the evidence that was presented during a trial. He claims he didn’t see the huge sign outside the courtroom prohibiting “photographing, recording or broadcasting.” [Chicago Tribune via ABA Journal]

    * Schneiderman, Schneiderman! Bans sports-betting wherever he can! New York Attorney General Eric Schneiderman issued a cease-and-desist order against DraftKings and FanDuel, saying the daily fantasy sites constituted illegal gambling. [New York Times]

    * Dentons finally formalized its merger with Dacheng Law Offices yesterday, thus making it the official largest law firm in the world. At 6,600 lawyers strong, just think about how many scandals we’ll be able to cover in 2016. [Big Law Business / Bloomberg BNA]

    * According to the Diversity & Flexibility Alliance, more women are being welcomed into the ranks of partnership at major firms. Out of 118 firms, women made up 34.4 percent of new partner classes. Let’s celebrate that less-than-50-percent benchmark! [WSJ Law Blog]

    * Fred Auston Wortman III, the Tennessee attorney who tried to murder his estranged wife, Staci, by lacing her toothpaste with poison, and later hired an inmate to do the deed after his plan failed, has been sentenced to 30 years in prison. [Commercial Appeal]

    * Here are three ways you can balance your law school applications with your college responsibilities, but to be honest, if you’re having trouble balancing these things, then perhaps you don’t belong in law school. [Law Admissions Lowdown / U.S. News]

    62 Comments / / Nov 11, 2015 at 8:57 AM
  • stripper

    Morning Docket

    Morning Docket: 11.10.15

    * Kid gets caught trying to buy skin mag with his dad’s money. Not one copy, but the whole magazine. Proving there are some fantasies too big even with $8 million and a Bryan Cave lawyer in your pocket. [Law360]

    * Chris Christie is taking a strong stand against bestiality. There you go, buddy — it’s these sorts of courageous, controversial positions that will get you back in the prime time debates. [Associated Press]

    * Congratulations to Neal Katyal, who has now argued more cases before the Supreme Court than any male minority lawyer save Thurgood Marshall. With his argument in Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan, Katyal passed Drew Days and Wade McCree in this accounting (No, not that Wade McCree). [Supreme Court Brief]

    * Hollywood hotshot gives $5 million to UCLA School of Law. [National Law Journal]

    * Supreme Court ignores all lower courts and expands qualified immunity to cops who base their decisions on well-established action movie tropes. [Huffington Post]

    * Biglaw faces slowdown. [American Lawyer]

    * One law school is taking a stab at the access to justice problem in this country. [Big Law Business / Bloomberg BNA]

    72 Comments / / Nov 10, 2015 at 9:00 AM
  • Adnan Syed

    Morning Docket

    Morning Docket: 11.09.15

    * On Friday night, Judge Julie Kocurek, the presiding felony judge for Travis County, Texas, was shot outside her home. Her condition has been upgraded from critical to stable, and some say that she may have been a target of retaliation. We may have more on this terrible news later today. [American-Statesman]

    * Apparently it takes podcast stardom to get a post-conviction hearing these days: A Maryland judge has agreed to reopen the case against Adnan Syed, the man whose murder conviction received an in-depth look during the first season of “Serial.” [CNN]

    * Per the Bureau of Labor Statistics, the legal sector added 700 jobs in October, bringing the industry to its highest level of employment all year. Don’t get too excited — we’re still a long way from reaching pre-recession era glory. [Big Law Business / Bloomberg BNA]

    * It took almost 10 years without putting anyone to death, but California has finally proposed a one-drug alternative to its three-drug lethal injection protocol after it was struck down as unconstitutional in 2006. Was this worth the wait? [WSJ Law Blog]

    * Following a much-deserved public excoriation from our very own Elie Mystal, Mizzou Law’s Student Bar Association has decided to do away with its absurd social media policy. In a media statement, the SBA even agreed that it was “poorly written.” [Huffington Post]

