[EL] Can federal partisan gerrymandering claims still be brought in state court?

[Josh Douglas]

To follow on Jim's point, just over half of the state constitutions have a
"free and equal" or "free and open" elections clause; 49 of the 50 state
constitutions have a "right to vote" provision that explicitly confers the
right to vote to the state's citizens; and either could be the basis for an
independent state constitutional claim with no federal constitutional
analogue. (I catalogue these provisions here
<https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2234762>.)

The problem comes if a state court construes the state constitution to be
in "lockstep" with the federal constitution. Some state courts have
interpreted, for example, their state constitutions' right to vote
provision to be in lockstep with the construction of the right to vote
under the U.S. Constitution's Equal Protection Clause. I've argued
previously that this lockstep approach is wrong for both textual and
prudential reasons. If a state court properly construes its state
constitution's free and equal/free and open clause and its right to vote
clause as going beyond the U.S. Constitution, then *Rucho* will pose no bar
to state solutions to partisan gerrymandering. That's exactly what happened
at the Pennsylvania Supreme Court, with a decision
<https://www.pubintlaw.org/wp-content/uploads/2017/06/2018-02-07-Majority-Opinion.pdf>
that can serve as a model for other state courts.

On Sun, Jun 30, 2019 at 3:20 PM Gardner, James <jgard at buffalo.edu> wrote:

> Incidentally, the strongest possible basis to protect state constitutional
> decisions from overrule by a US Supreme Court unwilling to exercise
> self-restraint (as hard to imagine as that may be) would be for the state
> decision to rest on a provision without federal analogue, such as a “free
> and fair elections “ clause like the one invoked by the PA Sup Ct.     Of
> course, not even that kind of ruling could protect against some kind of
> bizarre federal reverse discrimination overrule should the US Supremes come
> up with a Shaw analogue grounded in the US Constitution to undermine
> successful state PG claims.
>
> Sorry, now I have to apologize for excessive garrulity.  I’ll stop for
> tonight.
>
> Jim
>
> Sent from my iPhone
>
> On Jun 30, 2019, at 6:06 PM, Pildes, Rick <rick.pildes at nyu.edu> wrote:
>
> I agree with Justin that any ongoing development of doctrine, for purposes
> of influencing some imagined future Supreme Court decision, could be done
> under state equal protection doctrine or state First Amendment law (as well
> as other provisions).  I would just add the additional point that if state
> courts strike down plans under federal law, we can imagine three main
> possibilities, in my initial reflections on this:  (1) they do so on the
> basis of different analysis than in the federal court decisions to date;
> (2) they do so on the same basis but their reasoning is much weaker; (3)
> they do on the same basis as the federal court decisions to date [I exclude
> the fourth possibility that they write stronger, more persuasive opinions
> than the federal courts to date since I think the opinions to date have
> been quite well done already].
>
>
>
> In other words, even favorable outcomes on the federal question wouldn’t
> necessarily strengthen the case for reconsideration.  If the state courts
> do either (1) or (2), it might very well weaken the case.  Right now, we
> have a number of three-judge federal court decisions that all converge on
> the same approach and provide extremely long, careful analysis of the
> issues.  The only scenario in which even favorable state decisions on
> federal grounds might in theory bolster the case would be if they basically
> track the analysis in the federal court opinions – and the theory have to
> be that by adding a bunch of state supreme court decisions to these federal
> court decisions, you bolster the case for reconsideration.  I find that a
> pretty thin speculative benefit; if the Court wants to point to convergent
> lower-court decisions that show how this issue can be manageable, there
> already exists a substantial body of those opinions.  And given the risks
> of opening the federal-law can of worms and inviting the Supreme Court back
> in, it’s hard to see these minor benefits, if they exist at all, as worth
> it.
>
>
>
> I see any further doctrinal developments as coming from state courts
> applying state law exclusively.
