[EL] Analysis of the Supreme Court's North Carolina Racial Redistricting Decision

Tue May 23 12:12:33 PDT 2017

I think the answer is more likely to be no. In central North Carolina, I
don't believe it's possible to draw a *reasonably compact* majority-minority
district, so prong 1 isn't satisfied (see *Shaw v. Hunt*). In eastern North
Carolina, it's unclear whether a reasonably compact majority-minority
district can be drawn, and the Court held that there was insufficient white
bloc voting to satisfy prong 3. So putting aside potential issues of
intentional vote dilution, I don't think the *Gingles* factors can be
satisfied in either area.

On Tue, May 23, 2017 at 1:56 PM, David Ely <ely at compass-demographics.com>
wrote:

> I think the answer to Justin's question is pretty clearly yes (If I
> understand the question correctly.). North Carolina has demonstrated that
> the first prong is met. (Possible to create 2 majority districts). If there
> were not 2 districts in which minority communities had an opportunity to
> elect, then certainly you would be able to meet the second and third prong.
> Given the issues here, not having 2 opportunity districts would almost
> certainly also satisfy the totality of circumstance requirement to find a
> section 2 violation.
>
>
> ------------------------------
> *From:* Justin Levitt <levittj at lls.edu>
> *To:* law-election at department-lists.uci.edu
> *Sent:* Tuesday, May 23, 2017 11:46 AM
> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina Racial
> Redistricting Decision
>
> I think both the conversation we've been having and the North Carolina
> opinion itself show that that's not quite the right question.
>
> Perhaps a friendly amendment: the question is really whether, at the end
> of the day, North Carolina needs to create two districts providing the
> minority community with an opportunity to elect candidates of choice.  The
> election results showed that both pre-existing districts got there without
> being "majority-minority."
>
> On 5/23/2017 11:12 AM, Mark Rush wrote:
>
> Hi all--
>
> A basic question:  Am I correct that, at the end of the day, North
> Carolina still needs to create two majority-minority districts?  Thanks to
> all.
>
> On Tue, May 23, 2017 at 1:34 PM, Nicholas Stephanopoulos <
> nicholas.stephanopoulos at gmail.com> wrote:
>
> The way to reconcile this tension, I think, is to treat the crossover
> district as a *remedy* for a Section 2 violation (or a prophylactic
> measure against future Section 2 liability). After all, in *every *minority
> opportunity district (crossover or not), there's insufficient white bloc
> voting to defeat the minority-preferred candidate. That doesn't mean that
> Section 2 becomes inapplicable once the opportunity district is drawn; it
> means that Section 2 has been complied with through the opportunity
> district's creation.
>
> On Tue, May 23, 2017 at 12:26 PM, Pamela S Karlan <pkarlan at stanford.edu>
> wrote:
>
> But the third prong of Gingles is not simply that there be majority-bloc
> voting, but that that bloc voting be sufficient to defeat the minority's
> preferred candidate.  In the example from Justice Souter, while there's
> lots of bloc voting, it's not causing the defeat of the minority-preferred
> candidate.
>
> I agree with your larger point about remedies and the like.  I'm just
> saying that it's hard simultaneously to claim that something is a crossover
> district and that the white voters in that district vote sufficiently as a
> bloc so as usually to defeat the minority's candidate of choice (the third
> Gingles prong).
>
> Pamela S. Karlan
> Kenneth and Harle Montgomery Professor of Public Interest Law
> Co-Director, Supreme Court Litigation Clinic
> Stanford Law School
> karlan at stanford.edu
> 650-725-4851
>
>
> ------------------------------
> *From:* Nicholas Stephanopoulos <nicholas.stephanopoulos at gmail .com
> <nicholas.stephanopoulos at gmail.com>>
> *Sent:* Tuesday, May 23, 2017 10:22 AM
> *To:* Pamela S Karlan
> *Cc:* Pildes, Rick; law-election at department-lists. uci.edu
> <law-election at department-lists.uci.edu>
>
> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina Racial
> Redistricting Decision
>
> It's certainly true that in *some* crossover districts (like North
> Carolina's District 1), the third *Gingles* criterion can't be satisfied
> because the level of crossover voting is too high. (Though I'd note that to
> determine this with confidence, a proper racial polarization analysis would
> be better than just data on minority population share and election
> outcomes.) But there are clearly other crossover districts where the third
> *Gingles* criterion can be satisfied. Here's a good example from Justice
> Souter's dissent in *Bartlett*:
>
> "If a minority population with 49% of the CVAP can elect the candidate of
> its choice with crossover by 2% of white voters, the minority 'by
> definition' relies on white support to elect its preferred candidate. But
> this fact alone would raise no doubt, as a matter of definition or
> otherwise, that the majority-bloc-voting requirement could be met, since as
> much as 98% of the majority may have voted against the minority’s candidate
> of choice."
