Category Archives: Uncategorized

But Your Honor, Elie Said So On The Internet

It’s both unfair and very fair to lay this at my pal Elie Mystal’s feet.  While he most assuredly didn’t write it, it appears under his byline and in a space under his control, ATLRedline.  The first three letters refer to Above The Law, while the Redline part refers to . . . well, I really don’t know, but it’s basically where Elie lets his freak flag fly.

Above The Law is a business. It started as a snarky, irreverent blog, back when David Lat wrote it, captured a huge audience, and then monetized. It still offers stuff that biglaw babies and wannabes want to know, like what firms are giving what bonuses.  It still has a few outside contract writers who offer smart posts.  And it offers a lot of worthless dreck because it needs to fill empty pages for whatever clicks they can get.  The people writing the dreck think they/re important because their dreck is on ATL. More knowledgeable people just shake their heads.

But for the most part, it’s harmless dreck. Occasionally, they’ll stumble into something foolish, like when Staci Zaretsky decided to try a new concept of using ATL for a bitchfest of sexism in the law, which was oddly called the “Pink Ghetto.” The problem was her characterization of complaints as “horror stories,” the “most appalling stories,” when they were largely pedestrian examples of banal sexism and bad jokes.* But it was hugely attractive clickbait for the disaffected females who wanted to share their feelz.  Continue reading →

No, You Aren’t Entitled and I’ve Had Enough

A while back, some flaming nutjob who called herself Judith decided that she was entitled to school me on what I owed readers. It started with this:

This is an excellent article on the state of affairs right now. But your answer to GEJC was curt and dismissive.

My reaction was less than supportive. She replied:

By virtue of writing this blog, you do owe something to your readers: a continuation of what was a thoughtful piece of writing. I am no one’s “entitled piece of shit.” I am a concerned grandmother who is very disheartened by the state of race relations in our country today. Your blog was recommended to me by someone whose opinion I respect, someone who would never say “fuck you” to a grandmother. Would you say that to yours? “Fuck you” is the response of the person who has nothing intelligent left to say. “I expect civility from you, but that does not mean I will respond in kind” is just insulting. I will no longer follow your blog. Please remove me from your list.

The only reason I responded in that manner was because I couldn’t reach through the computer and smack her upside the head.  But perhaps at the time, I didn’t fully appreciate the sense of entitlement of some readers, that I “owed” them. Continue reading →

When No Amount of Brady Will Do

And if the prosecution fails to provide the material required hereunder, and it’s only discovered after the defendant has been convicted, it will be left to the judge, as protector of the Constitution, to decide whether it is sufficiently exculpatory, sufficiently material, to decide whether there is a sufficient probability that, had it been disclosed, the jury would have returned a verdict of “not guilty.”  Chances of that ever happening are slim to none. Heh. Got ya.

— Associate Justice of the Supreme Court of the United States, William O. Douglas, Brady v. Maryland (first draft)

How Caddo Parish Judge Katherine Clark Dorroh got her hands on the draft opinion is a mystery, but she certainly put it to use in her opinion in Louisiana v. Williams.

In an opinion that reads like a parody of the absurd results courts can reach in applying the doctrine of “materiality” in Brady claims, a judge in Louisiana held late last month that witness statements placing a murder weapon in the hands of a man other than the defendant–both before and after the crime–are “not material” evidence, and would not have affected the outcome of the trial. Continue reading →

The Department of Education’s Next Epidemic

Flush with its success at having done what would have been unimaginable a generation ago, having untethered the concept of rape from its definition, eviscerated due process, and rammed its guidance down the throats of academia despite the absence of any lawful authority, outgoing Secretary of Education, Arne Duncan, has a new dragon to slay.

“Yes, we should have free speech. Yes, we should have diversity of ideas. Yes, we should be encouraging vigorous debate and all kinds of things,” Duncan told Mic. “But when young people don’t feel safe, feel absolutely isolated, feel absolutely intimidated, made to not feel welcome — that’s something else.”

“We have to make sure that kids feel they belong on campus, that they belong in this world,” he said. “And we have some work to do.”

As was accomplished under the guise of gender discrimination, where the nature of sexual interactions morphed from a putative anti-rape attack of “no means no” into an unworkable, meaningless morass of unprovable feelings and excuses under “yes means yes,” the rubric for the next assault on campus will be characterized as ending racial discrimination. Continue reading →

Dogma U: Only Virgins Need Apply

Nobody would have anticipated that Robert Dear would blurt this out in open court:

“I’m guilty. There’s no trial,” the accused mass killer Robert L. Dear Jr. told a startled courtroom here on Wednesday. “I’m a warrior for the babies.”

