Joanna C. Schwartz

For helpful comments on earlier drafts, thanks to Karen Blum, Roger Clark, Barry Friedman, Christopher Kemmitt, James Pfander, Richard Re, Alexander Reinert, Lou Reiter, Jack Ryan, Seth Stoughton, and Stephen Yeazell. For help constructing the dataset of Ninth Circuit cases, many thanks to John Wrench and Anya Bidwell. For excellent research assistance, thanks to Bryanna Taylor and Hannah Pollack. Thanks also to the editors at The University of Chicago Law Review for excellent editorial assistance.