>
> Based on *Bartlett *and *Cooper*, I think it's now clear that (1) the
> potential existence of such a crossover district isn't enough to satisfy
> the first *Gingles* prong -- it has to be possible to draw another
> majority-minority district; but (2) such a crossover district can be
> created by a jurisdiction as a remedy for a Section 2 violation; and (3) if
> such a district is dismantled, there can be liability under Section 2
> (provided all of the *Gingles* prongs are satisfied).
>
> On Tue, May 23, 2017 at 11:46 AM, Pamela S Karlan <pkarlan at stanford.edu>
> wrote:
>
> The discussion on the list has been very interesting.  Nick writes that
>
> 2. Another question left open by the Court’s case law is whether crossover
> districts can comply with Section 2 when all three *Gingles*
> preconditions *are* satisfied. This precise fact pattern was not before
> the Court since there was insufficient white bloc voting in District 1 to
> meet the third *Gingles* precondition. However, the Court’s opinion
> hinted pretty clearly that crossover districts are acceptable Section 2
> remedies, even under conditions of severe racial polarization.
>
> I was a bit confused by this.  The third Gingles precondition is that "the
> minority must be able to demonstrate that the white majority votes
> sufficiently as a bloc to enable it - in the absence of special
> circumstances, such as the minority candidate running unopposed, . . . -
> usually to defeat the minority's preferred candidate."  Gingles, 478 U.S.
> at 51.  So I'm not sure that there can *be* crossover districts in the
> face of the third Gingles precondition.
>
> To be sure, there can be crossover districts in the face of significant
> white bloc voting.  E.g., in a district where the electorate is 40% black
> and black voters are entirely cohesive, the black voters' candidate of
> choice can win even if only about 18 percent of the white electorate
> crosses over.  But if that crossover occurs consistently, then the third
> Gingles precondition won't be satisfied, will it?
>
> Pamela S. Karlan
> Kenneth and Harle Montgomery Professor of Public Interest Law
> Co-Director, Supreme Court Litigation Clinic
> Stanford Law School
> karlan at stanford.edu
> 650-725-4851
>
>
> ------------------------------
> *From:* law-election-bounces at departmen t-lists.uci.edu
> <law-election-bounces at department-lists.uci.edu> <law-election-bounces at departme
> nt-lists.uci.edu <law-election-bounces at department-lists.uci.edu>> on
> behalf of Pildes, Rick <pildesr at mercury.law.nyu.edu>
> *Sent:* Monday, May 22, 2017 3:18 PM
> *To:* Nicholas Stephanopoulos
> *Cc:* law-election at department-lists. uci.edu
> <law-election at department-lists.uci.edu>
>
> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina Racial
> Redistricting Decision
>
> For those who are not steeped in these issues, I want to point out the
> broad significance of the graph Nick Stephanopoulos included in his
> message/post.  That graph shows that the way the VRA affected districts
> throughout the South was to push minority voters (mainly, black voters)
> into two predominant types of districts:  those with a 60% minority
> voting-age population and those with a 20% voting-age minority population.
> What this did was to dramatically reduce throughout the South the number of
> districts in which minority voters constituted 30-50% of the voting-age
> population.
>
> These 30-50% minority districts were the ones that tended to elect white
> Democrats in the South.  As a result, the ranks of white Democrats in the
> South were significantly reduced, starting in the 1990s when this system
> went into effect.  The 20% minority population districts tended to elect
> Republicans.  The 60% minority districts tended to elect black Democrats.
>
> Nick’s graph, aggregated across all districts in the South, sharply
> illustrates this VRA-induced sorting.