>
>
>
>
>
>
>
> *From:* Law-election [mailto:law-election-bounces at department-lists.uci.edu
> <law-election-bounces at department-lists.uci.edu>] *On Behalf Of *Levitt,
> Justin
> *Sent:* Sunday, June 30, 2019 4:51 PM
> *To:* Nicholas Stephanopoulos <nicholas.stephanopoulos at gmail.com>
> *Cc:* law-election at UCI.EDU
> *Subject:* Re: [EL] Can federal partisan gerrymandering claims still be
> brought in state court?
>
>
>
> As Justice Thomas keeps reminding us, Supreme Court doctrine is not
> fixed.  The Court has said that it can find no manageable standards in a
> federal constitutional cause of action.  I think that decision was both
> unwise and incorrect, but I acknowledge that it’s firm.
>
>
>
> If state courts decided to address not only state law, but also federal
> law, in forthcoming decisions, I’m not at all sure that the Court would sit
> that fight out, no matter how much current doctrine on adequate and
> independent state grounds suggests otherwise.  Smith begat RFRA,  which
> begat Boerne.  Citizens United seemed to leave the theoretical opening for
> as-applied cases, and the Montana litigation shut that down.  The Court
> doesn’t appear to like other actors attempting to “correct” its
> constitutional decisions, or to evade what the Court _thinks_ is a broad
> and definitive rule settling the field.
>
>
>
> I hear the hypothetical value of the notion of state courts building
> federal constitutional doctrine in waiting for a future Supreme Court.  It
> is, sincerely, an interesting theory.  I happen to think that state
> constitutional approaches to partisan gerrymandering would supply the same
> reservoir of available approaches for a future Supreme Court, without
> provoking the bear into defending what it perceives as its holding (even at
> the expense of current doctrinal limits on jurisdiction).  And so I wonder
> whether, in practice, that particular juice would be worth the squeeze.
>
> --
>
> Justin Levitt
>
> justin.levitt at lls.edu
>
>
> On Jun 30, 2019, at 1:32 PM, Nicholas Stephanopoulos <
> nicholas.stephanopoulos at gmail.com> wrote:
>
> I'm more or less persuaded by Michael, Rick, and Sam that if a state court
> struck down a map *solely* on federal partisan gerrymandering grounds,
> the Supreme Court would find a way to reverse that judgment, even if this
> result isn't compelled by *ASARCO*. The question then becomes whether
> there's value in state courts striking down maps *jointly* on federal and
> state partisan gerrymandering grounds. I think there's significant value.
> The state courts' decisions are then unreviewable by the Supreme Court. But
> they still constitute precedents -- on-the-books, non-reversed precedents
> -- about the contours of the federal partisan gerrymandering cause of
> action. Those precedents could be quite helpful to a future Supreme Court
> inclined to reverse *Rucho*. That future Court could cite the precedents
> as evidence that, actually, partisan gerrymandering claims *can* be
> decided consistently and non-arbitrarily. The precedents themselves could
> amount to changed circumstances compelling the Court to revisit *Rucho*.
>
>
>
> On Sun, Jun 30, 2019 at 3:10 PM Samuel Bagenstos <sbagen at gmail.com> wrote:
>
> Pildes's point and mine work out to the same place.
>
>
>
> On Sun, Jun 30, 2019 at 4:08 PM Pildes, Rick <rick.pildes at nyu.edu> wrote:
>
> I do not see why any lawyer would now bring a state-court partisan
> gerrymandering case and invoke the federal constitution.  There is no
> benefit to bringing the federal claim.  Every state constitution has
> provisions that bear just as directly, or even more directly, on partisan
> gerrymandering claims as does the federal constitution.  Moreover, any
> state court prepared to invoke the federal constitution to strike down a
> partisan GM would surely be willing to do so under the state constitution.
>
>
>
> And on the cost side of the ledger, if a state court did rely on the
> federal constitution as the basis for its holding, I have little doubt the
> Supreme Court would review the matter.  There is no way that a state court
> will have final say over the substantive meaning of the federal
> constitution.  That is the larger point that *ASARCO *represents.  Yes,
> it is technically only a standing case and the Court has never had to
> directly address the analogous issue under the political question
> doctrine.  But standing is the hardest hurdle to get over in federal
> courts, since it is an Art. III hurdle.   Doctrines like mootness and
> ripeness are prudential principles, not Art. III ones, and so the question
> is even easier there:  any state court decision relying on the federal
> constitution will be reviewable in the Supreme Court, even if it could not
> have been brought in the first instance in the federal courts.
