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Volume 91.8
The Reconciliation Roots of Fourth Amendment Privacy
Sophia Z. Lee
Professor of Law, University of Pennsylvania Carey Law School.

I am indebted to my Penn Carey Law colleagues, fellow members of the Writers’ Bloc(k), participants in the Privacy Law Scholars Conference, the Harvard Law School Legal History Workshop, the American Bar Foundation’s Legal History Roundtable, as well as Laura Edwards, Scott Heerman, Orin Kerr, Sandra Mayson, Ajay Mehrotra, Shaun Ossei-Owusu, Nicholas Parrillo, and David Rudovsky for especially generous and helpful feedback. I am immensely grateful to Alana Bevin, Madeline Bruning, Miles Gray, Susan Gualtier, Paul Riermaier, Anna Rosenfeld, Austin Severns, Mary Shelly, and David Sowry for their phenomenal research assistance, as well as to the National Archives and Records Administration staff who made accessing case records amid a pandemic possible.

The Roberts Court has made protecting “the privacies of life” a catchphrase of Fourth Amendment law in the digital era. The time is thus ripe for revisiting the doctrinal and political roots of this newly influential quote from the Court’s 1886 decision Boyd v. United States. This Article makes a novel argument that Boyd and its elevation of protecting the “privacies of life” to an animating principle of the Fourth Amendment was instead a product of Reconstruction and its dismantlement. Fourth Amendment privacy was produced by and helped secure Reconciliation—the process through which White Americans North and South, Democrat and Republican came together to limit Reconstruction, preserve White supremacy, and pave the way for the violent disenfranchisement of newly freed Black men. The Article concludes by considering the divergent doctrinal implications of resituating Boyd and Fourth Amendment privacy in the politics of Reconciliation.

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Volume 91.8
Post-Emption and the Mayoral Toolbox: Levers and Limits of City Resistance to State Preemption
Quinton D. Lucas
Mayor, Kansas City, Missouri.

Several individuals provided support and insight without which this Essay would not have been possible. Morgan Said’s administrative and political genius deserves credit for many of Kansas City’s successes, and this Essay is no exception. Others in the mayor’s office contributed time and critical thought, including Reid Day and Melesa Johnson. Nicholas Hine’s strategic assistance helped get this piece across the finish line, and Jack Wolverton’s diligent research assistance was fundamental in compiling data and references. Discussions with the exceptional students and faculty at the University of Kansas School of Law helped us refine our local government experiences for an academic context. Lastly, heartfelt thanks to the editors of the University of Chicago Law Review—particularly Aleena Tariq, Adrian Ivashkiv, and Helen Zhao—for their meticulous substantive and technical edits.

Gavriel Schreiber
General Counsel to the Mayor of Kansas City, Missouri.

Several individuals provided support and insight without which this Essay would not have been possible. Morgan Said’s administrative and political genius deserves credit for many of Kansas City’s successes, and this Essay is no exception. Others in the mayor’s office contributed time and critical thought, including Reid Day and Melesa Johnson. Nicholas Hine’s strategic assistance helped get this piece across the finish line, and Jack Wolverton’s diligent research assistance was fundamental in compiling data and references. Discussions with the exceptional students and faculty at the University of Kansas School of Law helped us refine our local government experiences for an academic context. Lastly, heartfelt thanks to the editors of the University of Chicago Law Review—particularly Aleena Tariq, Adrian Ivashkiv, and Helen Zhao—for their meticulous substantive and technical edits.

States increasingly deploy aggressive preemption measures against disfavored localities. Scholars have raised the alarm, but cities’ subordinate legal status leaves them disempowered. To push back, municipal advocates need to thoroughly understand the complex bilateral relationship between cities and their states.

That is where I come in. As Mayor of a progressive city in a conservative state, I swim in the hostile symbiosis that characterizes city-state relations. By drawing on real-life examples, closed-door conversations, and previously private documents, my coauthor and I demonstrate the potence of multi-pronged city power. We synthesize our stories into a thicker account of state motivation, and then showcase the city’s “toolbox” for limiting state preemption.

That process unearths preemption’s next frontier. Post-enactment state preemption, or “post-emption,” occurs when a state retroactively nullifies a specific, already-passed municipal law. It has been widely acknowledged but not individually distinguished. Analyzing it independently reveals that it is already ubiquitous and likely to proliferate. Post-emption thus warrants individualized normative assessment, and this Essay begins that surprisingly nuanced discussion.