That he was against abortion does not distinguish him from millions of others. That his belief manifested in his going to Planned Parenthood in Colorado Springs and opening fire does.  Nobody who favors pro-choice walks into an obstetrician’s office and starts shooting people because they deliver babies rather than abort them.  There is an asymmetry to the competing beliefs, and it seems like all the deadly crazies adhere to one side rather than the other.

Yet, this is America, and we are entitled to believe whatever we want to believe.  We don’t need permission to believe in dogma, no matter how silly it may seem to others. It’s part of our bundle of rights, and you’re no more entitled to “thought police” someone else than they are entitled to “thought police” you.  What no one is entitled to do is kill people in furtherance of their beliefs.

There is a school in Tennessee named Carson-Newman University. Until today, I had never heard of it. After today, I won’t give it another thought. It’s a Christian college, and it makes no bones about that fact. Continue reading →

The “Mismatch” Between Scalia’s Troubling Question And The Troubling Reaction

Oral argument in Fisher v. University of Texas II was bound to be subject to enormous public scrutiny.  Challenges to affirmative action, or “holistic” college admissions policies as UT calls it, raise strong feelings.  There are problems with such policies from a legal perspective, that they are grounded in fuzzy words that defy clear definitions, lines and limits, leaving much to beliefs that can’t be nailed down.

Think of the sophomoric op-eds in student newspapers filled with sweeping cries of oppression, pain, privilege and trauma, designed to leave a reader with a sense of outrage and passion, but offering nothing that actually has concrete meaning.  Courts try to give meaning in their rulings.

They don’t always succeed, but that’s a bug, not a feature. Affirmative action is replete with warm and fuzzy rhetoric, and few hard definitions, regardless of the fact that diversity provides benefits to all, and lack of diversity reflects an unacceptable detriment to some.  How much diversity, how it’s determined, how far a college can go to help some at the expense of others, eludes easy definition. For believers, this isn’t a problem. For justices, it should be. They’re paid the big bucks to draw lines.  Hopefully, they do their job this time, but I won’t hold my breath.

Yet, the explosion out of the Supreme Court came not from the justices’ inability to get clarity, but from Nino Scalia’s question to Gregory Garre, representing UT. Continue reading →

Cross: Orin Kerr, Because Computers Aren’t Going Away

Dec. 9, 2015 (Mimesis Law) — Ed. Note:  Scott Greenfield crosses Orin Kerr, Volokh co-Conspirator, Fred C. Stevenson Research Professor of Law at George Washington Law School, prolific law review author on computer crime and Fourth Amendment law, and beltway bon vivant.

Q. Your college degree came from that bastion of racism, Princeton, where you received a B.S. in mechanical engineering. You went on to Stanford for your masters in mechanical engineering. And then, having the capacity to contribute beneficially to society, something went horribly awry and you went to Harvard Law School. What went wrong? Why waste a fine education and an opportunity serve humanity by becoming a lawyer? What the hell were you thinking?!?

A. I really enjoyed studying engineering as an undergraduate. But by the time I reached grad school, engineering lost its sense of excitement. In my field, fluid mechanics, professors were spending their entire careers seeking only incremental improvements to the solutions of very specific problems. I didn’t want to devote my career to solving small problems that only a few people cared about.

Q. It took a smart guy like you until the completion of his masters in mechanical engineering to realize that fluid mechanics might be a bit limiting? There are certainly a wealth of opportunities beyond fluid mechanics to apply your education in ways that served a broader purpose, but you instead chose to abandon engineering altogether for law school. Why law, of all the possibilities that were open to you?

A. I thought it would be intellectually exciting, I thought it would lead to gainful employment, and I had a sense that lawyers could do important things. And I got into Harvard.

Q. After law school, you clerked for Third Circuit Judge Leonard Garth, then headed straight for Main Justice. Was that the plan when you decided to waste your life by going to HLS? Did you have the dream of saving society from the bad guys?  You landed in the Honors Program, doing computer crime, which was in its relative infancy back then. Was this deliberate? Did they figure your engineering background made you one of the few who could figure out how computers worked?  Did you have an interest in the budding field of computer law before, or did it come from your work at DoJ?  Or do you really hate computer crime, but can’t figure out what else to do with yourself?

A. As far as I can remember – it’s been a while – I didn’t have much of a plan when I decided to go to law school. I vaguely recall that I wanted to go to a big law firm and make a lot of money representing large corporations, probably in a field that involved technology.