>
>
>
> But even if you did not think the *ASARCO *question is as clear as I do
> here, there would certainly be a significant risk the Supreme Court would
> apply *ASARCO *here.  So why would a lawyer run the risk of Supreme Court
> review by invoking the federal constitution when state constitutional
> grounds are every bit as strong in every case and stronger in many cases.
>
>
>
>
>
>
>
>
>
> *From:* Law-election [mailto:law-election-bounces at department-lists.uci.edu]
> *On Behalf Of *Nicholas Stephanopoulos
> *Sent:* Sunday, June 30, 2019 3:19 PM
> *To:* Michael Morley <mmorley at law.fsu.edu>
> *Cc:* law-election at UCI.EDU
> *Subject:* Re: [EL] Can federal partisan gerrymandering claims still be
> brought in state court?
>
>
>
> I think some of Michael's analysis may well be right, but I doubt *ASARCO* can
> be read as broadly as Michael suggests. *ASARCO* holds that *standing* can
> be created, where it wouldn't otherwise exist, by an adverse state court
> decision. But it doesn't stand for the proposition that federal
> jurisdiction *generally* can be generated by an adverse state court
> ruling on a federal issue. Assume, for example, that a litigant raises a
> federal claim in state court that would be moot or nonripe if it were
> raised in federal court. I don't see why the claim would become live or
> ripe simply by virtue of a state court decision. And the political question
> doctrine seems like mootness and ripeness to me: a justiciability doctrine
> that's unaffected by the mere presence of a state court decision.
>
>
>
> On Sun, Jun 30, 2019 at 1:21 PM Michael Morley <mmorley at law.fsu.edu>
> wrote:
>
> I think some of Nick's analysis might be indirectly in tension with *ASARCO
> v. Kadish*, 490 U.S. 605 (1989), which deals with U.S. Supreme Court
> review of state-court rulings in cases that initially would've been
> non-justiciable in federal court.
>
>
>
> Nick's post distinguishes between two types of cases.  First, there could
> be situations in which federal and state political gerrymandering claims
> are both brought in state court, and the state court construes both the
> U.S. and state constitutions the same way, and as imposing identical
> remedial requirements.  In those situations, as Nick points out, the
> "independent and adequate state-law grounds" doctrine would preclude
> federal review.  As he notes, however, the federal claims really aren't
> doing any work in those cases, and the state court's adjudication of them
> is largely irrelevant (except perhaps as "shadow precedent," in the manner
> Nick intriguingly suggests).
>
>
>
> Second, there could be a case in which: (i) only federal claims are
> brought in state court, or (ii) the state court construes the U.S.
> Constitution as providing stronger protections against political
> gerrymandering, or providing more extensive relief, than the state
> constitution.  If a state court of last resort allows a political
> gerrymandering ruling for plaintiffs to stand in either of those types of
> cases, I think it's likely the ruling is reviewable by the U.S. Supreme
> Court, and -- unless the U.S. Supreme Court decides to overturn *Rucho*
> -- it should reverse the state-court's ruling.
>
>
>
> Under *ASARCO *(to oversimplify a bit), the Supreme Court considered a
> case that was initially non-justiciable, filed by a plaintiff who lacked
> standing.  That plaintiff ultimately prevailed in the state courts.  The
> Supreme Court held that it had jurisdiction to hear the defendant's appeal,
> even though a federal court couldn't have heard the case as an initial
> matter.  The state court's ruling ordering relief against the defendant
> constituted injury-in-fact to the defendant, giving it standing to seek
> federal review and creating a justiciable dispute.  Thus, *ASACRO *recognizes
> that cases which couldn't initially have been filed in federal court due to
> justiciability restrictions may nevertheless be amenable to Supreme Court
> review.