>
> Richard H. Pildes
> Sudler Family Professor of Constitutional Law
> NYU School of Law
> 40 Washington Square South, NY, NY 10012
> 212 998-6377
>
> *From:* Nicholas Stephanopoulos [mailto:nicholas.stephanopoulo s at gmail.com
> <nicholas.stephanopoulos at gmail.com>]
> *Sent:* Monday, May 22, 2017 4:37 PM
> *To:* Pildes, Rick
> *Cc:* Justin Levitt; law-election at department-lists. uci.edu
> <law-election at department-lists.uci.edu>
> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina Racial
> Redistricting Decision
>
> A few more points to add to the analyses by Rick H., Rick P., and Justin:
>
> 1. Ever since *Gingles* itself, it has been an open question whether the
> mere *fact* of racial polarization in voting suffices to satisfy the
> case’s second and third prongs. (Justice Brennan’s opinion said yes, but it
> commanded only four votes on this issue. Some lower courts—including the
> Fifth Circuit—subsequently held that the prongs are *not* satisfied if
> partisanship explains racial polarization.)
>
> Today the Court strongly suggests that the causes of racial polarization
> are irrelevant. In the Court’s long discussion of crossover voting in
> District 1, it does not mention a single potential explanation for voter
> behavior: not partisanship, not racial animus (or its absence), not
> socioeconomic characteristics, not anything. Instead, the Court relies
> exclusively on the raw election returns, which indicate that substantial
> crossover voting must be occurring since black-preferred candidates
> consistently won elections with ~65% of the vote even though blacks made up
> only ~48% of District 1’s population.
>
> Going forward, I expect that Section 2 plaintiffs will be able to use the
> Court’s discussion as a powerful rejoinder to any argument that racial
> polarization should not “count” for *Gingles* purposes if it is the
> product of some non-racial factor. This should make it significantly easier
> for plaintiffs to satisfy the *Gingles* preconditions, especially in
> areas (like the Fifth Circuit) where courts had previously probed quite
> rigorously the reasons for racial polarization.
>
> 2. Another question left open by the Court’s case law is whether crossover
> districts can comply with Section 2 when all three *Gingles*
> preconditions *are* satisfied. This precise fact pattern was not before
> the Court since there was insufficient white bloc voting in District 1 to
> meet the third *Gingles* precondition. However, the Court’s opinion
> hinted pretty clearly that crossover districts are acceptable Section 2
> remedies, even under conditions of severe racial polarization. In the key
> passage, the Court quoted North Carolina’s position that if “§ 2 does not *require
> *crossover districts . . . then § 2 also cannot be *satisfied* *by*
> crossover districts.” This stance, declared the Court, “is at war with our
> § 2 jurisprudence.”
>
> Several implications follow. First, jurisdictions that are successfully
> sued under Section 2 should be able to design crossover districts as a
> remedy for the violation. Second, Section 2 suits should fail if they are
> used to challenge existing crossover districts (in an effort to replace
> them with majority-minority districts). And third, as in *Cooper*,
> jurisdictions should not be able to use Section 2 compliance as a defense
> in a racial gerrymandering case if they convert crossover districts into
> majority-minority districts. Arguably, all of this was implicit in
> *Bartlett*, but it’s still important to see the Court providing
> confirmation.
>
> 3. Finally, there are *many* majority-minority districts, both in the
> South and elsewhere in the country, where functioning crossover districts
> could be drawn instead. In an article
> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2336749> a few years
> back, I created the below density curve of minority population share in all
> districts (congressional and state legislative) in states previously
> covered by Section 5. The distribution is clearly bimodal, with one of its
> peaks around *60%* minority voting age population. The district
> distribution also looks nothing like the underlying distribution of
> minority population share at the precinct level, which is unimodal and
> normal in shape. This suggests that the district distribution—with its many
> majority-minority districts—is the product of intentional racial
> redistricting.
>
> Of course, the mere fact that a crossover district could have been drawn
> in an area where a majority-minority district was drawn instead does not
> establish that race was the predominant factor in the district’s creation.
> The plaintiffs in *Cooper* had much more damning evidence than that,
> including the use of an explicit racial target. Nevertheless, it is
> certainly relevant that many majority-minority districts are more “packed”
> than they need to be to comply with Section 2—likely intentionally in many
> cases. This means that *Cooper*’s reach could be greater than that of the
> racial gerrymandering cases the Court has previously decided this cycle.
