Symposium: Ensuring accurate information for patients does not violate the First Amendment

Symposium: Ensuring accurate information for patients does not violate the First AmendmentErwin Chemerinsky is Dean and Jesse H. Choper Distinguished Professor of Law at the University of California, Berkeley School of Law. Merely requiring clinics to post a notice informing women of the availability of free or low-cost reproductive health care services does not violate the First Amendment. In many different ways, health-care professionals are already […]

The post Symposium: Ensuring accurate information for patients does not violate the First Amendment appeared first on SCOTUSblog.

Symposium: Ensuring accurate information for patients does not violate the First Amendment

Erwin Chemerinsky is Dean and Jesse H. Choper Distinguished Professor of Law at the University of California, Berkeley School of Law.

Merely requiring clinics to post a notice informing women of the availability of free or low-cost reproductive health care services does not violate the First Amendment. In many different ways, health-care professionals are already required by law to provide information to patients so they can make informed choices. The California statute at issue in National Institute of Family and Life Advocates v. Becerra is no different.

The Reproductive FACT Act is quite straightforward. Licensed health-care facilities must post or distribute a notice that states, “California has public programs that provide immediate free or low-cost access to comprehensive family planning services (including all FDA-approved methods of contraception), prenatal care, and abortion for eligible women. To determine whether you qualify, contact the county social services office at [insert the telephone number].” An unlicensed facility also must disseminate a notice to all clients acknowledging that it is not licensed as a medical facility by the state of California.

That’s all the FACT Act does. No doctor, other health-care professional or facility is required to provide contraceptives or abortions, or even provide referrals for these services. The new law simply ensures that clinics expose their patients to accurate information about the existence of state programs.

The FACT Act was created for the stated purpose of ensuring that “[a]ll California women, regardless of income, … have access to reproductive health services.” In the preamble to the bill, the legislature noted that more than 700,000 California women become pregnant each year and that one-half of these pregnancies are unintended. The legislature adopted the act because many women are not aware of the services available to them — and if they happen into a “crisis pregnancy center,” they’ll exit none the wiser.

The California legislature was concerned that there are 200 crisis pregnancy centers in California that hinder the ability of California women to receive accurate information about their reproductive rights and to exercise those rights. The legislative history explains that crisis pregnancy centers “pose as full-service women’s health clinics, but aim to discourage and prevent women from seeking abortions” in order to fulfill their goal of “interfer[ing] with women’s ability to be fully informed and exercise their reproductive rights.” The legislature found that crisis pregnancy centers, which include unlicensed and licensed clinics, employ “intentionally deceptive advertising and counseling practices [that] often confuse, misinform, and even intimidate women from making fully-informed, time-sensitive decisions about critical health care.”

Crisis pregnancy centers have been known to spread false medical information and use scare tactics to dissuade their clients from seeking abortions. For instance, centers have told pregnant women that their chances of getting breast cancer increase after an abortion. They have also warned clients that abortions are high-risk procedures that could well result in infection and death. Neither of these claims is true.

In light of this history, the California statute is clearly constitutional. The First Amendment burden on the crisis pregnancy centers is minimal: They are just required to post a notice. Their employees need not utter any words. The notices are entirely factual, informing patients about the existence of state programs. The required signs do not advocate anything. Requiring unlicensed facilities to disclose these facts to patients is just another way of ensuring that patients have full and accurate information.

Health-care professionals are routinely required to inform patients of the range of treatment options available to them and of possible side effects to medical procedures. Whether the patient has a heart problem, wants plastic surgery or is considering how to handle an unintended pregnancy should make no difference. There is a constitutional right to abortion, after all.

More generally, businesses that sell products and services are frequently required to provide information to consumers, ranging from the disclosure of calories in fast-food restaurants to the risks from tobacco and alcohol. Courts consistently have upheld such disclosure requirements and rejected claims that they violate the First Amendment.

Thus, as the U.S. Court of Appeals for the 9th Circuit concluded, “California has a substantial interest in the health of its citizens, including ensuring that its citizens have access to and adequate information about constitutionally-protected medical services like abortion.” Even if the Supreme Court finds that the required posting is compelled speech, the traditional interest in ensuring that patients receive accurate and adequate information is sufficient to justify this law. A contrary holding would put in jeopardy all informed-consent laws in medicine and the countless laws that require posting of information in a myriad of contexts.

It is notable that the Supreme Court granted review only on the question of whether the California statute violates the speech clause of the First Amendment. The challengers to the law also raised in the federal district court and the 9th Circuit the issue of whether the law violates their free exercise of religion. Both lower courts rejected the religion claim based on the Employment Division v. Smith, which held that the free exercise clause of the First Amendment cannot be used to create an exception from a general law. In that case, Native Americans argued that an Oregon law prohibiting consumption of peyote infringed their free exercise of religion in that their religion required use of the hallucinogenic substance. The Supreme Court, in an opinion by Justice Antonin Scalia, ruled against the Native Americans and held that the free exercise clause could not be used to challenge the Oregon law because it was neutral, in that it was not motivated by a desire to interfere with religion, and because it applied to everyone in the state. Likewise, California’s Reproductive FACT Act is a neutral law of general applicability.

This also explains why NIFLA is distinguishable from Burwell v. Hobby Lobby Stores Inc. In Hobby Lobby, the Supreme Court held that it violated the Religious Freedom Restoration Act to require that a family-owned business provide contraceptive coverage for employees when doing so violates the owner’s religious beliefs. But there is no religion issue before the court in this case. Moreover, RFRA applies only to the federal government; it was declared unconstitutional as to state and local governments.