But I caught the criminal law bug instead. Part of that was being inspired by my first-year criminal law professor, James Vorenberg. He was awesome. And part of that was my experience as a summer associate after my 1L year. I was at Morris Nichols Arsht & Tunnell, a law firm in Wilmington, Delaware, mostly working on patent litigation. The people were nice, but I found patent work pretty dry. An associate at the firm had a pro bono criminal case and she let me help her. I was hooked. The human stakes were so much more interesting to me than which large corporation would keep a pot of money.

I ended up in the computer crime section mostly by accident. I was accepted into the Honors Program, and they gave me a list of sections I could rank. Computer crime seemed cool and the section had a good reputation, and I figured it was a good fit with my tech background. So I ranked the Computer Crime and Intellectual Property Section (CCIPS) first. But I got the job only because CCIPS management made a mistake. CCIPS was new and they had never hired an Honors Program lawyer before. When they received the form to rank candidates, they thought it was a form to invite candidates in for an interview. They decided to interview me and submitted the form. Later on, they were informed that they had permanently hired me. The Chief of CCIPS was livid because I was filling a spot he wanted to use for an experienced lawyer. He tried to get me fired before I arrived.   But it was too late, as there was no form to unhire someone. When I started the job and met with the Chief of CCIPS in his office, he told me that he didn’t want me in the section and that he had tried unsuccessfully to get rid of me. But there I was.

Q. You spent three years toiling in the trenches of Main Justice as a trial lawyer. Did you try cases? Back then, the internet was still in its infancy (maybe toddlerdom), and while the Computer Fraud and Abuse Act was already a tween by the time you showed up, it too was still subject to interpretation as to its application to ever-changing technology.  What did you think of the CFAA as a prosecutor? What were the issues with computer fraud when you were in the trenches?  Looking back now, are you happy with how you handled computer crime? Would you have done things differently knowing what you know now?

A. My trial experience at DOJ all happened when I was a SAUSA in the EDVA, which I did on a detail from CCIPS. I had two jury trials, a bunch of misdemeanor bench trials (common in the EDVA, which has a big misdemeanor docket), and the usual run of hearings (supervised release violations, etc.).   When I was at CCIPS in Main Justice, my title was “trial attorney,” but there wasn’t much cyber-related trial work to go around. The AUSAs in the field took most of what was there. I helped AUSAs with the cyber aspects of their cases, but the cases belonged to them.

I started thinking seriously about the CFAA and what it meant late in 1998 and early in 1999, when I was at CCIPS.  My recollection is that, at the time, everyone thought the CFAA was pretty simple and uncontroversial. You just had to look for unauthorized access, which was thought to be straightforward and obvious. My view was different: It seemed to me that there were lots of different ways of thinking about “access” and “authorization.” I also thought that the narrower reading of the CFAA was correct. When the civil cases adopting really broad interpretations of the CFAA started to emerge around 2000 and 2001, I thought they were wrong.  I wrote my first article on the ambiguity of the CFAA and the need to interpret it narrowly soon after I left DOJ. I left DOJ in 2001, and the article was written in 2002 and published in the NYU Law Review in 2003.

Q. After two years of teaching, you got a gig as law clerk to Supreme Court Justice Anthony Kennedy. How did you manage that coup?  As the “swing vote” on the Court, you were working under perhaps the single most powerful judge in the nation. Did you share his perspective on the law? How involved were you in the decision-making?  What was the coolest case you worked on for Justice Kennedy, and what was your role in the case?  Did you ever find yourself in strong disagreement? If so, how did you deal with it? And how did Justice Kennedy deal with you?

A. How did I get the job? Well, I applied.  It was a long shot, and I wasn’t expecting anything. I hadn’t been on law review, I hadn’t clerked for a feeder judge, and I didn’t have references from the usual bigwig Harvard professors.  But sometimes strange things happen, and it worked out.

I had some common views with Justice Kennedy, but we approached a lot of issues pretty differently.  I think the law clerk ethics rules still prevent me from talking about particular cases, though.

Q. Following your stint as law clerk, you spurned another opportunity to use your not insignificant education and experience for good, and went back to teaching. Why?

A. GW let me come up for tenure the semester I returned from my clerkship. It was an easy call.

Q. For a guy who spurned engineering because it didn’t offer you the opportunity to work on issues that affected a lot of people, academia alone is curious, and tenure as the reason emits an unpleasant odor. You could have gone for the big bucks, the earth-shattering cases, and instead you chose the cloisters and snot-nosed kids. There had to be more than cheap and easy tenure. I call bullshit. Why?

A. You see academia as a way to avoid the real world.  But I think a law professor can have more influence on the real world than a practitioner can.

