Partner and Co-Chair, Public Policy Group, Shook Hardy & Bacon LLP
Mark Behrens co-chairs Shook's Washington, DC-based Public Policy Practice Group and is a leading national expert on civil justice issues with over thirty years of experience. A substantial part of his practice is working to improve the civil litigation environment through state and federal legislation; in the courts through amicus curiae briefs; through legal scholarship and judicial education; and in the court of public opinion.
Mark is actively involved in civil justice reform efforts at the federal and state levels. He has testified before the U.S. Congress and most state legislatures on behalf of business and civil justice organizations. Mark also has an active amicus brief practice specializing in tort liability and civil justice issues. He has authored or co-authored over 150 amicus briefs in cases before the United States Supreme Court and federal and state appellate courts on behalf of business, civil justice, and defense lawyer organizations. In addition, Mark routinely files comments on behalf of business, civil justice, and defense lawyer organizations regarding potential changes to federal and state court rules. He chairs the International Association of Defense Counsel’s (IADC) Civil Justice Response Committee and serves on the Board of Directors of Lawyers for Civil Justice (LCJ).
Mark is a member of the American Law Institute (ALI). He received his J.D. in 1990 from Vanderbilt University Law School, where he was a member of the Vanderbilt Law Review. He received his B.A. in economics from the University of Wisconsin in 1987.
Professor of Law, University of Minnesota Law School
Professor James W. Coleman is a scholar of energy law. He specializes in North American energy infrastructure, transport, and trade. He is also a nonresident senior fellow at the American Enterprise Institute focused on energy policy.
Professor Coleman has testified before Congress on steps to speed up energy infrastructure permits. He also worked with a team of experts as part of Alberta's Royalty Review to revise the Canadian province's management of its vast oil and gas resources.
Before joining Minnesota, Professor Coleman taught at Southern Methodist University's Dedman School of Law, the University of Calgary’s law and business schools, and Harvard Law School. Earlier, he practiced environmental and appellate law at Sidley Austin in Washington, D.C., and clerked for the Honorable Steven M. Colloton of the U.S. Court of Appeals for the Eighth Circuit.
Professor Coleman received two degrees from Harvard University—a J.D. (cum laude) and B.A. in biology (magna cum laude with highest honors in the field). As a result of his undergraduate thesis on butterfly genetics, which required fieldwork in Central Asia, a species of lycaenid butterfly was named after him—Agrodiaetus ripartii colemani.
Associate Professor of Law, Suffolk University Law School
Sharmila L. Murthy is an Associate Professor at Suffolk University Law School, where she teaches and writes on issues of property law, environmental law, international environmental law, poverty, and human rights. A list of her scholarly publications is available.
Professor Murthy is active with the American Association of Law Schools. She currently serves as Chair of the International Human Rights Section, as Chair-Elect of the Environmental Law Section, and on the Executive Board of the Law and South Asia Studies Section. In 2017, she received the Woman of the Year: Faculty Division from the Suffolk Law Women of Color Law Student Association.
Previously, Professor Murthy was a Visiting Scholar at Harvard Kennedy School of Government, where she served as the lead investigator for water for the Project on Innovation and Access to Technologies for Sustainable Development through the Sustainability Science Program. She also co-founded the Human Rights to Water and Sanitation Program as a Fellow at Harvard Kennedy School’s Carr Center for Human Rights Policy. In addition, Professor Murthy has taught as part of the Water Diplomacy Workshop since 2013. In 2014, Professor Murthy was selected as a finalist for the United Nations Special Rapporteur on the human right to safe drinking water and sanitation.
Professor Murthy began her legal career as a public interest poverty lawyer. She was awarded a Skadden Fellowship to work with the Legal Aid Society of Middle Tennessee and the Cumberlands, where she created the Refugee and Immigrant Partnership Program for Legal Empowerment and litigated predatory lending and foreclosure rescue scam cases. For these efforts, she received the New Advocate of the Year award from the Tennessee Alliance of Legal Services. Professor Murthy also litigated complex and class action cases as an associate with Lieff Cabraser Heimann & Bernstein, where she represented members of the public in mortgage fraud and natural resource cases.