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Volume 91.8
A Disability Inclusive Theory of "Ordinary" Care: Redistributing Accommodative Labor in Torts
Rachel Caldwell
B.A. 2021, Arizona State University; J.D. Candidate 2025, The University of Chicago Law School.

I would like to thank Professor Adam Chilton for advising this Comment, as well as Andrew Webb, Barry Taylor, and Professor Katie Eyer for their feedback.

Everyone owes each other a duty of ordinary care—but what is “ordinary”? How does one act reasonably to meet this burden? This Comment analyzes the current reasonable person standard for disabled plaintiffs and the corresponding duty of “ordinary care” provided by defendants through a critical disability studies lens. The current system of tort law burdens disabled plaintiffs with accommodating themselves, rather than requiring defendants to include accessible care in meeting their duty of ordinary care. To make the distribution of accommodative labor more equitable, this Comment proposes three stackable changes: (1) courts should reinterpret defendants’ duty of ordinary care to include care of individuals with disabilities by eliminating the doctrine that tortfeasors owe accommodations to people with disabilities only if they are on notice of their disabilities; (2) courts could further shift the balance of accommodative labor by factoring the mental and physical cost of accommodating oneself into the reasonable care inquiry when the plaintiff is disabled; and (3) courts could eliminate comparative negligence for plaintiffs with disabilities to address the problematic “reasonable person with a disability” standard. This Comment also explores theoretical, doctrinal, and normative justifications while creating space for a more robust dialogue on how the law treats disability as “extra”—but not ordinary.

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Volume 91.8
Weighing In: Why Obesity Should Be Considered a Qualifying Disability Under the Americans with Disabilities Act
Anne Marie Hawley
B.A. 2019, Georgetown University; J.D. Candidate 2025, The University of Chicago Law School.

I would like to thank Professor Sarah Konsky, Professor Katie Eyer, and the editors of the University of Chicago Law Review for their guidance and helpful feedback. Special thanks are also due to activist Aubrey Gordon and journalist Michael Hobbes, whose tireless advocacy inspired my research topic.

Anti-fat bias has been described as the last socially acceptable form of prejudice. Despite the discrimination that fat people face, there is no federal protection against weight discrimination. One potential solution to the lack of existing legal protections is the Americans with Disabilities Act (ADA). Claims challenging weight discrimination under the ADA argue that weight discrimination is a form of disability discrimination that is based on the medical condition of obesity. Yet, courts have resisted granting the ADA’s protections to obese plaintiffs.

This Comment argues that courts should recognize obesity as an ADA-protected disability, even in circuits that have restricted obesity-as-a-disability ADA claims to cases where a plaintiff can show that their obesity is related to a physiological disorder. The author draws parallels between obesity and gender dysphoria to highlight courts’ recent willingness to extend the ADA’s protection to highly stigmatized clinical conditions when a diagnosis has gained credibility in the medical community and evidence suggests that the condition has a physiological cause.

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Volume 91.8
When the Taker Goes Broke: Takings Claims in Municipal Bankruptcy
Joshua Kayne Kaufman
B.A. 2021, The University of Chicago College; J.D. Candidate 2025, The University of Chicago Law School.

I would like to thank Josh Avratin, Douglas Baird, Vincent Buccola, Andrea Kayne, Kate Gehling, Ryan Schloessmann, Jenna Liu, Jack Brake, Karan Lala, and many other members of the University of Chicago Law Review for their thoughtful advice and feedback. In addition, I would like to thank Maria Sofia Peña, Andrea Kayne, Ariel Kaufman, Jacob Kaufman, Borscht Kaufman, Babka Kaufman, Justin Peña-Behar, and my friends for their support throughout the writing process. This Comment is dedicated to Chicago—my home for the past quarter century and a testament to the importance of giving communities a second chance.

When a municipality takes property, the former owners can allege a violation of the Takings Clause and try to recover just compensation. But what should happen when the municipality goes broke and enters municipal bankruptcy? Can the municipal bankruptcy code empower judges to release municipalities from their obligation to pay just compensation through a discharge? Or does the Takings Clause provide special constitutional protection to claims for just compensation from a municipality that immunizes the claims from discharge? This issue has played out in municipal bankruptcies in Detroit, Michigan; Stockton, California; and Puerto Rico—where courts are deeply divided on the right approach, resulting in a live circuit split. This Comment provides the first comprehensive analysis that shows takings claims are constitutionally dischargeable. As a threshold matter, the Comment shows that formalist considerations do not require immunizing takings claims from discharge. The Comment then shows that making takings claims dischargeable follows best from the original design of the Takings Clause given the host of procedural and political safeguards within municipal bankruptcy that would protect takings claimants against abuse. Lastly, the Comment shows that making takings claims dischargeable is normatively good.

