Professor Jacqueline Nolan-Haley offered a cautious endorsement of the E.U. directive requiring all member states to implement mediation programs. I agree with her assertion that mandating mediation will strip the process of its voluntary nature and amicability but was disappointed that she did not take a clearer position on whether this mandated mediation violates Article 6 of the European Convention for the Protection of Human Rights and Fundamental Freedoms.