>
>
>
> The political gerrymandering hypothetical isn't exactly the same, of
> course, since the justiciability barrier is the political question
> doctrine, rather than lack of standing.  Like the defendant in *ASARCO*,
> however, when a defendant in a political gerrymandering case seeks Supreme
> Court review, the nature of its claim is different than that of a plaintiff
> initially attempting to invoke federal jurisdiction.  The defendant isn't
> really bringing a "political gerrymandering" claim.  Rather, it's arguing
> the state court has impermissibly limited its sovereign power to draw
> district lines based on an erroneous construction of some federal
> constitutional provision, like the First or Fourteenth Amendment.  Such an
> argument may be especially strong in the context of congressional
> redistricting, where the defendant can argue that the state court
> impermissibly burdened or limited its exercise of power under the U.S.
> Constitution's Elections Clause to determine the "manner" in which
> congressional elections are held.
>
>
>
> *Rucho* held there are no judicially manageable standards under any U.S.
> constitutional provisions for prohibiting political gerrymandering.  A
> state court ruling interpreting the First Amendment, Equal Protection
> Clause, or some other U.S. Constitutional provision as imposing a test or
> standard for prohibiting political gerrymandering claims is contrary to
> that holding.  Even if one construes the political question doctrine
> exclusively as a jurisdictional doctrine (but see Tara Grove and John
> Harrison), its applicability in this context depends on the Supreme Court's
> conclusions about various provisions of the U.S. Constitution that state
> courts aren't free to disregard.  The Supreme Court could grant
> certiorari to enforce its construction of those constitutional provisions
> -- even if that construction is that they don't give rise to any judicially
> applicable prohibitions on political gerrymandering -- and I don't think
> there are any justiciability barriers to it doing so.
>
>
>
> If this argument is correct, a defendant still would not be able to remove
> a political gerrymandering claim under the U.S. Constitution from state
> court to federal court.  It would have to litigate the matter through the
> state courts until it can seek Supreme Court review of the state
> judiciary's rulings.
>
>
>
> P.S. - I discussed and argued against the possibility of litigating claims
> that are nonjusticiable under* Spokeo* in state court in:
> https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2946482
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__linkprotect.cudasvc.com_url-3Fa-3Dhttps-253a-252f-252furldefense.proofpoint.com-252fv2-252furl-253fu-253dhttps-2D3A-5F-5Fpapers.ssrn.com-5Fsol3-5Fpapers.cfm-2D3Fabstract-2D5Fid-2D3D2946482-2526d-253dDwMFaQ-2526c-253dslrrB7dE8n7gBJbeO0g-2DIQ-2526r-253dv3oz9bpMizgP1T8KwLv3YT-2D-5FiypxaOkdtbkRAclgHRk-2526m-253d-2D7bCyOv4ytKgnZoZYL8IfJnSD8sZSmzLfaQrT90ksME-2526s-253dr-5Fgo-5FVbLr3k5DVli3w2meVlLaz-2D6pAQsYsUfpn3QeKs-2526e-253d-26c-3DE-2C1-2CgTAPz4ork4Qf6kMtrSXrDsO8M5xN2LedUaTNNXfb09V6GEKaf1nEqJQi8qMMzTqnh6koVntz0xbTUCaJrRVvmqwOUO4-5FhDhHc472-2DdJPpA-2C-2C-26typo-3D1&d=DwMGaQ&c=slrrB7dE8n7gBJbeO0g-IQ&r=v3oz9bpMizgP1T8KwLv3YT-_iypxaOkdtbkRAclgHRk&m=NjWfkgG4Pn5W0TeO6oCU09H3GU_BfaaN666JGkTM9zk&s=r3Ek2nmkTeTtXsCHzgt1SdPzwX6KwICKwpsdbk9ubQM&e=>
>
>
>
>
>
> Michael T. Morley
>
> Assistant Professor of Law
>
> Florida State University College of Law
>
> mmorley at law.fsu.edu
>
> (860) 778-3883
>
>
>
>
>
>
> ------------------------------
>
> *From:* Law-election <law-election-bounces at department-lists.uci.edu> on
> behalf of Nicholas Stephanopoulos <nicholas.stephanopoulos at gmail.com>
> *Sent:* Sunday, June 30, 2019 1:28 PM
> *To:* law-election at UCI.EDU
> *Subject:* [EL] Can federal partisan gerrymandering claims still be
> brought in state court?
