On the Docket’s Preview of the March Supreme Court Arguments

March 2 Nasrallah v. Barr No. 18-1432, 11th Cir. Preview by Megan Walden In Nasrallah v. Barr, the Court will resolve a long-standing circuit split in immigration law and determine whether the Court of Appeals has jurisdiction to review findings of fact in denials of withholding and deferral of removal cases. Nidal Khalid Nasrallah, a...
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On the Docket’s Preview of the February Supreme Court Arguments

February 24 United States Forest Service v. Cowpasture River Preservation Association; Atlantic Coast Pipeline, LLC v. Cowpasture River Preservation Association No. 18-1584 & 18-1587, 4th Cir. Preview by Taylor Dowd, Senior Online Editor Is the Appalachian Trail, the 2,200-mile-long stretch running from Georgia to Maine, “land,” or just a footpath traversing land? The Appalachian Trail...
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On the Docket’s Preview of the January Supreme Court Arguments

January 13 Lucky Brand Dungarees v. Marcel Fashion Group No. 18-1086, 2d Cir. Preview by Michael Fischer, Online Editor Lucky Brand Dungarees and Marcel Fashion group are two competitors within the apparel industry who each own various trademarks using the term “Lucky.” In 2001, Marcel sued Lucky Brand alleging that it violated its “Get Lucky”...
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On the Docket’s Preview of the October Supreme Court Arguments

October 7 Kahler v. Kansas No. 18-6135, Kan. Preview by Michael Fischer, Online Editor In response to several high-profile cases wherein defendants were found not guilty by reason of insanity, the State of Kansas passed legislation in 1995 which effectively abolished the insanity defense for criminal defendants. Thirteen years later, Kraig Kahler was experiencing numerous...
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Clerks at 100

Join us Friday, October 4th for a symposium focusing on the institution of Supreme Court clerkships. Essays will be published on the George Washington Law Review’s Arguendo. Find More Information About the Public Portion of the Event Here. Register For the Event Here. *** Private Pre-Panel for GW Law Students, Alumni & Faculty: Clerking at...
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A Review of The Cost-Benefit Revolution and Carceral Capitalism

James Hannaway · September 2019 87 Geo. Wash. L. Rev. Arguendo 26 In The Cost-Benefit Revolution, Cass Sunstein celebrates the dominance of cost-benefit analysis in administrative law and imagines new frontiers for its application. While he acknowledges problems associated with cost-benefit analysis like failing to account for unfair distributions of resources or intangible dignitary concerns,...
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Kisor v. Wilkie: A Reprieve for Embattled Administrative State?

July 3, 2019 Kisor v. Wilkie, 587 U.S. ___ (2019) (Kagan, J.). Response by Robert L. Glicksman Geo. Wash. L. Rev. On the Docket (Oct. Term 2018) Slip Opinion | SCOTUSblog Kisor v. Wilkie: A Reprieve for Embattled Administrative State? Imagine a world in which administrative agencies whose actions are challenged in court are afforded...
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Herrera v. Wyoming: A New Trend for Indian Law?

June 11, 2019 Herrera v. Wyoming, 587 U.S. ___ (2019) (Sotomayor, J.). Response by Monte Mills Geo. Wash. L. Rev. On the Docket (Oct. Term 2018) Slip Opinion | SCOTUSblog Herrera v. Wyoming: A New Trend for Indian Law? On May 20, 2019, the United States Supreme Court, by a 5–4 decision in Herrera v. Wyoming,...
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Franchise Tax Board v. Hyatt: An Unnecessary Overruling

May 21, 2019 Franchise Tax Board v. Hyatt, 587 U.S. ___ (2019) (Thomas, J.). Response by Alan B. Morrison Geo. Wash. L. Rev. On the Docket (Oct. Term 2018) Slip Opinion | SCOTUSblog Franchise Tax Board v. Hyatt: An Unnecessary Overruling In Franchise Tax Board of California v. Hyatt1, the Court, by a vote of 5–4,...
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Is Transmission of Electricity a “Governmental Function?” Thacker v. Tennessee Valley Authority