>
>  [image: Inline image 1]
>
> On Mon, May 22, 2017 at 2:18 PM, Pildes, Rick <pildesr at mercury.law.nyu.edu>
> wrote:
> Had I know Justin was posting a critique of Rick Hasen and the NC case, I
> would not have found a need myself to do a second post on the case to
> explain why I reject Rick Hasen’s analysis of the decision.  I agree with
> Justin’s critique on that, but I had already gone ahead and posted my
> similar critique, here <http://electionlawblog.org/?p=92706>, on the
> problems with Rick Hasen’s discussion.
>
> Best,
> Rick
>
> Richard H. Pildes
> Sudler Family Professor of Constitutional Law
> NYU School of Law
> 40 Washington Square South, NY, NY 10012
> 212 998-6377
>
> *From:* law-election-bounces at departmen t-lists.uci.edu
> <law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at d
> epartment-lists.uci.edu <law-election-bounces at department-lists.uci.edu>] *On
> Behalf Of *Justin Levitt
> *Sent:* Monday, May 22, 2017 2:55 PM
> *To:* law-election at department-lists. uci.edu
> <law-election at department-lists.uci.edu>
> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina Racial
> Redistricting Decision
>
> If you're looking for a reaction to the NC redistricting case from someone
> not named Rick, I'll offer my version, now up on the Election Law Blog
> <http://electionlawblog.org/?p=92700>.
> Though I agree with a lot of both Ricks' assessment, I pretty strongly
> disagree with Rick Hasen that the Court just conflated race and party.
> Indeed, I think that's the same sort of overly blunt, back-of-the-envelope
> assessment that got the legislators in North Carolina (and several other
> states now <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2487426>)
> in trouble.
> Instead, I think the Court "just" reiterated the notion that whether tribally
> partisan <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2239491>
> motivations are themselves permissible (more to come in both the Wisconsin
> case and in Part 6 of the North Carolina CD12 saga), it's unlawful to
> intentionally use race as the predominant and unjustified means to that
> end.  I put "just" in scare quotes because it's a concept that in the
> dilution context is quite old, but legislators seem to need fairly constant
> reminders.  And the fact that the Court issued yet another forceful
> reminder isn't a small thing.
> (Much) more on the blog, here <http://electionlawblog.org/?p=92700>.
> Justin
>
> --
>
> Justin Levitt
>
> Professor of Law
>
> Loyola Law School | Los Angeles
>
> 919 Albany St.
>
> Los Angeles, CA  90015
>
> 213-736-7417
>
> ssrn.com/author=698321
>
> @_justinlevitt_
>
> On 5/22/2017 9:32 AM, Pildes, Rick wrote:
>
> I have been asked to contribute to a SCOTUS blog Symposium on today’s
> North Carolina decision.  Here is the piece I have submitted, which I
> wanted to circulate to the list while it is in the editing process at the
> SCOTUS blog, for those who are trying to digest the decision now:
>
> *The Court Continues Winding Down Unnecessary Racial Redistricting  *
>
> The main take-away from today’s decision is that the Supreme Court is
> continuing the project of winding down unnecessary racial redistricting.
> The decision reflects the Court’s effort to modernize the Voting Rights Act
> (VRA) and ensure it adapts to the way the dynamics of race and politics
> have changed, in some parts of the country, in the many decades since the
> Act first was passed.  The crucial fact in today’s decision is that 30-40%
> of white voters in parts of North Carolina are willing to cross-over and
> vote for the same candidates that African American voters prefer – and that
> the VRA must reflect and recognize these changing realities.
>
> The Court today shored up the constitutional constraints limiting the use
> of race in redistricting, which has been the main development in the law of
> redistricting this decade.  That development began with the *Alabama *cases,
> *Alabama Legislative Black Caucus v. Alabama, *and has now been extended
> to Virginia and North Carolina.  And the Court also opened up a new avenue
> of constraint by holding that if white voters now vote for candidates black
> voters prefer at high enough rates, the intentional creation of
> majority-black districts is no longer required – and indeed, is
> unconstitutional.