    35 Comments / / Nov 9, 2015 at 8:58 AM
  • Game of Loans

    Morning Docket

    Morning Docket: 11.05.15

    * Seton Hall Law Professor Michael Simkovic — he of the million-dollar law degree study — is back with a vengeance. Pay no attention to that law school scam op-ed in the New York Times; very few law school graduates are actually defaulting on their crushing loan debt. [ABA Journal]

    * The U.S. Senate is finally looking into what’s going on with predatory pharmaceutical pricing at companies like Valeant Pharmaceuticals and Turing Pharmaceuticals, both of which have recently hiked up the price on lifesaving drugs to an absurdly exorbitant degree. [Reuters]

    * Judge Arnold Ogden Jones II, a North Carolina state court jurist, has been accused of attempting to bribe an FBI agent with “a couple of cases of beer” in exchange for information. It better have been some damn good beer, Your Honor. [News & Observer]

    * Complaints about tuition be damned, because law schools are still churning out pricey LL.M. programs like its their job. Fordham Law’s compliance program may be useful for some, but it comes with a $53,000 price tag. [Big Law Business / Bloomberg BNA]

    * Law schools have been in a “death spiral” since applications started to drop along with admissions standards and student debt started to increase exponentially, but some will survive if the ABA steps in and polices accreditation and gainful employment. [Forbes]

    71 Comments / / Nov 5, 2015 at 9:03 AM
  • Texas Attorney General Ken Paxton

    Morning Docket

    Morning Docket: 11.04.15

    * Fans of this man’s dopey mugshot grin will be sad if they’re deprived of another jailhouse picture, but lawyers for Texas Attorney General Ken Paxton want their client’s securities fraud indictment to be tossed over what they claim was a faulty grand jury investigation. [Reuters]

    * Friday is apparently “Love Your Lawyer Day,” and the ABA recently passed a resolution to commemorate this special day every year. Biglaw firms can show their love for lawyers by announcing bigger, better bonuses! [Big Law Business / Bloomberg BNA]

    * Alabama thinks the legal fees and costs that are being requested by attorneys in the state’s landmark same-sex marriage decision are “entirely excessive” and should be “cut dramatically.” It’s not like these lawyers had to “reinvent the wheel” or anything. [AL.com]

    * “I may be known in tiny corners of the tubes of the Internet, but I am not well-known to the American public generally.” One-issue Democratic candidate Professor Lawrence Lessig of Harvard Law School is dropping out of the presidential race. [Boston Globe]

    * It’s high time you joined the green rush, lawyers: although Ohioans voted against legalizing marijuana yesterday, more and more states are adding ballot measures for the legalization of marijuana or medical marijuana to be voted on in 2016. [Washington Post]

    * “I’m glad Houston led tonight to end this constant political-correctness attack.” In other election news, voters in Texas repealed an LGBT anti-discrimination ordinance that would’ve prevented bias related to several important areas in life. [New York Times]

    14 Comments / / Nov 4, 2015 at 8:58 AM
  • Janice Dickinson (Photo by Kevin Winter/Getty)

    Morning Docket

    Morning Docket: 11.03.15

    * For the horde! If you thought Dentons was done gobbling up law firms to create its international legion of lawyers, then you were dead wrong. The firm will likely merge with 500-lawyer Australian firm Gadens and 200-lawyer Singaporean firm Rodyk & Davidson in 2016. [Reuters]

    * Thanks to this ruling, lawyers for model Janice Dickinson may depose Bill Cosby in the defamation case she filed against him after he denied raping her. Cosby’s former lawyer, Martin Singer, who the comedian recently dumped for Quinn Emanuel, may be deposed as well. [Los Angeles Times]

    * If daylight saving time has been messing with your head, you’ll feel better to know that even the Supreme Court was having trouble with the time. Both clocks in the SCOTUS courtroom were hours behind thanks to an electrical malfunction. [WSJ Law Blog]