>
>
>
> Will Baude has an intriguing post
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__linkprotect.cudasvc.com_url-3Fa-3Dhttps-253a-252f-252furldefense.proofpoint.com-252fv2-252furl-253fu-253dhttps-2D3A-5F-5Freason.com-5F2019-5F06-5F28-5Fcan-2D2Dfederal-2D2Dpartisan-2D2Dgerrymandering-2D2Dclaims-2D2Dbe-2D2Dbrought-2D2Din-2D2Dstate-2D2Dcourt-5F-2526d-253dDwMFaQ-2526c-253dHPMtquzZjKY31rtkyGRFnQ-2526r-253d5f6POwjrH-5FvnsYmoF-2D4bLjJfKWN5xS43XQSvIUnmNR4-2526m-253dogVKeQ0nI4GVhAPtGwquA8E75OaxvAJ9K9An08BAFIg-2526s-253dLljW1SKazDRI9mB8qWXW9SAtH6FRcmiqUjOwbDW9kqE-2526e-253d-26c-3DE-2C1-2CPao6yrYR9fKEo62VFC9XOevTkJ939BSnOExJfQf7mlNYB0MZX890-5Fc5u6f7gppKTEJ8dbxiYiZRQlO8xJ5ElGYy34mYK4RZ3nw11jHt7uMXQ5Sy1-26typo-3D1&d=DwMGaQ&c=slrrB7dE8n7gBJbeO0g-IQ&r=v3oz9bpMizgP1T8KwLv3YT-_iypxaOkdtbkRAclgHRk&m=NjWfkgG4Pn5W0TeO6oCU09H3GU_BfaaN666JGkTM9zk&s=xa68b5wm0SSYeL0bTNxIVfuOwK-TxLfMdPihOLmGsfA&e=> suggesting
> that, even after *Rucho*, federal partisan gerrymandering claims can
> still be brought in state court. The rationale is that federal
> jurisdictional doctrines like standing, mootness, and justiciability don't
> apply in state court. So a state court could reason: (1) The Supreme Court
> unanimously believes that extreme partisan gerrymandering is
> unconstitutional. (2) The Supreme Court also believes that partisan
> gerrymandering claims are nonjusticiable. (3) However, *we* believe that
> such claims *are* justiciable. (4) So we're going to adjudicate them.
>
>
>
> I'm curious whether this move would be attractive to the litigants
> currently pursuing (or considering pursuing) state constitutional partisan
> gerrymandering claims. On the one hand, these claims are only being brought
> in forums thought to be receptive. If state courts are already expected to
> be sympathetic to state claims, it might be pointless to add a federal
> claim to the mix.
>
>
>
> On the other hand, after *Rucho*, any judgment a state court reaches on a
> federal partisan gerrymandering claim would seem to be nonreviewable by the
> Supreme Court. The Court couldn't tell the state court to apply a federal
> jurisdictional doctrine that the state court rejects. And the Court
> couldn't reach the merits of a federal partisan gerrymandering claim. As
> long as *Rucho* remains good law, then, it appears possible for state
> courts to generate a body of shadow precedent about partisan gerrymandering
> under the federal Constitution. These rulings could never be recognized by
> federal courts. But they would nevertheless have legal force. And they
> would serve as powerful evidence that *Rucho* is wrong: that courts are
> indeed capable of deciding federal partisan gerrymandering claims
> consistently and non-arbitrarily.
>
>
>
> Two final points: First, a defendant against whom a federal partisan
> gerrymandering claim was brought couldn't remove the case to federal court.
> That's because, per *Rucho*, no federal court would have jurisdiction
> over the claim. And second, if a state court reached its decision on
> federal *and* state grounds, the decision's nonreviewability by the
> Supreme Court would be even clearer. In that case, there would be an
> adequate and independent state law basis for the decision.