May 10, 2019 Thacker v. Tennessee Valley Authority, 587 U.S. ___ (2019) (Kagan, J.). Response by Richard J. Pierce, Jr. Geo. Wash. L. Rev. On the Docket (Oct. Term 2018) Slip Opinion | SCOTUSblog Is Transmission of Electricity a “Governmental Function?” Thacker v. Tennessee Valley Authority The Court concludes its unanimous opinion in Thacker v. Tennessee...
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Crossing the River: Lorenzo v. Securities and Exchange Commission

April 2, 2019 Lorenzo v. SEC, 586 U.S. ___ (2019) (Breyer, J.). Response by Theresa A. Gabaldon Geo. Wash. L. Rev. On the Docket (Oct. Term 2018) Slip Opinion | SCOTUSblog Crossing the River: Lorenzo v. Securities and Exchange Commission Section 17(a)(1) of the Securities Act of 1933 provides that it is “unlawful for any...
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On the Docket’s Preview of the March Supreme Court Arguments

March 18 Virginia House of Delegates v. Bethune Hill No. 18-281, E.D. Va. Preview by Sean Lowry, Online Editor* In Virginia House, the Court will re-examine a Virginia state electoral map for racial gerrymandering claims and hear new arguments about who has the standing to defend the map on appeal. The initial controversy arose when voters...
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What Timbs Does Not Say

March 7, 2019 Timbs v. Indiana, 586 U.S. ___ (2019) (Ginsburg, J.). Response by Suja A. Thomas Geo. Wash. L. Rev. On the Docket (Oct. Term 2018) Slip Opinion | SCOTUSblog What Timbs Does Not Say Timbs v. Indiana1 isn’t a surprising case. Over time, the United States Supreme Court successively has decided that different...
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On the Docket’s Preview of the February Supreme Court Arguments

February 19 Return Mail, Inc. v. United States Postal Service No. 17-1594, Fed. Cir. Preview by Michelle Divelbiss, Online Editor It has been almost a decade since the Supreme Court decided that corporations are people, and now the Court looks to whether the government is a “person.” Under the Leahy-Smith America Invents Act (“AIA”), patent...
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Hearsay in the Modern Age: Balancing Practicality and Reliability by Amending Federal Rule of Evidence 801(d)(1)(A)

Madeline Smedley 87 Geo. Wash. L. Rev. 207 The Advisory Committee on the Federal Rules of Evidence is considering amending Federal Rule of Evidence 801(d)(1)(A) to make prior inconsistent statements captured on audiovisual devices admissible for their substantive value rather than solely for impeachment purposes. Although this proposed change allows litigants to leverage the benefits of digital technology, the proposal lacks the...
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The First American Climate Refugees and the Need for Proactive Relocation

Kelley Pettus 87 Geo. Wash. L. Rev. 172 American disaster response under the Stafford Act currently provides only reactive responses to natural and man-made disasters, offering assistance to states under major disaster or emergency declarations once harm has occurred. In the age of climate change, where future disasters are accurately predictable and resulting harm is preventable, the United States should adopt...
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Biological Citizenship and the Children of Same-Sex Marriage

Michael J. Higdon 87 Geo. Wash. L. Rev. 124 In 2015, the Supreme Court ruled that states could not, consistent with the Due Process Clause, deny same-sex couples the right to marry. To allow otherwise, said the Court, would “harm and humiliate the children of same-sex couples.” Thus, it was hoped that marriage equality would provide greater security for the children...
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Sexual Harassment and Solidarity

Marion Crain & Ken Matheny 87 Geo. Wash. L. Rev. 56 In the waning months of 2017, Americans endured an almost daily barrage of news reports describing sexual harassment by powerful men in entertainment, media, politics, and law. The media focus continued in 2018 as reactions proliferated, ranging from walkouts at Google by workers protesting the company’s handling of sexual-misconduct allegations...
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A Rule of Persons, Not Machines: The Limits of Legal Automation