    * Law school graduates have been having a rough time when it comes to bar passage in recent years, but Biglaw firms likely have nothing to worry about — in fact, many partners didn’t even know a problem like this was happening. [Big Law Business / Bloomberg BNA]

    * “[T]he Harvard crest . . . should be a source of shame for the whole school.” According to a student movement at Harvard Law that’s been dubbed “Royall Must Fall,” the school was endowed by a “brutal” slaveowner and yet still bears his family’s seal. [Harvard Crimson]

    51 Comments / / Nov 3, 2015 at 8:48 AM
  • It's not all that it's cracked up to be.

    Morning Docket

    Morning Docket: 11.02.15

    * Despite the fact that people seemed to have been losing their minds over court packing, according to Judge Sri Srinivasan of the D.C. Circuit, President Obama’s appointment of four new judges on the powerful court had little to no impact on the outcome of cases. [POLITICO]

    * “Americans are actively being deprived of their rights.” In this excellent longread on arbitration, we learn it’s the best for big companies, but for plaintiffs who are forced into it, it amounts to the “privatization of the justice system.” [DealBook / New York Times]

    * Uh oh! Disgraced plaintiffs’ lawyer Stan Chesley — perhaps better known as the “Master of Disaster” — had a warrant issued for his arrest last week after he failed to appear for a hearing related to his refusal to pay a $42 million judgment. [Louisville Courier Journal]

    * Florida A&M University College of Law has a brand new dean. We’d like to wish a warm welcome to Angela Felecia Epps, whose salary of $252,000 is likely more than any of the school’s recent and barely employed graduates can hope to make. [Orlando Sentinel]

    * A 30-year-old New Jersey man has been sentenced to a 16-year prison term for aggravated arson after the fires he set last year damaged a local law firm (one that was representing him at the time) and the county prosecutor’s office. [Associated Press]

    35 Comments / / Nov 2, 2015 at 8:56 AM
  • Taylor Swift (Photo by Frazer Harrison/Getty)

    Morning Docket

    Morning Docket: 10.30.15

    * “Say you’ll remember me, getting groped in a nice dress…” Uh oh! This pop star seems pretty pissed! Taylor Swift has filed a countersuit against a radio DJ who sued her because he claims he was fired for inappropriately touching the singer backstage at a concert. [Rolling Stone]

    * Charleston School of Law has a new president, and hopefully his tenure will be less wrought with disaster than that of his predecessors. He says he’ll be paid one whole dollar per year as his salary until he can turn things around. [Charleston Post and Courier]

    * At a speaking engagement at Santa Clara Law earlier this week, Justice Antonin Scalia proclaimed that the Supreme Court has been “liberal” throughout the entirety of his 30-year tenure. We’d like to beg His Honor’s pardon; that can’t be true. [WSJ Law Blog]

    * As this article so eloquently puts it, “[t]he Supreme Court is about to climb back into Americans’ bedrooms.” Today, the high court will review several petitions from non-profit groups that want to be exempted from ACA’s contraception mandate. [USA Today]

    * Everything’s bigger in Texas, including the number of firms that are trying to enter the market. To establish a presence in the Lone Star State, Kilpatrick Townsend & Stockton is saying howdy to some new partners and merging with Crouch & Ramey. [ABA Journal]

    16 Comments / / Oct 30, 2015 at 8:57 AM
  • 'I'll get you in court, my pretty!'

    Morning Docket

    Morning Docket: 10.29.15

    * It’s almost Halloween, so members of the legal profession had to have expected some spooky legal proceedings to occur this week. It seems that Lori Sforza, a witch priestess from Salem, has been granted a protective order against a well-known warlock. [Associated Press]

    * Presidential candidate Bernie Sanders would like to remove marijuana from the list of dangerous controlled substances that are regulated by the Drug Enforcement Administration, which would free up states to legalize it on their own terms. Stoners are really feeling the “Bern” now, in more ways than one. [Washington Post]

    * Four federal lawyers spent weeks nailing down the legalities behind the killing of Osama bin Laden, and they weren’t allowed to ask Attorney General Eric Holder for help for fear of leaks to the press. They even had to do the legal research themselves! [New York Times]

