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Volume 93.5
Extradition in the Early Republic: International Law and Constitutional Authority
Curtis A. Bradley
Allen M. Singer Distinguished Service Professor, University of Chicago Law School.

For helpful feedback, I thank Will Baude, Kathy Bradley, Adam Cox, Ashley Deeks, Kristen Eichensehr, Jean Galbraith, Alex Loomis, Hiroshi Motomura, Gerald Neuman, Farah Peterson, John Parry, Eric Posner, Joe Schottenfeld, Neil Siegel, Ed Swaine, participants in a faculty workshop at the University of Chicago Law School, and participants in a conference at the University of Chicago Law School on “Sovereign Power and the Constitutional Text.” I would also like to thank the staff of the University of Chicago Law Library for their assistance in tracking down materials.

This Article is the first comprehensive account of the constitutional foundations of U.S. extradition practice and its relationship to international law. Through detailed analysis of early American extradition controversies—including the Longchamps Affair and the Robbins case—the Article shows how political actors and courts constructed the modern constitutional law of extradition, resolving key issues concerning presidential power, the role of the states, and the scope of congressional authority. This regime, the Article argues, emerged not from appeals to the constitutional text or original understandings, but rather from structural intuitions, consequentialist considerations, and, as time went on, historical traditions. The Article also complicates the dominant narrative of a unilateral “imperial presidency” in foreign affairs by showing that, because of the liberty interests involved, extradition authority evolved and remained as a shared power, requiring a treaty-based or statutory foundation as well as judicial involvement.

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Volume 93.5
Native Marburys: Judicial Review in Tribal Courts
Elizabeth Hidalgo Reese
Associate Professor of Law, Stanford Law School.

A sincere thank you to the editors at The University of Chicago Law Review, who were a total joy to work with. Many thanks to Greg Ablavsky, Matthew Fletcher, and Angela Riley for helpful comments and insights about the piece’s development. I could not have finished this without above and beyond edits from Adam Davidson and Easha Anand. Thanks to Richard Ford, Michelle Anderson, and George Triantis for being supportive, patient, and understanding so that I had time to finish writing this. This work would not have been possible without excellent research assistance from Madison Burson, Delaina Dixiemarie Castillo, Marissa Cheng Uri, Julia Regan, and Erin Hartman Wenokur. A final thank you to my incredible parents, Drs. George and Debbie Reese, and my husband, Nick Hidalgo, who all took incredible care of me (and Eevee) while I was slogging through writing this throughout a hard and exhausting pregnancy.

This Article is the first comprehensive account of judicial review in tribal courts. It makes four contributions. First, it provides insights about the institution of judicial review and its relationship to governance, highlighting that it is a choice that must be made with careful attention to the source and scope of judicial power, and to public opinion. Second, it helps us understand what tribal courts are, and how they fit into their tribal government systems. Third, it demonstrates how this better understanding of tribal courts is essential to the rights questions that preoccupy mainstream discussion of and lawmaking about tribal courts. Finally, it evidences the complexity of legal discourse in tribal courts. It demonstrates that tribal courts are thinking deeply about the law and the way that the law structures their governments and can limit or protect the rights of their citizens.

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Comment
Volume 93.5
Establishing a Right to Civil Transcription
Shruti Baxi
B.S. 2020, Yale University; J.D. Candidate 2027, The University of Chicago Law School.

My sincerest thanks to the Children & Families Practice Group at Legal Aid Chicago for introducing me to this topic, and to Professor William H.J. Hubbard, Jorge Colmenares, and the incomparable editors and staff of The University of Chicago Law Review for their thoughtful feedback.

Court reporters have long been a fixture of American jurisprudence, but tightening state budgets and a nationwide shortage of certified reporters have left many civil proceedings without any form of verbatim transcription at state expense. This hinders access to justice for impoverished parties: The absence of a transcript is often deadly to one’s chances of prevailing on appeal, no matter how meritorious the claim. This Comment draws on precedent regarding appellate transcript fees to argue that the Due Process and Equal Protection Clauses establish a right to verbatim transcript creation for some indigent civil litigants.

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Comment
Volume 93.5
A Principled Approach to Equitable Compensation Under ERISA § 502(a)(3)
Gabriel Juedemann
B.S. 2023, The University of North Carolina at Chapel Hill; J.D. Candidate 2027, The University of Chicago Law School.

I would like to thank Professor Josh Avratin and the editors and staff of The University of Chicago Law Review for their thoughtful advice and insight.

ERISA’s civil enforcement provisions protect workers whose plan administrators mishandle their benefits. In many cases, a beneficiary’s only path to relief is through § 502(a)(3)’s authorization of “appropriate equitable relief”; yet the Supreme Court has not been clear about when monetary compensation is available under this provision, and circuit courts have split as a result. This Comment proposes a workable judicial framework to resolve the split: Courts should award equitable monetary compensation when a fiduciary causes harm with clearly identifiable financial value and the beneficiary lacks the sophistication to protect themselves through alternative means.

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Comment
Volume 93.5
Administrative Acquiescence: An Analysis of Nonadverse Litigation Involving Administrative Agencies
Sami Winawer
B.A. 2023, Brandeis University; J.D. Candidate 2027, The University of Chicago Law School.

 I would like to thank Professor Sarah Konsky, Rachel Sommers, and the editors and staff of The University of Chicago Law Review for their thoughtful advice and insight.

When an agency declines to defend the constitutionality of its structure, the court must determine whether it can decide the issue despite the parties’ agreement. Building on case law and scholarship about the adversity requirement, this Comment proposes a multifactor framework for courts to use when making this decision. Pursuant to this framework, if a court finds that separation of powers concerns and pragmatic considerations related to judicial economy and the protection of affected nonparty interests counsel in favor of proceeding to the merits, it should appoint an amicus curiae to raise adverse arguments before deciding the issue.

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

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J.D. Candidate at the University of Chicago Law School, Class of 2025.

He thanks the University of Chicago Law Review Online team.

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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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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.