Frank Pasquale 87 Geo. Wash. L. Rev. 1 For many legal futurists, attorneys’ work is a prime target for automation. They view the legal practice of most businesses as algorithmic: data (such as facts) are transformed into outputs (agreements or litigation stances) via application of set rules (the law). These technophiles promote substituting computer code for contracts and descriptions of facts...
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On the Docket’s Preview of the January Supreme Court Arguments

January 7 Merck Sharpe & Dohme Corp. v. Albrecht No. 17-290, 3d Cir. Preview by Samuel E. Meredith, Senior Online Editor Merck was initiated by over 500 people who used an osteoporosis medication known as Fosamax. The plaintiffs claim that Fosamax caused them to experience “an atypical femoral fracture,” and that the drug manufacturer did not...
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On the Docket’s Preview of the December Supreme Court Arguments

December 3 Dawson v. Steager No. 17-419, W. Va. Preview by Samuel E. Meredith, Senior Online Editor West Virginia does not collect tax on some kinds of retirement benefits given to former state law enforcement officials. The state does not, however, extend this same tax relief to retired federal law enforcement personnel. The question presented by...
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On the Docket’s Preview of the November Supreme Court Arguments

November 5 Sturgeon v. Frost No. 17-949, 9th Cir. Preview by Clay Wild At issue in this case is whether the Alaska National Interest Lands Conservation Act (“ANILCA”) prohibits the National Park Service (“NPS”) from regulating State, Native Corporation, and private land located within the National Park System in Alaska. In 2007, NPS rangers found...
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“Good Cause” Is Cause for Concern

James Yates 86 Geo. Wash. L. Rev. 1438 The Administrative Procedure Act (“APA”) generally requires that all federal administrative rules undergo public “notice and comment.” The “good cause” exception allows an agency to bypass this requirement where it would be “impracticable, unnecessary, or contrary to the public interest.” In recent years, good cause has been increasingly used to excuse “major” rules,...
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Chartering Fintech: The OCC’s Newest Nonbank Proposal

Elizabeth J. Upton 86 Geo. Wash. L. Rev. 1392 The Office of the Comptroller of the Currency is responsible for ensuring federally chartered banks’ safety and soundness, compliance with federal banking laws, and compliance with federal laws regarding fair access to financial services and fair treatment of customers. The states have historically overseen and regulated nonbank companies, including nonbank financial services providers...
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Use of the Congressional Review Act at the Start of the Trump Administration: A Study of Two Vetoes

Stephen Santulli 86 Geo. Wash. L. Rev. 1373 Once regarded as a legislative dead letter, the Congressional Review Act (“CRA”) gained new vitality in 2017 as President Trump and Republicans in Congress used the Act to veto more than a dozen regulations issued late in the Obama Administration. The reemergence of the CRA renewed debate over a vague provision at the...
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Lying in Wait: How a Court Should Handle the First Pretextual For-Cause Removal

Richard Rothman & Katelin Shugart-Schmidt 86 Geo. Wash. L. Rev. 1348 The legal limits of for-cause removal protections for executive officials have barely been defined, even as the current presidential administration considers removing protected officials. Open questions include whether and how courts will choose to define “cause,” as well as whether courts will inquire into the authenticity of a President’s stated...
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Defying Debarment: Judicial Review of Agency Suspension and Debarment Actions

Samantha Block 86 Geo. Wash. L. Rev. 1316 Judicial review of agencies’ suspension and debarment decisions is currently in flux. Recently, courts are more closely scrutinizing such decisions, potentially altering the way these tools are used. Both Congress and the courts need to consider creating a clear and consistent standard for agency review of suspension and debarment actions. To illuminate the...
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Topic Modeling the President: Conventional and Computational Methods

J.B. Ruhl, John Nay & Jonathan Gilligan 86 Geo. Wash. L. Rev. 1243 Law is generally embodied in text, and lawyers have for centuries classified large bodies of legal text into distinct topics—that is, they “topic model” the law. But large bodies of legal documents present challenges for conventional topic modeling methods. The task of gathering, reviewing, coding, sorting, and assessing...
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Optimal Ossification