    * According to a new report by the National Association of Women Lawyers, there’s been no “appreciable progress” made for women in the nation’s largest law firms since at least 2006. This is extremely disheartening. Please do better, Biglaw. [Big Law Business / Bloomberg BNA]

    * You know Walgreens is buying Rite Aid for $9.4B, but you might not have known which law firms were prescribing advice in the mega pharmacy merger. Skadden, Jones Day, Simpson Thacher, and Weil Gotshal got billable scripts. [DealBook / New York Times]

    20 Comments / / Oct 29, 2015 at 8:56 AM
  • legally_blonde_2

    Morning Docket

    Morning Docket: 10.28.15

    * Good news, everyone! Legally Blonde 3 is supposedly in the works, and Reese Witherspoon says that the movie may involve Elle Woods becoming a Supreme Court justice or some kind of an elected official. It’s really too bad that SCOTUS robes aren’t pink. [Washington Post]

    * Biglaw firms aren’t the only ones that are downsizing when it comes to their headcount. Case in point, Lear Corporation’s in-house legal department has dropped from 20 attorneys to 11, but its GC Terry Larking says it’s working for the company. [Big Law Business / Bloomberg BNA]

    * Cornell Law School will be teaming up with Cornell Tech to launch a new LL.M. degree in law, technology, and entrepreneurship. Like most LL.M. degrees, we imagine that it will cost a pretty penny, but that its overall value on the market will be low. [Cornell Chronicle]

    * “Do we really need to protect people from trying to achieve their dreams?” Professor Noah Feldman of Harvard Law thinks we shouldn’t coddle law school applicants who are unlikely to pass a bar or try to “save” them from a lifetime of debt. [Bloomberg View]

    * She shoots, she scores? An ex-cheerleader filed suit against the Milwaukee Bucks under the Fair Labor Standards Act because she alleges she was paid less than minimum wage to cheer for the team. The suit is the first of its kind filed against an NBA team. [ABC News]

    41 Comments / / Oct 28, 2015 at 9:01 AM
  • Goooo minimum wage!  (Photo by Andy Lyons/Getty)

    Morning Docket

    Morning Docket: 10.27.15

    * The Cincinnati Bengals reached a $255K settlement with their cheerleaders in a wage-and-hour suit. Each Ben-Gal stands to receive at least $2,500. Hmm, maybe they needed better lawyers who could BE AGGRESSIVE! B-E AGGRESSIVE! B-E A-G-G-R-E-S-S-I-V-E! [CBS News]

    * Biglaw leaders think that first-year associates are likely to be replaced by robots within 10 years. Some even think that second- and third-year associates could be replaced by artificial intelligence. Damn, no wonder NY to $190 is still a pipedream. [Ars Technica via Am Law Daily]

    * “What you’re asking them to do is do work for you.” Despite the fact that the cellphone was seized in an investigation, this federal magistrate judge says that he isn’t quite sure if he has the legal authority to compel Apple to access data on a locked iPhone. [Reuters]

    * Justice waits for no one, except this defendant who allegedly murdered her 19-month-old daughter in 2010. After her trial was rescheduled for the 18th time, a judge finally decided he’d had enough: “Anything following this will be a trial or dismissal.” [WSJ Law Blog]

    * If you’re trying to get into to law school, there’s no need to wait for your fall semester grades before you send off your applications. A pulse and the ability to sign federal loan documents are all that you’ll need. [Law School Lowdown / U.S. News & World Report]

    60 Comments / / Oct 27, 2015 at 8:59 AM
  • Legally Blonde Poster

    Morning Docket

    Morning Docket: 10.26.15

    * “Cases swing. I don’t.” Justice Anthony Kennedy would really like it if folks would stop referring to him as the high court’s swinger swing vote. In other news, the Supreme jurist thinks Legally Blonde is a “pretty good movie.” [Harvard Gazette]

