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Volume 93.4
Enforcing the First Amendment in an Era of Jawboning
Genevieve Lakier
Professor of Law and Herbert & Marjorie Fried Teaching Scholar, University of Chicago Law School.

Thanks to participants at the University of Colorado, University of Texas, and University of Chicago Workshops for thoughtful feedback, to my First Amendment discussion group for helping refine my thinking on the topic, and to Evelyn Douek for all her ideas and edits.

For decades, it has been black letter law that the informal exercise of government power can violate the First Amendment when it creates an “informal system of censorship.” Lower courts have been deeply divided about what kinds of government actions create this kind of informal system. The Court’s recent NRA v. Vullo decision holds that officials engage in informal censorship whenever they intentionally use informal power to evade First Amendment constraints on their formal powers. Vullo clarified that the rule against informal censorship is categorical: officials may never evade constitutional constraints by threatening harm or promising benefits to private parties, no matter how they attempt to do so. This Article argues that the Court's reaffirmation of the categorical nature of the First Amendment rule against informal censorship is very good and comes at a critical time. The Article examines the doctrine prior to the decision, the significance of Vullo’s intervention, and its implications.

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Volume 93.4
How Deals Die
Da Lin
Senior Lecturer, Victoria University of Wellington; Affiliated Scholar, University of Richmond School of Law.

We are grateful to Adam Badawi, Albert Choi, Elisabeth de Fontenay, Jeff Gordon, Steven Haas, Lawrence Hamermesh, Scott Hirst, David Katz, Ronald Masulis, Holger Spamann, and Randall Thomas for generous conversations and valuable feedback, and to workshop participants at the Conference on Empirical Legal Studies, Junior Faculty Forum, NYU/Penn Conference on Law & Finance, Tulane Corporate Law Roundtable, Winter Deals Conference, the University of Richmond School of Law, Temple University Beasley School of Law, Vanderbilt Law School, and the New Zealand Takeovers Panel. The production of this Article involved a team of exceptional research assistants too large to mention here, to whom we are immensely grateful and whose names we list in Appendix A.

Morgan Ricks
Herman O. Loewenstein Chair in Law, Vanderbilt Law School.

We are grateful to Adam Badawi, Albert Choi, Elisabeth de Fontenay, Jeff Gordon, Steven Haas, Lawrence Hamermesh, Scott Hirst, David Katz, Ronald Masulis, Holger Spamann, and Randall Thomas for generous conversations and valuable feedback, and to workshop participants at the Conference on Empirical Legal Studies, Junior Faculty Forum, NYU/Penn Conference on Law & Finance, Tulane Corporate Law Roundtable, Winter Deals Conference, the University of Richmond School of Law, Temple University Beasley School of Law, Vanderbilt Law School, and the New Zealand Takeovers Panel. The production of this Article involved a team of exceptional research assistants too large to mention here, to whom we are immensely grateful and whose names we list in Appendix A.

The risk of deal breakage is central to merger and acquisition (M&A) dealmaking. Yet neither the finance nor corporate law literatures have systematically explored how and why deals fall apart. This Article rectifies this deficiency, making three principal contributions. First, it develops a comprehensive typology of eight M&A outcomes: completed-as-announced deals and seven types of deal breakage. Second, it unveils a novel dataset of 5,058 mergers and acquisitions involving U.S. public company targets signed between 1996 and 2020. Finally, it demonstrates how the Article's typology and data yield important implications for M&A practice and doctrine by casting new light on key debates over deal protection devices, the power of controlling shareholders, and “merger arbitrage” investors.

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Volume 93.4
The Specter of Future Blight: State Approaches to Speculative Takings
Julianna G. Bass
B.A. 2023, University of California, Berkeley; J.D. Candidate 2027, The University of Chicago Law School.

I would like to thank Professors Lior Strahilevitz and Jeff Leslie for their invaluable insights and guidance. I would also like to thank the editors and staff of The University of Chicago Law Review—especially Margaret Schaack, Beck Reiferson, and Zoë Lewis Ewing—who could not have been more thoughtful editors.

This Comment creates the first comprehensive taxonomy of state eminent domain regimes’ treatment of private-to-private takings for the purpose of preventing future blight. Following the Supreme Court’s expansion of the Public Use Clause, many states moved to limit takings justified solely by economic development, yet maintained broad blight statutes that continued to authorize the condemnation of property to eliminate or prevent blight. The Comment exposes the indeterminate contours of the future-blight takings landscape, urging legislatures and courts seeking to cabin sweeping public use determinations to find the prevention of future blight an invalid public use.

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Volume 93.4
When a Mass Resignation Becomes a Merger: Rethinking Asset Acquisitions for the AI Era
Nina Fridman
B.A. 2022, Northwestern University; J.D. Candidate 2027, The University of Chicago Law School.

I would like to thank Professors Douglas Baird and Eric Posner for their thoughtful advice and insight and the members of The University of Chicago Law Review for their invaluable feedback and edits.

This Comment argues “reverse acquihires”—deals in which a Big Tech firm poaches an AI startup’s team and then paysits shell hundreds of millions—constitute asset acquisitions subject to Hart-Scott-Rodino (HSR) Act review. While regulators typically review only tangible asset acquisitions under the Act, this Comment argues that regulators can mandate review of certain intangible asset transfers as well. Drawing on regulatory treatment of intellectual property licensing agreements, language from divestiture orders, and guidance from foreign competition authorities, this Comment demonstrates that reverse acquihires are acquisitions of AI startups’ most valuable assets: their business information and know-how.

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Comment
Volume 93.4
Quasi-Judicial Immunity Misapplied
Claire Hodges
A.B. 2022, Brown University; J.D. Candidate 2027, The University of Chicago Law School.

I would like to thank Professor Curtis Bradley and the editors and staff of The
University of Chicago Law Review for their advice.

Multiple circuits have extended quasi-judicial immunity to sheriffs, marshals, and bailiffs when they execute judicial orders, including—in some circuits—when they use excessive force. This Comment argues that the extension of quasi-judicial immunity to enforcement officers is inconsistent with the Supreme Court’s absolute immunity doctrine. A survey of the Court’s absolute immunity cases reveals four considerations guiding those determinations. Enforcement officers do not meet any of those considerations. This Comment proposes a simple rule to correct for this doctrinal inconsistency: absolute immunity for deliberative functions and qualified immunity for enforcement functions.

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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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Essay
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.