Aaron L. Nielson 86 Geo. Wash. L. Rev. 1209 One of the dirtiest words in administrative law is “ossification”—the term used for the notion that procedural requirements force agencies to spend a long time on rulemakings. Ossification, however, is misunderstood. Even leaving aside the other benefits of procedures, delay itself can be valuable. For instance, procedural delay...
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The American Nondelegation Doctrine

Cass R. Sunstein 86 Geo. Wash. L. Rev. 1181 An American nondelegation doctrine is flourishing. Contrary to the standard account, it does not forbid Congress from granting broad discretion to executive agencies. Instead it is far narrower and more targeted. It says, very simply, that executive agencies cannot make certain kinds of decisions unless Congress has explicitly authorized them to do...
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On the Docket’s Preview of the October Supreme Court Arguments

The Supreme Court has dominated the news cycle lately, and yet none of it has had anything to do with the Court’s jurisprudence. Instead, all the attention has been focused on Judge Brett Kavanaugh, whose confirmation prospects have diminished in the wake of allegations of sexual misconduct. Following a set of extremely contentious hearings, some...
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Drone Trespass and the Line Separating the National Airspace and Private Property

Lane Page 86 Geo. Wash. L. Rev. 1152 On August 29, 2016, the Federal Aviation Administration (“FAA”) released a small-drone rule that will substantially increase the number of commercial drones flying throughout the national airspace. This new rule fails to specifically regulate or define when a drone is trespassing over a landowner’s private property. Moreover, since the development of drone technology,...
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Before the Breach: The Role of Cyber Insurance in Incentivizing Data Security

Brendan Heath 86 Geo. Wash. L. Rev. 1115 Data breaches continue to increase in size, scope, and consequence as companies face the prospect of millions of personal records of their customers or clients being disclosed to internet hackers. In the face of this growing risk, insurance policies explicitly written to cover cyber incidents offer benefits to society in the form of...
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The Trespass/Nuisance Divide and the Law of Easements

Kenneth A. Stahl 86 Geo. Wash. L. Rev. 966 The law of easements is a mess. In one case, a property owner ends up with a landlocked parcel because, although he had a desperate need to traverse his neighbor’s land to access a public road, the necessity did not arise from the severance of a unified parcel. In another, a...
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Franchise Regulation for the Fissured Economy

Andrew Elmore 86 Geo. Wash. L. Rev. 907 Franchise stores employ nearly nine million people in the United States. Many franchisors, which own trademarks that they license to franchisees, are among the largest, most sophisticated corporations in the United States. Yet franchise store employees are often paid below the minimum wage and frequently report unsafe workplaces and workplace discrimination.  The thesis...
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Lucia v. SEC

July 3, 2018 Lucia v. SEC, 585 U.S. ___ (2018) (Kagan, J.). Response by Richard J. Pierce, Jr. Geo. Wash. L. Rev. On the Docket (Oct. Term 2017) Slip Opinion | SCOTUSblog Lucia v. SEC The only issue in Lucia v. SEC1 was whether Securities and Exchange Commission (“SEC”) Administrative Law Judges (“ALJs”) are employees or...
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Carpenter v. United States: Big Data is Different

July 2, 2018 Carpenter v. United States, 585 U.S. ___ (2018) (Roberts, C.J.). Response by Margot E. Kaminski Geo. Wash. L. Rev. On the Docket (Oct. Term 2017) Slip Opinion | SCOTUSblog Carpenter v. United States: Big Data Is Different A central truism of U.S. privacy law is that if you share information, you do not...
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Why Art Does Not Need Copyright

Amy Adler 86 Geo. Wash. L. Rev. 313 This Article explores the escalating battles between visual art and copyright law in order to upend the most basic assumptions on which copyright protection for visual art is grounded. It is a foundational premise of intellectual property law that copyright is necessary for the “progress” of the arts. This Article demonstrates that this...
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The Myth of Free

John M. Newman 86 Geo. Wash. L. Rev. 513 Myths matter. This Article is the first to confront a powerful myth that pervades modern economic, technological, and legal discourse: the Myth of Free. The prevailing view is that consumers capture massive welfare surplus from a flood of innovative new products that are offered free of charge. Economists, legal scholars, and industry...
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What Happens Behind Bars Should Not Stay Behind Bars: The Case for an Exhaustion Exception to the Prison Litigation Reform Act for Juveniles