> Let me situate today’s decision, before turning to its specifics, in the
> broader context of the Voting Rights Act and how race came to play the role
> it currently does in the modern era of redistricting.
> The regime of Voting Rights Act-required racial redistricting began in the
> 1990s, in the wake of Congress’ 1982 Amendments to the VRA and the Supreme
> Court’s 1986 decision in *Thornburg v. Gingles.  *But almost immediately
> after the start of that regime, beginning with the *Shaw v. Reno *line of
> cases, the Court has been struggling to cabin in and constrain VRA-required
> race-based districting to circumstances in which it is truly necessary.  In
> an opinion by Justice Souter back in 1994, *Johnson v. DeGrandy, *the
> Court wrote that race-based districting under the VRA relies “on a
> quintessentially race-conscious calculus aptly described as the ‘politics
> of the second best.’”  A majority of the Court – confirmed by the parts of
> today’s opinion that are unanimous – has acted on that view ever since.
> If the VRA truly requires race- based districting in certain circumstances,
> that is fine.  But the Court has been extremely wary of extending the
> regime of race-based districting anywhere beyond those circumstances.
>
> Over the last 30 years, the Court has held that the VRA does not require
> maximizing the number of minority districts, but only ensuring that
> minority voters have an equal opportunity to elect their candidates of
> choice; it has held that the VRA does not require (and the Constitution
> prohibits) using irregular district shapes to create “minority opportunity”
> districts; it has held that the VRA does not apply if minorities cannot be
> made into the majority  in a district.  And with ever more force – as in
> today’s decision – the Court has held that the Constitution is violated if
> jurisdictions use the VRA to engage in race-based districting unless it is
> clear that the VRA clearly requires doing so.  I viewed  developments as
> moving in this direction back in a 2007 article, *The Decline of Legally
> Mandated Representation,
> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1028607>* and since
> then, the Court’s efforts to constrain unnecessary race-based districting
> have become only more forceful.
>
> The most important aspect of today’s decision is the Court’s *unanimous *conclusion
> that Congressional District 1 (CD 1) is an unconstitutional racial
> gerrymander.  It would be easy to miss that this part of the opinion is
> unanimous, because the Court divided 5-3 on a second district at stake, CD
> 12.  But I have always said <https://electionlawblog.org/?p=92393> the
> most important issue in the NC case was that involving CD 1, and there, the
> Court was indeed unanimous.  And here, what is critical is that the Court
> rejected North Carolina’s argument that the VRA required it to create a
> majority-black district to make sure black voters had equal political
> opportunity.  More specifically, the Court concluded that voting in this
> area was not racially polarized enough to require the remedy of a
> majority-black district.
> What does it mean for voting to be racially polarized (RPV)?  This has
> been a key concept under the VRA, and yet the Court has given the concept
> almost no significant attention – with today’s decision being the Court’s
> first and thus most significant opening up of questions about this
> concept.
>
> When RPV first entered this area of the law, the idea was simple: if 90%
> of blacks vote for one candidate and 90% of whites vote for the opposing
> candidate (especially when the former candidate is black), there is a clear
> pattern of RPV.  But what happens when – as in North Carolina today –
> roughly 30-40% of whites are willing to vote for minority candidates?
> Since the VRA is only triggered in the redistricting area when voting is
> racially polarized, should RPV still be considered to exist in NC when
> there is this level of white cross-over voting support?  If the VRA still
> applies, how does it apply when we no longer have in NC the extreme and
> stark racial polarization of earlier decades?
>
> Here is how the Court resolves these issues as they come to bear in CD 1:
> for the last twenty or so years, there was enough white cross-over voting
> support that even though the district had a black population of only
> 46-48%, it overwhelmingly and repeated elected a black member of Congress –
> typically, with 70% of the vote.  Yet North Carolina took the view that the
> VRA required pump up the black population above 50% to be sure the district
> was “safe” in ensuring for black voters an equal opportunity.  But the
> Court held that voting cannot be considered racially polarized if there is
> enough white cross-over support that black candidates are being elected
> from districts that are less than 50% black.
> This conclusion is of great significance in further unwinding unnecessary
> racial redistricting.  It means that the mechancial creation of
> majority-minority districts will no longer be constitutionally tolerated.