Professor Murthy received her JD from Harvard Law School, her MPA from Harvard Kennedy School of Government, and her BS in Natural Resources from Cornell University. She clerked for the Honorable Martha Craig Daughtrey on the U.S. Court of Appeals for the Sixth Circuit. She was also a U.S. Fulbright Scholar in India, where she studied the rural microfinance program of the Self-Employed Women’s Association.
Professor Murthy also volunteers with several civic and legal organizations. She currently serves on the Massachusetts State Board of the Conservation Law Foundation, on the Scientific Committee of WaterLex, and on the Steering Committee of the Boston Lawyer Chapter of the American Constitution Society (ACS). Previously, she was the President of the Tennessee Immigrant and Refugee Rights Coalition and the founding President of the Nashville ACS Chapter.
Professor of Law, Notre Dame Law School
Professor Derek Muller is a nationally-recognized scholar in the field of election law. His research focuses on the role of states in the administration of federal elections, the constitutional contours of voting rights and election administration, the limits of judicial power in the domain of elections, and the Electoral College.
He has published more than two dozen academic works, and his op-eds have appeared in the New York Times, the Los Angeles Times, and the Wall Street Journal. He has testified before Congress, and he is a contributor at the Election Law Blog. He is a co-author on a Federal Courts casebook published by Carolina Academic Press. He is also the co-reporter on a new Restatement of the Law, Election Litigation, an effort led by the American Law Institute.
Professor Muller teaches Election Law, Civil Procedure, and Evidence.
Associate Dean for Faculty; Charles W. Ebersold and Florence Whitcomb Ebersold Professor of Constitutional Law, The Ohio State University Mortiz College of Law
Professor Daniel Tokaji is an authority on the law of elections and democracy. He teaches courses on Election Law, Civil Rights, Civil Procedure, Comparative Law, Constitutional Law, Federal Courts, Legislation and Regulation, and the U.S. Legal System. His scholarship addresses questions of voting rights, racial justice, free speech, and the role of the courts in American democracy.
Professor Tokaji is the author of Election Law in a Nutshell (2d ed. 2016), and co-author of Election Law: Cases and Materials (6th ed. 2017) and The New Soft Money (2014). He has written numerous articles and book chapters on a wide variety of election and voting issues, including voting rights, voter ID, voter registration, redistricting, campaign finance regulation. Recent articles include “Gerrymandering and Association,” 59 William & Mary Law Review 2159 (2018), and “Denying Systemic Equality: The Last Words of the Kennedy Court,” 13 Harvard Law & Policy Review 539 (2019). His current research focuses on the challenges facing democracies around the globe, including the free speech issues surrounding digital disinformation and the need for trustworthy electoral institutions.
Media outlets frequently seek Professor Tokaji’s expertise on election and voting issues. He has been quoted in The New York Times, Los Angeles Times, The Columbus Dispatch, USA TODAY, and appeared on TODAY, FOX News, NBC News, and National Public Radio and many other media outlets.
A graduate of Harvard College and the Yale Law School, Professor Tokaji clerked for the Honorable Stephen Reinhardt of the U.S. Court of Appeals for the Ninth Circuit. Before arriving at Ohio State, he was a staff attorney with the ACLU Foundation of Southern California and Chair of California Common Cause.
Professor Tokaji has litigated many civil rights, civil liberties, and election law cases. He was lead counsel in a case that struck down an Ohio law requiring naturalized citizens to produce a certificate of naturalization when challenged at the polls. He also served as counsel in litigation challenging the state’s voting purges. He was also an attorney for plaintiffs in cases that kept open the window for simultaneous registration and early voting in Ohio’s 2008 general election, and that challenged punch-card voting systems in Ohio and California after the 2000 election.
President Emeritus, Intercollegiate Studies Institute
T. Kenneth Cribb Jr. is the former president of the Intercollegiate Studies Institute. Mr. Cribb was Assistant to the President for Domestic Affairs in the Reagan administration, serving as President Reagan’s top adviser on domestic matters. Earlier in the administration he held the position of Counselor to the Attorney General. He also served as Vice Chairman of the Fulbright Foreign Scholarship Board from 1989 to 1992.
Ronald Reagan Distinguished Fellow Emeritus, The Heritage Foundation
Edwin Meese III, the prominent conservative leader, thinker and elder statesman, continues a quarter-century formal association with The Heritage Foundation as the leading think tank’s Ronald Reagan Distinguished Fellow Emeritus.