Samantha Bennett 86 Geo. Wash. L. Rev. 587 Congress enacted the Prison Litigation Reform Act (“PLRA”) in an effort to reduce the number of frivolous lawsuits brought by prisoners. As a result of some of its provisions, however—in particular, the exhaustion provision—nonfrivolous suits are effectively blocked from reaching the courts, enabling grave injustices to persist in America’s prison facilities without...
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Bifurcating Settlements

Michael Abramowicz & Sarah Abramowicz 86 Geo. Wash. L. Rev. 376 In settling a lawsuit, parties agree on their obligations to one another, but they need not separately address each issue, claim, or remedy that a trial court would have confronted. The legal system, however, can bifurcate the settlement process, requiring separate resolution of components of a settlement. Bifurcation can protect...
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Tiered Constitutional Design

Rosalind Dixon & David Landau 86 Geo. Wash. L. Rev. 438 Scholarship has posited two models of constitutionalism. One is short, abstract, and rigid, like the United States Constitution. The other is lengthy, detailed, and flexible, like the constitutions found in many U.S. states and in many other countries around the world. This Article argues that there is a descriptively common...
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“Some Kind of Notice” Is No Kind of Standard: The Need for Judicial Intervention and Clarity in Due Process Protections for Public School Students

Elizabeth J. Upton 86 Geo. Wash. L. Rev. 655 Public backlash over zero tolerance policies that funnel public school students to jail through the “school to prison pipeline” has unveiled the systemic issues associated with discriminatory application and the detrimental effects of exclusionary discipline. What remains unaddressed and largely ignored is the lack of procedural safeguards afforded to students who face...
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Animal Science Products, Inc. v. Hebei Welcome Pharmaceutical Co.: Respect but Verify: Foreign Government Statements of Foreign Law Do Not Get Conclusive Deference

June. 21, 2018 Animal Science Products, Inc. v. Hebei Welcome Pharmaceutical Co., 585 U.S. ___ (2018) (Ginsburg, J.). Response by Donald C. Clarke Geo. Wash. L. Rev. On the Docket (Oct. Term 2017) Slip Opinion | SCOTUSblog Animal Science Products, Inc. v. Hebei Welcome Pharmaceutical Co.: Respect but Verify: Foreign Government Statements of Foreign Law...
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Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission: A Troublesome Application of Free Exercise Principles by a Court Determined to Avoid Hard Questions

June 7, 2018 Masterpiece Cakeshop, Ltd. v. Colo. Civil Rights Comm’n, 584 U.S. ___ (2018) (Kennedy, J.). Response by Ira C. Lupu & Robert W. Tuttle Geo. Wash. L. Rev. On the Docket (Oct. Term 2017) Slip Opinion | SCOTUSblog Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission: A Troublesome Application of Free Exercise Principles...
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SAS Institute Inc. v. Iancu: The Statute is Hereby Clear

May 7, 2018 SAS Institute Inc. v. Iancu, 584 U.S. ___ (2018) (Gorsuch, J.). Response by Andrew C. Michaels Geo. Wash. L. Rev. On the Docket (Oct. Term 2017) Slip Opinion | SCOTUSblog SAS Institute Inc. v. Iancu: The Statute is Hereby Clear Before the Law stands a doorkeeper . . . . From hall to hall there is...
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Murphy v. Smith: Limiting Access to Counsel for Prisoners

Apr. 2, 2018 Murphy v. Smith, 138 S. Ct. 784 (2018) (Gorsuch, J.). Response by Katy Ramsey Geo. Wash. L. Rev. On the Docket (Oct. Term 2017) Slip Opinion | SCOTUSblog Murphy v. Smith: Limiting Access to Counsel for Prisoners On February 21, 2018, the U.S. Supreme Court decided Murphy v. Smith,1 which hinged on the...
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On the Docket’s Preview of the March Supreme Court Arguments