> If a cohesive black community can get its preferred candidates elected in
> districts that are, perhaps, only 35-40% black, then pumping those
> districts up to more than 50% black – on the view that the VRA requires it
> – will be unconstitutional.  This opens up much more space for the creation
> of what I have called coalitional or cross-over districts
> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=304587>, in which
> black and white political coalitions unite behind the same candidates.
> Indeed, as the Court today recognized, it would turn the VRA on its head if
> the law actually required – as North Carolina insisted it did – that these
> kind of effective coalitional districts had to be turned into
> majority-black districts, just to ensure they are sufficiently “safe.”
>
> Put in other terms, the decision confirms that States must adhere to the
> view that the intentional creation of majority-minority districts is a
> “second best” remedial device, to be used only where clearly required.
> Indeed, important parts of the opinion further emphasize that, when engaged
> in race-based districting, States must do a thorough job of demonstrating
> that doing so is necessary – “the State must carefully evaluate” whether
> the facts support this, and the State must engage in a “meaningful
> legislative inquiry” about whether doing so is necessary.
> There are other aspects of today’s decision that will also be important in
> enforcing constitutional constraints on the excessive and unjustified use
> of race in redistricting.  The Court said, once again, that  the setting of
> “a racial target” that has a direct impact on the design of a district
> means that strict scrutiny is triggered and the district can survive only
> if the VRA requires it.
> Once again, the Court confirmed that if the State intentionally sorts
> voters by race into districts, the State cannot hide behind the argument
> that its ultimate goal was to pursue an effective partisan gerrymander.  To
> the extent partisan gerrymandering is constitutional, States can sort
> voters by their voting patterns, but not by their race.  As the Court has
> said before, race cannot be used as a “proxy” for political voting
> preferences.  To be sure, this can create a mess for the lower courts if a
> State does not directly and obviously use race to sort voters; the courts
> then have to sort out whether it was “really” race or partisan factors that
> drove the district’s design (I have long argued that it makes little sense
> for the Court to impose constitutional constraints on racial
> gerrymandering, but not partisan gerrymandering).
>
> There is still more in today’s decision:  The Court held that plaintiffs
> in these *Alabama *cases do not have provide their own alternative map
> (which can be a costly and time consuming venture) in order to be able to
> prove that a jurisdiction has engaged in race-based districting.  And there
> had been a confusing couple of sentences in an earlier case, also from
> North Carolina, that had befuddled the lower courts; the Court today
> confines those sentences to the particular facts of that one case, as
> Justice Thomas, who joined the majority, pointed out.  That is all to the
> good as well.
>
> In every respect of today’s decision today, then, the Court built on the *Alabama
> *line of cases further and made it all the more clear that the Court will
> aggressively police the role of race in redistricting, not permit the VRA
> to become a vehicle for excessively packing black voters into districts,
> and will continue the project of unwinding unnecessary race-based
> districting.
>
> Disclosure:  I argued one of the *Alabama *cases and continue to
> represent plaintiffs in that case, which remains pending in the lower
> courts.
>
> Richard H. Pildes
> Sudler Family Professor of Constitutional Law
> NYU School of Law
> 40 Washington Square South, NY, NY 10012
> 212 998-6377
>
>
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> --
> Nicholas O. Stephanopoulos Assistant Professor of Law University of
> Chicago Law School nsteph at uchicago.edu (773) 702-4226 http://www.law.uchicago.edu/fa
> culty/stephanopoulos <http://www.law.uchicago.edu/faculty/stephanopoulos>
>
> --
> Nicholas O. Stephanopoulos Assistant Professor of Law University of
> Chicago Law School nsteph at uchicago.edu (773) 702-4226 http://www.law.uchicago.edu/fa
> culty/stephanopoulos <http://www.law.uchicago.edu/faculty/stephanopoulos>
>
> --
> Nicholas O. Stephanopoulos Assistant Professor of Law University of
> Chicago Law School nsteph at uchicago.edu (773) 702-4226 http://www.law.uchicago.edu/
> faculty/stephanopoulos
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-- 
Nicholas O. Stephanopoulos
Assistant Professor of Law
University of Chicago Law School
nsteph at uchicago.edu
(773) 702-4226
http://www.law.uchicago.edu/faculty/stephanopoulos
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