In that capacity, Meese oversees special projects and acts as an ambassador for Heritage within the conservative movement.
Meese was chairman of Heritage’s Center for Legal and Judicial Studies from its founding in 2001 until what he calls his “semi-retirement” on Feb. 1, 2013.
He joined Heritage in 1988 as the think tank's first Ronald Reagan Distinguished Fellow -- the only policy chair in the country to be officially named for the 40th president. His work focused on keeping President Reagan’s legacy of conservative principles alive in public debate and discourse.
The legal center now bears his name, in recognition of Meese’s contributions to the rule of law and the nation’s understanding of constitutional law. Its mission is to educate government officials, the media and the public about the Constitution and legal principles -- and how they affect public policy.
Perhaps best known as U.S. attorney general during Reagan’s second term, Meese’s service to the conservative icon stretched from the California governor’s mansion in 1966 to the White House in 1981 before he went to the Department of Justice four years later.
His Heritage “hats” kept Meese among the major conservative voices in national policy debates at an age when most men and women enjoyed quiet retirements.
In 2006, for example, Meese was named to the Iraq Study Group, a special presidential commission dedicated to examining the best resolutions for America's involvement in Iraq. In the past few years he wrote and spoke about constitutional topics ranging from religious liberty to the responsibility of Supreme Court justices.
Immediately after Reagan's death in 2004, and in the years since, Meese often agreed to major media appearances to discuss the lasting impact of his old friend, mentor and boss. He has summarized the Reagan legacy in three accomplishments: Reagan cut taxes and kept them low. He worked to defeat and end the Soviet Union and its worldwide push for communism. And he restored America's faith in itself after years of failure and "malaise."
"I admired him as a leader and cherish his friendship," Meese wrote in a 2004 essay for Heritage members and supporters. "Ronald Reagan had strong convictions. He was committed to the principles that had led to the founding of our nation. And he had the courage to follow his convictions against all odds." <[>Edwin Meese III was born Dec. 2, 1931, to Edwin Jr. and Leone Meese in Oakland, Calif. He graduated from Yale University in 1953 and holds a law degree from the University of California-Berkeley.
Meese spent much of his adult life working for Reagan, first after the former actor, sports announcer and athlete was elected as California’s governor in 1966 and then when he sought and won the presidency in 1980.
Reagan never forgot Meese's loyalty and hard work. During a press conference at which reporters questioned Meese's actions at the Justice Department, Reagan replied: "If Ed Meese is not a good man, there are no good men."
During the Reagan governorship, Meese served as executive assistant and chief of staff from 1969 through 1974 and as legal affairs secretary from 1967 through 1968. He previously was deputy district attorney in Alameda County, Calif.
From January 1981 to February 1985, Meese held the position of counsellor to the president -- the senior job on the White House staff -- and functioned as Reagan's chief policy adviser. In 1985, he received Government Executive magazine's annual award for excellence in management.
Meese served as the 75th attorney general of the United States from February 1985 to August 1988. As the nation's chief law enforcement officer, he directed the Justice Department and led international efforts to combat terrorism, drug trafficking and organized crime.
Meese’s relationship with Heritage began when he met with senior management to discuss the think tank's landmark policy guide, Mandate for Leadership, prepared for the incoming administration. Meese later recalled that Reagan personally handed out copies of the 1,093-page book to members of his Cabinet and asked them to read it. Nearly two-thirds of Mandate's 2,000 recommendations would be adopted or attempted by the Reagan administration.
More than a decade after joining Heritage, Meese assumed the chairmanship of its Center for Legal and Judicial Studies. Under his guidance, the center counseled White House staffers, Justice Department officials and Senate Judiciary Committee members on the importance of filling judicial vacancies with qualified men and women who are committed to interpreting the Constitution according to the founding document's original meaning.
The center became known for hosting "moot court" practice sessions to sharpen the arguments of attorneys slated to bring important cases before the Supreme Court. Those cases addressed constitutional issues ranging from property rights to racial preferences in primary and secondary schools to restrictions on free speech in campaign finance law.
Meese headed the legal center's Advisory Board for the writing and editing of the best-selling book, The Heritage Guide to the Constitution (Regnery, 2005). In it, 109 experts walked readers through a clause-by-clause analysis of the Constitution. Sen. Tom Coburn (R-Okla.) was among those keeping the reference work handy during Judiciary Committee hearings on Supreme Court nominees.