The first oral arguments for the month of March will commence when the Court convenes this coming Monday. Since our last set of argument previews was released, the Court has issued opinions in nine different cases, including a consequential ruling in Jennings v. Rodriguez. The Court’s March schedule will undoubtedly generate momentous decisions as well, as...
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The Mathematical Question: Defining “Relatively Easy” Political Questions

Nathaniel Schwamm 92 Geo. Wash. L. Rev. 1182 Justiciability doctrines are intertwined with constitutional commands and prudential concerns. They weave together text and history; they aim to protect democracy and individual rights. In 2019, the Supreme Court, in Rucho v. Common Cause, determined that partisan gerrymandering claims suffer from justiciability problems by implicating a doctrinal...
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Judicial Review of Agency Noncompliance with Presidential Administrative Orders and OMB Circular A-4

Eitan Sirkovich 92 Geo. Wash. L. Rev. 1163 President Biden’s Executive Order 14,094, Modernizing Regulatory Review, continues the line of presidential directives dating back to the Reagan Administration that centralize the President’s control over administrative agencies’ regulatory processes. Its express purpose is to ensure well-reasoned, high-quality regulations, but it affords no private right of action...
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What the New Major Questions Doctrine Is Not

Anita S. Krishnakumar 92 Geo. Wash. L. Rev. 1117 The major questions doctrine has undergone a sea change in prominence within the span of two years. In the ten months between August 2021 and June 2022, the Court invoked the canon three times, using it aggressively to invalidate some of the signature policies implemented by...
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Chenery II Revisited

Daniel T. Deacon 92 Geo. Wash. L. Rev. 1050 Ever since the Supreme Court’s 1947 decision in SEC v. Chenery Corporation, known as Chenery II, agencies have enjoyed wide latitude to develop policy through individual adjudications in addition to rulemaking. Chenery II has never been completely uncontroversial, and in recent years, calls to overturn or...
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The Ordinary Questions Doctrine

In Loper Bright Enterprises v. Raimondo, the Supreme Court overruled Chevron as inconsistent with the Administrative Procedure Act (“APA”), which requires courts to decide “all relevant questions of law” and therefore prohibits them from deferring to agency interpretations because the relevant statutory language is ambiguous. A different approach now governs judicial review of the countless routine, often specialized questions of statutory interpretation that agencies answer in the normal course of implementing their statutes—the “ordinary” questions.

Balancing the Burden of Qualified Immunity: How to Better Address the Original Intentions of this Limited Defense to § 1983 Claims

Gillian Isabelle 92 Geo. Wash. L. Rev. Arguendo 95 The doctrine of qualified immunity was born in a time of turmoil in the United States. A Supreme Court-created defense meant to shield government officials from petty lawsuits, qualified immunity has become a highly criticized doctrine. This criticism is representative of the ever-growing concern that government...
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Previews for the 2024 October Term of the Supreme Court

As the 2024 Supreme Court term gets underway, several pivotal cases are set to challenge and refine existing legal precedents across a wide range of issues. From questions about federal authority and constitutional rights to crucial interpretations of criminal law, the following case previews provide a glimpse into the issues the Court will tackle and...
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TransUnion LCC v. Ramirez and the Fight to Protect Climate Change Standing

Olivia Venus 92 Geo. Wash. L. Rev. 949 As the impacts of climate change come to fruition, plaintiffs battle strict standing requirements to litigate climate harms. Federal courts impose increasingly strict definitions of injury in fact while Congress continually fails to present a comprehensive climate plan, leaving plaintiffs without a remedy. The Supreme Court recently...
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Shouldn’t All Asylum Be “Humanitarian”? A Case for Merging Traditional and Humanitarian Asylum and Eliminating the Particular Social Group

Katie Cantone-Hardy 92 Geo. Wash. L. Rev. 908 Asylum law in the United States faces near-constant critique. The “membership in a particular social group” eligibility category is one of its persistent thorns. Faced with a lack of legislative instruction on what “particular social group” (“PSG”) means, asylum adjudications of PSG claims have been chronically disjointed....
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