    * Hey, everyone, it’s high time we did something about this law school debt crisis. Have you somehow never heard about or experienced this before (despite reading Above the Law for eons)? Not to worry, because the New York Times is on it! [New York Times]

    * “She’ll still be fighting for the things she cares about. But this time, she’ll be asking us to join her.” Irin Camron, co-author of Notorious RBG: The Life and Times of Ruth Bader Ginsburg (affiliate link), thinks we’ll see more Badass Bader this Term. [New York Times]

    * The Pennsylvania Senate is trying to kick embattled Attorney General Kathleen Kane out of office because she’s working with a suspended law license. Come on, it must be pretty embarrassing when your AG can’t even refer to herself as a lawyer. [Morning Call]

    * According to Professor Paul Campos, the law school scam will keep on trucking thanks to the for-profit institutions — Arizona Summit Law, Charlotte Law, and Florida Coastal Law — that are run by InfiLaw. Well, at least they’re good at one thing, right? [The Atlantic]

    * Toke the vote! The next states that will likely legalize recreational marijuana by ballot referendum come November 2016 include California, Maine, Massachusetts, and Nevada. Vermont, on the other hand, may pass marijuana-friendly legislation. [Rolling Stone]

    24 Comments / / Oct 26, 2015 at 8:57 AM
  • Jay Z (Photo by Frederick M. Brown/Getty)

    Morning Docket

    Morning Docket: 10.22.15

    * Brush that dirt off your shoulder: Jay-Z may have 99 problems, but this copyright lawsuit about his song “Big Pimpin'” is no longer one of them. The suit filed against the rap mogul in 2007 was dismissed on standing grounds, but the plaintiff says he plans to appeal. [Los Angeles Times]

    * When it comes to the death penalty, Justice Antonin Scalia says that it “wouldn’t surprise [him]” if the Supreme Court were to strike it down as unconstitutional. It seems that a capital punishment case could become the next SCOTUS blockbuster. [CBS Minnesota]

    * No one is a fan of the Securities and Exchange Commission’s in-house court system, and legislation to give financial defendants the right to opt out will be introduced in Congress later this week. Would you rather face trial before a federal judge or jury? [WSJ Law Blog]

    * Earlier this week, a state-court judge brought a live grenade to the courthouse, but only because he wanted to have it properly disposed of by police. The jurist currently remains unidentified, which is a good thing, because this is pretty embarrassing. [CBS Los Angeles]

    * Jurors in New York are paid $40 per day for their service, so you may be wondering how the confused members of the jury in the Dewey & LeBoeuf (mis)trial were able to survive on only $2,920 after five months spent in the courtroom. [Big Law Business / Bloomberg]

    62 Comments / / Oct 22, 2015 at 8:44 AM
  • fail failure

    Morning Docket

    Morning Docket: 10.21.15

    * Arizona Summit Law wasn’t the only law school to post an embarrassing passage rate on the July 2015 administration of the bar exam. Only 28 percent of test-takers from this law school passed, but its dean says that the scores don’t “reflect a problem with the school’s quality.” Hey, whatever helps you get to sleep at night. [Tennessean]

    * Speaking of bar passage rates, if you’re applying to law school, should you care about them? Job statistics are probably a more telling measurement when comparing schools, but then again, it’s harder to get a job when you can’t pass the bar exam. [U.S. News]

    * “It’s a huge blow to his tenure as DA.” The mistrial in the criminal case against Dewey & LeBoeuf’s former executives is putting a major damper on what was supposed to be Manhattan DA Cy Vance’s crackdown on corporate crime. [Big Law Business / Bloomberg]

    * Thanks to the Department of Education’s “gainful employment rule,” for-profit law schools could be in trouble when it comes to eligibility for federal student loans under the “debt-to-earnings” test. This certainly may put a crimp in Infilaw’s style. [Huffington Post]