Meese's other books include “Leadership, Ethics and Policing” (Prentice Hall, 2004); “Making America Safer” (Heritage, 1997); and “With Reagan: The Inside Story” (Regnery Gateway, 1992).He wrote the Introduction to a well-received 2010 book on the “overcriminalization” trend, “One Nation Under Arrest,” by Heritage veterans Paul Rosenzweig and Brian W. Walsh.
He also is a distinguished visiting fellow at the Hoover Institution at Stanford University in California and lectures, writes and consults throughout the United States on a variety of subjects.
As both attorney general and counsellor to Reagan, Meese was a member of the Cabinet and the National Security Council. He served as chairman of the Domestic Policy Council and the National Drug Policy Board. After Reagan won the White House in the 1980 election, Meese headed the transition team. During the campaign, he was the Reagan-Bush Committee's senior official.
Meese had a career outside government and politics. From 1977 to 1981, he was a law professor at the University of San Diego, where he also directed the Center for Criminal Justice Policy and Management.
He was an executive in the aerospace and transportation industry as vice president for administration of Rohr Industries Inc. in Chula Vista, Calif. He left Rohr to return to the practice of law, doing corporate and general work in San Diego County.
A retired colonel in the Army Reserve, Meese remains active in numerous civic and educational organizations.
He and his wife, Ursula, have two grown children and reside in McLean, Va.
Former United States Assistant Attorney General, Civil Rights Division, United States Department of Justice
William Bradford served as the United States Assistant Attorney General for the Civil Rights Division from 1981 to 1988.
Reynolds was Senior Counsel in BakerBotts Antitrust and Competition division. He graduated with a LL.B. from Vanderbilt University Law School in 1967 where he was Order of the Coif and Editor-in-Chief of the Vanderbilt Law Review. In 1964, he received a B.A. from Yale University.
Reynolds passed away on September 14, 2019, in Seabrook Island, South Carolina at age 77.
President Emeritus, Intercollegiate Studies Institute
T. Kenneth Cribb Jr. is the former president of the Intercollegiate Studies Institute. Mr. Cribb was Assistant to the President for Domestic Affairs in the Reagan administration, serving as President Reagan’s top adviser on domestic matters. Earlier in the administration he held the position of Counselor to the Attorney General. He also served as Vice Chairman of the Fulbright Foreign Scholarship Board from 1989 to 1992.
Ronald Reagan Distinguished Fellow Emeritus, The Heritage Foundation
Edwin Meese III, the prominent conservative leader, thinker and elder statesman, continues a quarter-century formal association with The Heritage Foundation as the leading think tank’s Ronald Reagan Distinguished Fellow Emeritus.
In that capacity, Meese oversees special projects and acts as an ambassador for Heritage within the conservative movement.
Meese was chairman of Heritage’s Center for Legal and Judicial Studies from its founding in 2001 until what he calls his “semi-retirement” on Feb. 1, 2013.
He joined Heritage in 1988 as the think tank's first Ronald Reagan Distinguished Fellow -- the only policy chair in the country to be officially named for the 40th president. His work focused on keeping President Reagan’s legacy of conservative principles alive in public debate and discourse.
The legal center now bears his name, in recognition of Meese’s contributions to the rule of law and the nation’s understanding of constitutional law. Its mission is to educate government officials, the media and the public about the Constitution and legal principles -- and how they affect public policy.
Perhaps best known as U.S. attorney general during Reagan’s second term, Meese’s service to the conservative icon stretched from the California governor’s mansion in 1966 to the White House in 1981 before he went to the Department of Justice four years later.
His Heritage “hats” kept Meese among the major conservative voices in national policy debates at an age when most men and women enjoyed quiet retirements.
In 2006, for example, Meese was named to the Iraq Study Group, a special presidential commission dedicated to examining the best resolutions for America's involvement in Iraq. In the past few years he wrote and spoke about constitutional topics ranging from religious liberty to the responsibility of Supreme Court justices.
Immediately after Reagan's death in 2004, and in the years since, Meese often agreed to major media appearances to discuss the lasting impact of his old friend, mentor and boss. He has summarized the Reagan legacy in three accomplishments: Reagan cut taxes and kept them low. He worked to defeat and end the Soviet Union and its worldwide push for communism. And he restored America's faith in itself after years of failure and "malaise."