Q. More influence? Does that mean by scholarship and research, by teaching others, by thinking deep thoughts, by serving on committees where only mitigated speech is tolerated?  What makes you say that?

A. Influence can happen in different ways, but scholarship and research is probably the most direct.  Some people say that no one reads law review articles.  But I don’t think that’s true.  A person who writes intelligently and thoughtfully about a really hard issue, especially one that others are struggling to figure out, can have a big impact.

My co-authors Wayne LaFave and Yale Kamisar are good examples.  Wayne’s work has been cited in thousands of legal opinions.   When there is a hard Fourth Amendment question, a lot of judges consult Wayne’s treatise to see what he has to say.  And Yale’s articles had a significant influence on the shape of interrogation law at the Supreme Court.  Would Yale and Wayne have had more influence on the law if they had started the criminal defense firm of Kamisar & LaFave?  I don’t think so.

Q. As one of the co-conspirators at Volokh, you’ve laid your politics on the table as a pretty conservative libertarian.  How did you come to that view?  How has it influenced you prolific writing?  Aside from computer crime, you’re deeply into Fourth Amendment law as well, where you’re not particularly inclined to be kind to the defense?  What happened to that libertarianism when it comes to search and seizure?

A. In college, I was vaguely left-of-center in the way that I would guess most college students are. After college, I decided to study American political conservatism because I hadn’t thought seriously about conservative ideas. I read as much as I could, and I was more persuaded by it than I expected. I shifted to vaguely right-of-center some time around 1994. Going to Harvard Law School, which I started in the fall of 1994, was probably a part of that. The political orthodoxy at HLS was so strong that it helped pushed me away towards the right.

I think my scholarship generally reflects my Burkean conservative views. I tend to think there’s a lot of wisdom in the traditional ways of doing things, and that plans to quickly and dramatically change the legal system are often utopian and will only make things worse. Given that, my scholarship tends to be more skeptical of dramatic change than that of other law professors. The equilibrium-adjustment theory is a good example. It has judges trying to maintain old protections as technology changes, changing the rules to preserve old values. It’s essentially a Burkean idea – preserving the old amidst the new.

From a career perspective, though, I suspect my Burkean conservative instincts are a hindrance. The hip thing in legal academia is to propose radical solutions; that is thought to signal creativity. In contrast, anything that doesn’t boldly challenge the status quo is considered overly cautious and small-minded. But so it goes.

Q. You’ve raised some fairly negative views toward the CFAA as being grossly misinterpreted to elevate terms of service into a sufficient basis for a criminal prosecution.  Along these lines, you served as one of Andrew Auernheimer’s (or “weev,” as we all know him) lawyers in the appeal of his conviction before the Third Circuit, and argued the case.  Of course, the conviction was reversed, but on the least sexy gound possible, venue.  Did it break your heart that the court didn’t decide on CFAA grounds?  When it came to representing weev, one of the most notorious trolls and generally difficult human beings around, did you have misgivings as to your argument on interpreting the CFAA resting on his very low-to the-ground shoulders?

A. I was very happy that we won, and I don’t have any misgivings about the case.

Q. One of the biggest bones of contention deals with the Magistrate’s Revolt, the refusal of some magistrate judges to sign off on warrants for digital content because of overbreadth and issues with disposition of data. You’ve been firm that the mags wrong, and this is for the judge to deal with after arrest. But since you can’t put the genie back in the bottle, you would give the government carte blanche to seize everything and sort it out later, after they’ve seen it all. Is there no hope for privacy in a digital world? Are there no limits, given that our entire lives can be seen online? Why, given your affection for equilibrium theory, shouldn’t the mags get involved to restore balance to the Fourth Amendment in a digital world?

A. I think you have this issue backwards.   I’m arguing for broad privacy protection, and you apparently want a world with only sporadic and discretionary privacy for a few lucky people. That is, I want the Supreme Court to interpret the Fourth Amendment to impose broad privacy protections in all cases, whether the cases involve warrants or not. The only way to get that broad privacy protection is from the Supreme Court in a case involving ex post review. On the other hand, you seem to only want privacy protection in the one in a thousand cases that happen to involve a warrant and one of the handful of appointed magistrate judges who decides to opt in to the revolt in that particular case. So in your approach, there’s privacy protection for the one in a thousand cases. You have to win the lottery to get privacy. But in my approach, everyone gets privacy.

Q. You’ve been a lawprof at George Washington since 2001, with a couple of stints as visiting prof at Penn and Chicago. Is that where you plan to stay?  Any thoughts of moving up the food chain, Harvard or Yale perhaps? A nice, warm bench, perhaps? What are the aspirations of a law professor who has made his mark, earned a firm niche through his scholarship and is still a young man?  Where do you go from here?