>
>
>
> --
>
> Nicholas O. Stephanopoulos
> Professor of Law
>
> Herbert and Marjorie Fried Research Scholar
> University of Chicago Law School
> nsteph at uchicago.edu
> (773) 702-4226
> http://www.law.uchicago.edu/faculty/stephanopoulos
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__linkprotect.cudasvc.com_url-3Fa-3Dhttps-253a-252f-252furldefense.proofpoint.com-252fv2-252furl-253fu-253dhttp-2D3A-5F-5Fwww.law.uchicago.edu-5Ffaculty-5Fstephanopoulos-2526d-253dDwMFaQ-2526c-253dHPMtquzZjKY31rtkyGRFnQ-2526r-253d5f6POwjrH-5FvnsYmoF-2D4bLjJfKWN5xS43XQSvIUnmNR4-2526m-253dogVKeQ0nI4GVhAPtGwquA8E75OaxvAJ9K9An08BAFIg-2526s-253dkojyCjN3xYjI1Rz-5FDfa2xUWmlWKu00ly7HgM6CzgaHQ-2526e-253d-26c-3DE-2C1-2C2RwoKOfL9tMplCWlcO0QOxFKfY0dhKCb9PQOTHlcnAg4psm-2DVfVNtp6-5FOfcZ4eqwm0-2DTdySipzt4kst3ZjsbDNx7iYVg84sWh-2De-5F0Y-2DIRqFW8wV-2DGC9m3zo-2C-26typo-3D1&d=DwMGaQ&c=slrrB7dE8n7gBJbeO0g-IQ&r=v3oz9bpMizgP1T8KwLv3YT-_iypxaOkdtbkRAclgHRk&m=NjWfkgG4Pn5W0TeO6oCU09H3GU_BfaaN666JGkTM9zk&s=YOCGgdGobj6VY88DII7YcDScKuuBBIGKJZrTL5tYkss&e=>
>
>
>
>
> --
>
> Nicholas O. Stephanopoulos
> Professor of Law
>
> Herbert and Marjorie Fried Research Scholar
> University of Chicago Law School
> nsteph at uchicago.edu
> (773) 702-4226
> http://www.law.uchicago.edu/faculty/stephanopoulos
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__linkprotect.cudasvc.com_url-3Fa-3Dhttps-253a-252f-252furldefense.proofpoint.com-252fv2-252furl-253fu-253dhttp-2D3A-5F-5Fwww.law.uchicago.edu-5Ffaculty-5Fstephanopoulos-2526d-253dDwMFaQ-2526c-253dslrrB7dE8n7gBJbeO0g-2DIQ-2526r-253dv3oz9bpMizgP1T8KwLv3YT-2D-5FiypxaOkdtbkRAclgHRk-2526m-253d-2D7bCyOv4ytKgnZoZYL8IfJnSD8sZSmzLfaQrT90ksME-2526s-253d1v4jq5RSqxDgNQmhsigJV-2DXJ4ruPqtji2X3fUMLdylw-2526e-253d-26c-3DE-2C1-2CtRS-2DYcYMg0VwRBhxFFpQNYXz1zClUj7Y0XeBp0GtUPo8UHnBACzHracNYaXmC0XQq0Cd0iBeC42fIS5uLvcvr6dZsTCaCRZB9iUWWSpywQ-2C-2C-26typo-3D1&d=DwMGaQ&c=slrrB7dE8n7gBJbeO0g-IQ&r=v3oz9bpMizgP1T8KwLv3YT-_iypxaOkdtbkRAclgHRk&m=NjWfkgG4Pn5W0TeO6oCU09H3GU_BfaaN666JGkTM9zk&s=_ijgRiIKWieGvHl7zBcrR0b73kEGUxCYln0x1z2T9yA&e=>
>
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
> https://department-lists.uci.edu/mailman/listinfo/law-election
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__linkprotect.cudasvc.com_url-3Fa-3Dhttps-253a-252f-252fdepartment-2Dlists.uci.edu-252fmailman-252flistinfo-252flaw-2Delection-26c-3DE-2C1-2CRu26ND-5FP3M-5Fq5zKAqc67oOw3QGJ93IuQQlGzPHnNX-2D1EBxAiWB7dDHaI-2DuSVpJI67Nv-2Dls1EVjqw37pmdYIZvM5zBq3lkOD6qvIxo0-2Dt-5Fpnc-2DZc-2C-26typo-3D1&d=DwMGaQ&c=slrrB7dE8n7gBJbeO0g-IQ&r=v3oz9bpMizgP1T8KwLv3YT-_iypxaOkdtbkRAclgHRk&m=NjWfkgG4Pn5W0TeO6oCU09H3GU_BfaaN666JGkTM9zk&s=zUBF29mOtLI-1U0wfuJ2aHT_lDjrsuwNwQEJ0beJH0s&e=>
