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Response
Algorithmic Interpretation
Kevin Tobia
Associate Professor, Georgetown University Law Center.

Professor Jonathan Choi’s Measuring Clarity in Legal Text adds to a growing literature in empirical legal interpretation, which uses corpus linguistics and survey-experiments to inform legal interpretation. Measuring Clarity offers two intriguing theses, one positive and one critical. On the “positive” reading, the article defends its word embedding approach as a useful method of first-order legal interpretation. On a “critical” reading, the article employs word embeddings as a new tool to assess textualism’s fundamental linguistic assumptions, concluding that there is a fundamental problem with textualism, or at least its current practice.

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Book review
Chaotic Childhoods
Stephanos Bibas
Judge, U.S. Court of Appeals for the Third Circuit

Stephanos Bibas is a judge on the U.S. Court of Appeals for the Third Circuit and a senior fellow at the University of Pennsylvania Law School. He thanks Brynne Follman and Joseph Graziano for their help.

To understand criminal justice, education, and family law, we lawyers typically look to social scientists, and their external expertise does teach us much. But we often neglect lived experience. Occasionally, we should toggle from the dry regressions and clinical detachment of social science to the internal perspective and expertise of those who live through family breakup, foster care, disrupted schooling, drugs, and crime. And that is what Rob Henderson’s breakout memoir, Troubled, gives us: a window on troubled youth.

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Essay
Appealing Magna Carta
Thomas J. McSweeney
Professor of Law, William & Mary Law School

I would like to thank Charlie Donahue, Dick Helmholz, John Hudson, Dan Hulsebosch, Matt Steilen, Jason Taliadoros, and Sarah White for comments on drafts of this Essay. Professors Helmholz and Donahue, both scholars I respect a great deal, have been very generous and gracious, even in the face of my disagreement with some of their conclusions.

In 1999, Professor Richard Helmholz published Magna Carta and the Ius Commune, in which he argued that some of the ideas and language found in Magna Carta provide evidence that the early common law was engaging with the ius commune, the ancestor of modern civil law traditions. This Essay argues that Magna Carta does not provide conclusive evidence whether contemporaries were thinking about Roman and canon law when reforming the common law.

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Considering Napue and the Defense's Role in Correcting False Testimony at Trial
Crystal Kwabea Adu-Poku
JD/MBA, University of Chicago, Class of 2023

She thanks Professor Judith Miller, Abigail Barney, Annie Kors, Matthew Makowski, and the University of Chicago Law Review Online team.

 

The views and opinions expressed in this Essay are solely those of the author. They do not purport to reflect the views or opinions of any entities or individuals she is associated with or represents.

This Essay argues that Gomez v. Commissioner of Correction provides an appropriate, holistic framework for determining when defense counsel should be precluded from raising Napue arguments in post-conviction proceedings.

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Essay
Some Doubts About Folk Jurisprudence: The Case of Proximate Cause
Felipe Jiménez
Assistant Professor of Law and Philosophy, University of Southern California.

Many thanks to Anya Bernstein, Lewis Kornhauser, Alexandra Lahav, Marcela Prieto, Anthony Sebok, Dan Simon, Kevin Tobia, Nina Varsava, and Benjamin Zipursky for comments on previous drafts.

According to a relatively common view, general jurisprudence is an exercise aimed at understanding “our ordinary concept of law.”

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Essay
Judicial Destruction of the Clean Water Act: Sackett v. EPA
Richard J. Lazarus
Howard J. and Katherine W. Aibel Professor of Law, Harvard Law School

In Sackett v. EPA, under the guise of judicial interpretation of the Clean Water Act, the Court effectively reduced the Act’s coverage of the nation’s streams by as much as 80%, and of the nation’s wetlands by at least 50%. Contrary to the majority’s proffered reasoning, nothing in the relevant statutory language compelled such an unprovoked hit job on the nation’s ability to protect its waters from harmful pollution.

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The Constitutionality of Prohibiting Caste Discrimination
Guha Krishnamurthi
Associate Professor at the University of Maryland Francis King Carey School of Law

Guha Krishnamurthi is an Associate Professor at the University of Maryland Francis King Carey School of Law. He thanks Kevin Brown, Charanya Krishnaswami, Chan Tov McNamarah, Alex Platt, Peter Salib, Joe Thai, attendees of the University of Maryland Carey School of Law Comparative Constitutional Democracy Colloquium for helpful comments, and the editors of the Law Review Online.

The problem of caste discrimination has come into sharp focus in the United States. In the last few years, there have been several high-profile allegations and cases of caste discrimination in employment and educational settings. As a result, organizations—including governmental entities—are taking action, including by updating their rules and regulations to explicitly prohibit discrimination based on caste and initiating enforcement actions against alleged caste discrimination.