A. I’m going to Disney World!

Seriously, I hope to have the health, the energy, and the support to enjoy a long future writing law review articles on issues I care about.

Q. Unlike many academics, you also want to keep yourself in the game, as reflected by your involvement in the weev appeal. You’ve done some very successful pro bono appellate work, but what about getting back into the trenches and trying cases?  Is it now just a matter of getting involved in cases that involve your area of scholarship, or could you see yourself becoming an advocate for, say, the defense?  What do you think of law professors who bootstrap their scholarship for cause advocacy?  Is there a line that an academic shouldn’t cross, even if he still wants to be a player in the game of law?

A. I really enjoyed the small amount of trial work I did at DOJ. In a perfect world, it would be great to do more. But between not having a lot of trial experience, and it being a long time ago, I couldn’t jump back into it easily. Besides, I’m a “law guy,” so I’m mostly drawn to appeals. And when you have a full-time teaching job, it’s much easier to schedule appellate work.

I enjoy both scholarship and advocacy, but I see them as fundamentally different. Scholarship is about the search for truth. As a scholar, you go where the good arguments go, wherever that may be. It’s essential to be open to changing your mind and admitting the weakness of your position.   In contrast, advocacy is about helping the client. Obviously, as an advocate, the result you seek is predetermined. The only question is how you can best persuade the decisionmaker to rule the way that will best serve your client’s interests.

Don’t Crybullies Have Free Speech Too?

The best defense is a good offense, as the mantra goes, and this isn’t lost on Karen Gross, former president of Southern Vermont College and former senior policy advisor for the U.S. Department of Education.  None of that defensive nonsense that hate speech isn’t free speech for her.  At the Hechinger Report, “covering innovation and inequality in education,” Gross goes right for the throat.

“Crybullies,” “entitled whiner syndrome,” “spoiled sense of entitlement … ”

Since the start of the student protests on the University of Missouri campus that included a hunger strike by a graduate student and a sit-out by the Tigers’ football team, negative, demeaning and offensive comments have been hurled at student participants.

Well, it’s true that the characterizations haven’t been warm and fuzzy. That, of course, doesn’t mean they’re inaccurate. Just unpleasant.

It is as if folks assume that being enrolled in college or university is such a privilege that one parks one’s capacity to criticize at the door. Continue reading →

Constitutionality Conflated: The Trump Dilemma

So a guy shoots his mouth off, says a bunch of crazy shit, feeds into the worst prejudice and darkest whole of stupidity in the American psyche.  All because he wants to be president and taps into that ugliest portion of the public psyche grasping for the worst possible solution that makes them feel better.  And thinking people everywhere hate it. Hi, Donald Trump.

Trump came up with an idea about excluding Muslims from entry into the United States. The details of his scheme are both a moving target and irrelevant. Ain’t happening in any permutation, so who cares what noise emits from his yap?  But the knee-jerk response from the intelligentsia is that it’s “unconstitutional.”

When we hate an idea, we love to hear that it’s unconstitutional. It saves us from having to otherwise explain why it’s awful. We can just point to the Constitution (you remember the Constitution, it’s that thing you drag out when you like it and shove in the closet when you don’t), shrug and say, “yeah, well, it’s unconstitutional, so no point in discussing it. Move along.”  And everybody breathes a sigh of relief, because that insanity won’t fly. Continue reading →

A SCOTUS Non-Decision Adds To Gun Confusion (Update)

The national conflagration (it would be irresponsible to call it a discussion or debate, except to the extent it happened here) over gun rights and gun regulation blew up yesterday, when the Supreme Court poured gasoline on it in the form of a denial of certiorari, what Elie Mystal called “a rare loss for the gun lobby.”

At issue in the new case, Friedman v. City of Highland Park, was the constitutionality of a 2013 ordinance.  It prohibited the sale, purchase, or possession of semi-automatic guns, including those used with magazines with more than ten rounds of ammunition.  It was agreed, during a challenge to the ordinance, that the ban includes the widely popular AR-15 rifle — the civilian equivalent of the military’s standard M-16.  The challengers contended that these are not machine guns, because a pull of the trigger only fires one shot, not repeated firings.

Clearly, the case raises core issues that facially conflict with the Supreme Court’s Heller and McDonald decisions, and so their denial of cert means…

The court’s order didn’t explain the reasoning behind the decision, but two justices, Clarence Thomas and Antonin Scalia, split with their colleagues and laid out why they would’ve agreed to hear the case. Continue reading →