    * The vast majority of all class members in the Subway “footlong” lawsuit aren’t likely to see a dime. This is fine because they don’t need to see any “dough,” but a guarantee that the company’s next spokesperson won’t be a child predator would be nice. [WSJ Law Blog]

    55 Comments / / Oct 21, 2015 at 8:58 AM
  • prison prisoner jail convicted criminal

    Morning Docket

    Morning Docket: 10.20.15

    * “This is the best we can do” doesn’t sound like a ringing endorsement on policy change, but at least the bipartisan sentencing reform bill has a chance to see the light of day. [National Law Journal]

    * Corporate scandals feed more and more of the news cycle, and general counsels are key to responding. [Law360]

    * Speaking of corporate scandals, the Petrobras corruption scandal has already cost an estimated $5 billion in losses. [Corporate Counsel]

    * Yup, Republicans are still trying to undo Obamacare via lawsuit. The Obama administration just lost a ruling to immediately appeal the viability of the lawsuit. [Wall Street Journal]

    * The Dewey trial’s hing jury mirrors the dysfunction of the Dewey & LeBoeuf partnership. [American Lawyer]
    * The feds are cracking down on drone registration, which means a bunch of new regulations to follow, you know, if you are into flying drones. [Fortune]

    23 Comments / / Oct 20, 2015 at 9:03 AM
  • Oscar Pistorius

    Morning Docket

    Morning Docket: 10.19.15

    * After a recent vote, the Florida Bar flat-out rejected a supposedly “controversial” proposal for bar reciprocity. Attorneys in the Sunshine State absolutely, positively do NOT want you practicing law there if you haven’t taken the Florida bar. [WSJ Law Blog]

    * Tomorrow, Oscar Pistorius will be released from prison after having only served a fifth of a five-year sentence for killing his girlfriend, a law school graduate. He’ll begin a stint of house arrest, and he’s not allowed to have guns there… for very obvious reasons. [UPI]

    * The case of the missing mistrial? After four weeks of deliberation, and after having acquitted the defendants of a slew of lesser charges, the jury in the criminal trial against the ex-execs of Dewey & LeBoeuf will enter a new month without a full verdict. [Reuters]

    * The Nebraska Legislature voted to abolish the death penalty in the state, but supporters of capital punishment have forced a November 2016 referendum vote instead. Not to worry, “[n]obody’s going to be executed in Nebraska anytime soon.” [New York Times]

    * This week, Connecticut’s Appellate Court will hear cases at the state’s most famous — and most prestigious — law school. Don’t get too excited, Yalies, because this has nothing to do with you. In fact, you’ve probably never even heard of this place. [Associated Press]

    46 Comments / / Oct 19, 2015 at 8:59 AM
  • John Stamos (Photo by Jemal Countess/Getty Images)

    Morning Docket

    Morning Docket: 10.16.15

    * John Stamos of Full House fame was formally charged with driving under the influence earlier this week following his arrest for erratic driving this summer. He faces up to six months in jail if convicted. We have faith that his beautiful hair will survive time in the slammer. [USA Today]

    * While the vast majority of the law school lawsuits containing allegations related to deceptive employment statistics have been dismissed, a few are still alive and kicking. The very first one filed — Alaburda v. Thomas Jefferson School of Law — is heading to trial in 2016. [WSJ Law Blog]

    * Trick or treat? Per federal prosecutors, former House Speaker Dennis Hastert will plead guilty before Halloween as part of a deal in his ongoing sexual misconduct hush-money case, but whether he’ll serve time is a question that’s yet to be answered. [Reuters]

    * Headcount at real estate firms with once-prominent foreclosure practices continues to shrink thanks to the recession’s end. To that effect, two Chicago firms have eliminated hundreds of positions for legal professionals since 2013. [Chicago Business Journal]

    * Thanks to a new online system, Northwestern Law will be able to interview prospective students any time, anywhere. The school is the first in the country to offer awkward casting couch sessions as part of its admissions process. [Northwestern University News]

    31 Comments / / Oct 16, 2015 at 9:00 AM