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Response
For Bankruptcy Exceptionalism
Jared I. Mayer
Business Restructuring Associate at Ropes & Gray, LLP

Jared I. Mayer is a Business Restructuring Associate at Ropes & Gray, LLP. He received his J.D. from the University of Chicago Law School in 2021, his M.A. from Johns Hopkins University in 2018, and his B.A. from Johns Hopkins University in 2018. He thanks Professor Seymour, as well as Ryan Preston Dahl, Katharine Scott, and the editors of The University of Chicago Law Review Online for their helpful comments on earlier drafts of this Essay. The views presented in this Essay are his alone and do not reflect the views of Ropes & Gray LLP. All errors are his alone as well.

In his recent article, Against Bankruptcy Exceptionalism, Professor Jonathan M. Seymour argues that bankruptcy courts have wrongly bucked the Supreme Court’s trend toward textualism. Bankruptcy courts believe that they need to approach the Bankruptcy Code pragmatically in light of the unique dynamics inherent in bankruptcy practice and therefore adopt purposivist, equitable, or “rough justice” approaches to facilitate that kind of pragmatism—an attitude that Professor Seymour calls “bankruptcy exceptionalism.”

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Essay
Catching Wizard Spider: How a New U.N. Cybercrime Treaty Can Address Ransomware Attacks from Russia and Beyond
Katherine M. Koza
Katherine M. Koza is a J.D. Candidate at the University of Chicago Law School, Class of 2023, and the Executive Comments Editor of the Chicago Journal of International Law.

I thank the editors and staff of the University of Chicago Law Review, especially Matthew Makowski, Anson Fung, and Annie Kors. I also thank the Chicago Journal of International Law, especially Carol Zhang, Clare M. Chiodini, Michael Morgan, Keila Mayberry, and Amber Symone Stewart. I am grateful to my faculty advisor, Professor Aziz Huq, my international law professor, Professor Mary Ellen O’Connell, and the University of Chicago’s excellent international law librarian, Lyonette Louis-Jacques. I thank the American Society of International Law, International Courts and Tribunals Working Group for the opportunity to present a draft of this paper at the 2022 Works-In-Progress Conference. Finally, I thank my family for their constant love.

In June 2022, a Russian-linked ransomware group attacked the Costa Rican government, targeting over twenty-seven agencies and sending Costa Rica’s healthcare system “into a spiral.”

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Essay
John Doe Defendants: Portents of Mystery, but Perhaps Not Diversity Jurisdiction
Tyler Mikulis
Tyler Mikulis is a J.D. Candidate at the University of Chicago Law School, Class of 2024.

He thanks Malcolm Yeary, Maggie Wells, Savannah Kostrzewa, and the University of Chicago Law Review Online team.

The Florida defendant files a motion to dismiss under Federal Rule of Civil Procedure 12(b)(1)—asserting that the court lacks subject matter jurisdiction. Should the court grant it? More specifically, does having an anonymous John Doe as a defendant categorically preclude diversity jurisdiction?

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Essay
Revisiting the Fairness of the Fair Housing Act: Whose Consideration is Enough?
Tahnee Thantrong Monnin
Tahnee Thantrong Monnin is a Managing Editor of the University of Chicago Law Review and a J.D. Candidate in the University of Chicago Law School Class of 2023. She received her B.A. from Duke University in 2018.

She thanks Professor Lee Fennell for her thoughtful advice and insight, as well as Jay Clayton, Matthew Makowski, Claire Rice, and Virginia Robinson for their comments on previous drafts. She also thanks the incredible editors of the Law Review for their continued support and guidance.

In 1975, Lawrence Salisbury moved into his father’s mobile home, which was situated on rented land owned by the city of Santa Monica.

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Essay
Aggregating Values: Mutual Funds and the Problem of ESG
Adriana Z. Robertson
Adriana Z. Robertson is the Donald N. Pritzker Professor of Business Law at the University of Chicago Law School.
Sarath Sanga
Sarath Sanga is a Professor of Law at the Northwestern University Pritzker School of Law and the William Nelson Cromwell Visiting Professor of Law at Harvard Law School.

We thank Jill Fisch, Kate Judge, Elizabeth Pollman, Christina Skinner, David Weisbach, and the University of Chicago Law Review Online team for valuable suggestions and discussions. This Essay benefited from comments by workshop participants at the 1st Annual Women in Law & Finance Conference. Talla Khelghati provided exceptional research assistance. All errors are our own.

What does it mean for a fund to deliver ESG results to its investors?