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Volume 91.8
Solving the Housing Puzzle
George J. Vojta
A.B. 2017, Claremont McKenna College; Ph.D. Candidate 2025, The University of Chicago Kenneth C. Griffin Department of Economics; J.D. Candidate 2025, The University of Chicago Law School.

I would like to thank Professors Eric Posner, Lior Strahilevitz, and David A. Weisbach and the editors and staff of the University of Chicago Law Review for their thoughtful advice and insight. I would also like to thank my parents, family, partner, and friends for their unwavering support.

This Comment analyzes the entrance of institutional investors into the single-family rental market after the Great Recession of 2008. The collapse of the housing market during the Great Recession fundamentally changed the ownership structure of U.S. single-family homes. This post-recession reality has introduced a housing puzzle: the pricing trends of single-family rentals in the decade after the Great Recession suggest that institutional investors have captured monopolistic power over the single-family rental market despite owning a relatively small market share. Thus, this Comment evaluates the housing puzzle through the lens of antitrust law.

While a potential antitrust case appears to suffer from the critical weaknesses of low entry barriers and market shares, analyzing the institutional entrance into the single-family rental market under antitrust merger doctrine reveals that the case is stronger than it may initially seem. After evaluating the antitrust case, this Comment considers how the housing market can instruct antitrust doctrine’s further evolution, since commentators across academia, the media, and politics all criticize institutional entrance. By highlighting how unique market facts in housing obfuscate market power, this Comment suggests expanding the merger analysis to include not just levels and changes in concentration, but also orders of magnitude.

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The Perils of Poor Penmanship: A D.C. Circuit Fight Demonstrates the Urgency of Electronic Union Elections
Noah Levine
J.D. Candidate at the University of Chicago Law School, Class of 2025.

He thanks the University of Chicago Law Review Online team for their careful feedback.

The legibility of handwriting is on the decline. Thankfully, calligraphy carries low stakes in a digital age. Why write something down when it can be typed instead? Yet, there is still one near-universal fragment of writing that must often be done by hand: the signature. While usually a formality, so long as signatures are done by hand, they can be second-guessed, threatening a generation untrained in cursive. This Essay highlights a recent incident in which a union representation election hinged on the legibility of one employee’s signature.

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The Objective Observer Test and Racial Bias in Civil Jury Trials: The Washington State Approach
Derek Willie
J.D. Candidate at the University of Chicago Law School, Class of 2025.

He thanks the University of Chicago Law Review Online team.

Is it OK for courts to think about race when they decide whether to bar certain arguments from being made, because they think those arguments could rely on stereotypes or otherwise play on the jury’s racial biases? For the Washington Supreme Court, the answer is yes—in fact, courts have a duty to consider race in making these evidentiary decisions. Rather than statements or arguments that are made with a clearly racist intent, the Washington Supreme Court’s idea of “racially biased arguments” is far more capacious: it includes “dog whistles,” or superficially harmless comments that have the effect of operating on a jury’s implicit biases.

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Textualism and Progressive Social Movements
Katie Eyer
Professor of Law, Rutgers Law School.

Many thanks to Tara Leigh Grove, Eric Fish, and Logan Everett Sawyer for helpful feedback on this project. Maya Lorey, Alexandra Webb, and Erin Yonchak of the University of Chicago Law Review Online provided excellent editorial suggestions and assistance.

Should progressive movement lawyers avoid making textualist arguments? This Essay suggests that the answer is no. While there may be good reasons for movement lawyers to eschew arguments associated with their ideological opponents, none of those reasons apply to the embrace of textualist arguments by progressive movements today. Indeed, the time may be especially ripe for progressive social movements to make increased use of textualist legal arguments.

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Liberalism, Dependence, and . . . Admiralty
Edward A. Hartnett
Richard J. Hughes Professor of Constitutional and Public Law and Service, Seton Hall University School of Law.

Liberal political and legal theory posit a world of autonomous individuals, each pursuing their own chosen ends, linked to each other by one or more agreements. But this is not how most of us experience most of our lives. This Essay seeks to open a conversation about resources in our legal history and culture that work from different assumptions—and might perhaps be a source of inspiration—by pointing to one such resource: admiralty.