>
>
>
>
> --
>
> Samuel Bagenstos
>
> sbagen at gmail.com
>
> Twitter: @sbagen
>
> University of Michigan homepage:
> http://www.law.umich.edu/FacultyBio/Pages/FacultyBio.aspx?FacID=sambagen
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.law.umich.edu_FacultyBio_Pages_FacultyBio.aspx-3FFacID-3Dsambagen&d=DwMGaQ&c=slrrB7dE8n7gBJbeO0g-IQ&r=v3oz9bpMizgP1T8KwLv3YT-_iypxaOkdtbkRAclgHRk&m=NjWfkgG4Pn5W0TeO6oCU09H3GU_BfaaN666JGkTM9zk&s=uCXNDv6M-HSEon9k3DQk2XqRxXF3FxUySZn_WmwfdcA&e=>
>
>
>
>
>
>
> --
>
> Nicholas O. Stephanopoulos
> Professor of Law
>
> Herbert and Marjorie Fried Research Scholar
> University of Chicago Law School
> nsteph at uchicago.edu
> (773) 702-4226
> http://www.law.uchicago.edu/faculty/stephanopoulos
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.law.uchicago.edu_faculty_stephanopoulos&d=DwMGaQ&c=slrrB7dE8n7gBJbeO0g-IQ&r=v3oz9bpMizgP1T8KwLv3YT-_iypxaOkdtbkRAclgHRk&m=NjWfkgG4Pn5W0TeO6oCU09H3GU_BfaaN666JGkTM9zk&s=CWD7ZJIWYRxaC2iq6IVJNXKu4Oe9kN-tIxj14IxiBr4&e=>
>
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
>
> https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fdepartment-lists.uci.edu%2fmailman%2flistinfo%2flaw-election&c=E,1,2HUxnyAL9UgOXQ2y1aumwgCKMxID6lOehgGnG7DaXPZDOFhjYYxeA6orsejVmyG2SWHmfAMX-MfoqmZcWt9vkoEQqZox7x9e0iLBKN6ez5s,&typo=1
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__linkprotect.cudasvc.com_url-3Fa-3Dhttps-253a-252f-252fdepartment-2Dlists.uci.edu-252fmailman-252flistinfo-252flaw-2Delection-26c-3DE-2C1-2C2HUxnyAL9UgOXQ2y1aumwgCKMxID6lOehgGnG7DaXPZDOFhjYYxeA6orsejVmyG2SWHmfAMX-2DMfoqmZcWt9vkoEQqZox7x9e0iLBKN6ez5s-2C-26typo-3D1&d=DwMGaQ&c=slrrB7dE8n7gBJbeO0g-IQ&r=v3oz9bpMizgP1T8KwLv3YT-_iypxaOkdtbkRAclgHRk&m=NjWfkgG4Pn5W0TeO6oCU09H3GU_BfaaN666JGkTM9zk&s=_oNkrj65Wr73yhsvIMwtJklhN_Kx0YOkqdMHUkOAZTg&e=>
>
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
> https://department-lists.uci.edu/mailman/listinfo/law-election
>
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
> https://department-lists.uci.edu/mailman/listinfo/law-election
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://webshare.law.ucla.edu/Listservs/law-election/attachments/20190701/4f9ea067/attachment.html>