"I admired him as a leader and cherish his friendship," Meese wrote in a 2004 essay for Heritage members and supporters. "Ronald Reagan had strong convictions. He was committed to the principles that had led to the founding of our nation. And he had the courage to follow his convictions against all odds." <[>Edwin Meese III was born Dec. 2, 1931, to Edwin Jr. and Leone Meese in Oakland, Calif. He graduated from Yale University in 1953 and holds a law degree from the University of California-Berkeley.
Meese spent much of his adult life working for Reagan, first after the former actor, sports announcer and athlete was elected as California’s governor in 1966 and then when he sought and won the presidency in 1980.
Reagan never forgot Meese's loyalty and hard work. During a press conference at which reporters questioned Meese's actions at the Justice Department, Reagan replied: "If Ed Meese is not a good man, there are no good men."
During the Reagan governorship, Meese served as executive assistant and chief of staff from 1969 through 1974 and as legal affairs secretary from 1967 through 1968. He previously was deputy district attorney in Alameda County, Calif.
From January 1981 to February 1985, Meese held the position of counsellor to the president -- the senior job on the White House staff -- and functioned as Reagan's chief policy adviser. In 1985, he received Government Executive magazine's annual award for excellence in management.
Meese served as the 75th attorney general of the United States from February 1985 to August 1988. As the nation's chief law enforcement officer, he directed the Justice Department and led international efforts to combat terrorism, drug trafficking and organized crime.
Meese’s relationship with Heritage began when he met with senior management to discuss the think tank's landmark policy guide, Mandate for Leadership, prepared for the incoming administration. Meese later recalled that Reagan personally handed out copies of the 1,093-page book to members of his Cabinet and asked them to read it. Nearly two-thirds of Mandate's 2,000 recommendations would be adopted or attempted by the Reagan administration.
More than a decade after joining Heritage, Meese assumed the chairmanship of its Center for Legal and Judicial Studies. Under his guidance, the center counseled White House staffers, Justice Department officials and Senate Judiciary Committee members on the importance of filling judicial vacancies with qualified men and women who are committed to interpreting the Constitution according to the founding document's original meaning.
The center became known for hosting "moot court" practice sessions to sharpen the arguments of attorneys slated to bring important cases before the Supreme Court. Those cases addressed constitutional issues ranging from property rights to racial preferences in primary and secondary schools to restrictions on free speech in campaign finance law.
Meese headed the legal center's Advisory Board for the writing and editing of the best-selling book, The Heritage Guide to the Constitution (Regnery, 2005). In it, 109 experts walked readers through a clause-by-clause analysis of the Constitution. Sen. Tom Coburn (R-Okla.) was among those keeping the reference work handy during Judiciary Committee hearings on Supreme Court nominees.
Meese's other books include “Leadership, Ethics and Policing” (Prentice Hall, 2004); “Making America Safer” (Heritage, 1997); and “With Reagan: The Inside Story” (Regnery Gateway, 1992).He wrote the Introduction to a well-received 2010 book on the “overcriminalization” trend, “One Nation Under Arrest,” by Heritage veterans Paul Rosenzweig and Brian W. Walsh.
He also is a distinguished visiting fellow at the Hoover Institution at Stanford University in California and lectures, writes and consults throughout the United States on a variety of subjects.
As both attorney general and counsellor to Reagan, Meese was a member of the Cabinet and the National Security Council. He served as chairman of the Domestic Policy Council and the National Drug Policy Board. After Reagan won the White House in the 1980 election, Meese headed the transition team. During the campaign, he was the Reagan-Bush Committee's senior official.
Meese had a career outside government and politics. From 1977 to 1981, he was a law professor at the University of San Diego, where he also directed the Center for Criminal Justice Policy and Management.
He was an executive in the aerospace and transportation industry as vice president for administration of Rohr Industries Inc. in Chula Vista, Calif. He left Rohr to return to the practice of law, doing corporate and general work in San Diego County.
A retired colonel in the Army Reserve, Meese remains active in numerous civic and educational organizations.
He and his wife, Ursula, have two grown children and reside in McLean, Va.
Former United States Assistant Attorney General, Civil Rights Division, United States Department of Justice
William Bradford served as the United States Assistant Attorney General for the Civil Rights Division from 1981 to 1988.
Reynolds was Senior Counsel in BakerBotts Antitrust and Competition division. He graduated with a LL.B. from Vanderbilt University Law School in 1967 where he was Order of the Coif and Editor-in-Chief of the Vanderbilt Law Review. In 1964, he received a B.A. from Yale University.
Reynolds passed away on September 14, 2019, in Seabrook Island, South Carolina at age 77.
Shareholder, Brownstein, Hyatt, Farber, Shreck
With more than 20 years of experience both as a first-chair litigator and in public service, Greg Brower’s practice focuses on civil and criminal litigation, as well as regulatory and enforcement actions, corporate investigations, cybersecurity matters and federal and state government relations.
Most recently, Greg served as the assistant director for the Office of Congressional Affairs at the Federal Bureau of Investigation (FBI), serving as the FBI’s chief liaison to Congress on a wide range of critical oversight and investigative matters. He previously served as the FBI’s Deputy General Counsel, managing a diverse portfolio of legal matters, including litigation, privacy, procurement, compliance and ethics. During his time as a senior FBI executive, spanning two administrations, he worked closely with high-ranking officials in the U.S. Department of Justice (DOJ), the U.S. intelligence community and with key leaders on Capitol Hill. Greg is a regular commentator and contributor on national security, legal and cybersecurity issues, regularly appearing on CNN and MSNBC, and he is the featured contributor on white collar crime and corporate compliance for the Washington Legal Foundation’s Legal Pulse blog.
Greg has a long history of public service. At the federal level, he previously served as the U.S. Attorney for the District of Nevada, and as both General Counsel and Inspector General at the U.S. Government Publishing Office. Greg also served at DOJ as Legislative Counsel in the Executive Office for U.S. Attorneys. At the state level, he has served in a variety of public policy roles, including five terms in the Nevada Legislature, where he was chairman of the Senate Judiciary Committee. He has also served on the Nevada Gaming Policy Committee, the Nevada Advisory Commission on the Administration of Justice, the Nevada Sentencing Commission and the Nevada Juvenile Justice Commission.
Throughout his career, Greg has served the Nevada legal community as an adjunct professor of law at the William S. Boyd School of Law at the University of Nevada, Las Vegas, where he has taught courses in national security law and trial advocacy. Before attending law school, Greg served in the U.S. Navy as a Surface Warfare Officer.
Executive Director, Alliance For Consumers
O.H. leads Alliance For Consumers, which fights to ensure that consumer protection efforts, class action lawsuits, and attorney general enforcement actions are consistent with the rule of law and benefit everyday consumers, not just class action lawyers and career bureaucrats.
His work with AFC builds off his time with the Arizona Attorney General's Office under Attorney General Mark Brnovich, where he not only defended constitutional questions and served as the State's lead counsel in the U.S. Supreme Court, but also had the privilege of leading Arizona's consumer protection lawsuit against Google over the tracking of consumers' location, and the successful case against Volkswagen over well-publicized diesel-related consumer deception.
O.H. is a 2010 graduate of Harvard Law School. Before joining Attorney General Brnovich in 2016, O.H. practiced at WilmerHale and Ropes & Gray in Boston and clerked for the Hon. J.L. Edmondson of the United States Court of Appeals for the Eleventh Circuit in Atlanta, Georgia.
2019 Civil Justice Update
Mark A. Behrens
White Paper
Note from the Editor: The Federalist Society takes no positions on particular legal and public...
Topics
Lemon is Dead
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Banquet Speech by Attorney General Edwin Meese III [Archive Collection]
T. Kenneth Cribb, Edwin Meese, Wm. Bradford Reynolds
First Annual National Lawyers Convention
On January 30, 1987, the Federalist Society hosted its annual National Lawyers Convention at the...
Banquet Speech by Attorney General Edwin Meese III [Archive Collection]
T. Kenneth Cribb, Edwin Meese, Wm. Bradford Reynolds
First Annual National Lawyers Convention
On January 30, 1987, the Federalist Society hosted its annual National Lawyers Convention at the...
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featuring Gregory Brower
On Feb. 26, 2020, in a 9-0 decision, the Supreme Court decided Shular v. United...
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On Tuesday, in a 5-4 decision in McKinney v. Arizona, the Supreme Court of the...