Most importantly, though, the California statute requires no more than that a notice be posted informing women of services that may be available to them from the government. This should be an easy case and the Supreme Court should uphold the California law.

The post Symposium: Ensuring accurate information for patients does not violate the First Amendment appeared first on SCOTUSblog.

from http://www.scotusblog.com

Mom dodges prison for being passed out on drugs as son froze to death

A North Carolina woman will not serve prison time after pleading guilty to involuntary manslaughter in the death of her 3-year-old son, who froze to death on the front porch of their home after she “passed out” on drugs. Jamie Lyn Basinger, 24, of Morganton, received a suspended sentence of 19 to 32 months with…

A North Carolina woman will not serve prison time after pleading guilty to involuntary manslaughter in the death of her 3-year-old son, who froze to death on the front porch of their home after she “passed out” on drugs. Jamie Lyn Basinger, 24, of Morganton, received a suspended sentence of 19 to 32 months with...

from https://nypost.com

Categories: Uncategorized

School staffer allegedly took upskirt videos of juvenile students

A former staffer at a Colorado secondary school is accused of secretly recording upskirt cellphone videos of at least three students. Steven Michael Jenkins, 54, was booked on three counts of sexual exploitation of a child after his arrest over a complaint made by the principal of Castle Rock’s Renaissance Secondary school that he had…

A former staffer at a Colorado secondary school is accused of secretly recording upskirt cellphone videos of at least three students. Steven Michael Jenkins, 54, was booked on three counts of sexual exploitation of a child after his arrest over a complaint made by the principal of Castle Rock’s Renaissance Secondary school that he had...

from https://nypost.com

Categories: Uncategorized

84 Percent of Young State Offenders Recidivate-New Federal Report

Overview A new federal report offers comparisons of recidivism as to age and a variety of additional factors. For offenders age 24 or younger at the time of release, 63.2 percent of federal prisoners were rearrested within five years compared to over four-fifths (84.1%) of state prisoners. Author Leonard Adam Sipes, Jr. Thirty-five years of […]

Overview A new federal report offers comparisons of recidivism as to age and a variety of additional factors. For offenders age 24 or younger at the time of release, 63.2 percent of federal prisoners were rearrested within five years compared to over four-fifths (84.1%) of state prisoners. Author Leonard Adam Sipes, Jr. Thirty-five years of […]

from https://www.crimeinamerica.net

Symposium: If Justice Kennedy thought Colorado was “neither tolerant nor respectful” of a baker’s religious beliefs, how will he feel about California’s attack on pro-life pregnancy centers?

Symposium: If Justice Kennedy thought Colorado was “neither tolerant nor respectful” of a baker’s religious beliefs, how will he feel about California’s attack on pro-life pregnancy centers?John J. Bursch is the founder of Bursch Law PLLC, a Michigan-based appellate boutique. He submitted an amicus brief in support of the crisis pregnancy centers’ cert petition in National Institute of Family and Life Advocates v. Becerra. The Supreme Court is taking an unusually hard look at government-compelled speech this term. The recent oral […]

The post Symposium: If Justice Kennedy thought Colorado was “neither tolerant nor respectful” of a baker’s religious beliefs, how will he feel about California’s attack on pro-life pregnancy centers? appeared first on SCOTUSblog.

Symposium: If Justice Kennedy thought Colorado was “neither tolerant nor respectful” of a baker’s religious beliefs, how will he feel about California’s attack on pro-life pregnancy centers?

John J. Bursch is the founder of Bursch Law PLLC, a Michigan-based appellate boutique. He submitted an amicus brief in support of the crisis pregnancy centers’ cert petition in National Institute of Family and Life Advocates v. Becerra.

The Supreme Court is taking an unusually hard look at government-compelled speech this term. The recent oral argument in Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission was our first window into what the justices are thinking, and how they might view National Institute of Family and Life Advocates v. Becerra, the upcoming argument involving California’s Reproductive FACT Act.

For those who have taken a long sabbatical from all legal news, the Masterpiece case involves cakeshop owner Jack Phillips, who sketches, sculpts and paints cakes as art. Phillips serves all customers, but because of his faith, he cannot express every customer’s message. He will not create cakes with vulgar language or slurs. He will not create cakes with Halloween themes. And he will not create custom-made cakes to celebrate a same-sex wedding ceremony, because he believes that God ordained marriage between one man and one woman.

The case began when a same-sex couple entered Phillips’ shop and asked him to create a cake for their wedding ceremony. Phillips told the couple that he would sell them any pre-made cake he had in his cooler; he would also sell them cupcakes or cookies or brownies or anything else on his shelf. But he could not custom-design a cake for their ceremony because of his religious beliefs. The declination resulted in a government order that compelled Phillips to make the cake, undergo sensitivity training with his employees — many are family members — and report regularly to the commission regarding his compliance.

At oral argument, in response to Colorado’s argument that Phillips had engaged in discrimination, Justice Anthony Kennedy gave a rather stern civics lecture about the importance of tolerance:

Counselor, tolerance is essential in a free society. And tolerance is most meaningful when it’s mutual.

It seems to me that the state in its position here has been neither tolerant nor respectful of Mr. Phillips’ religious beliefs.

Kennedy’s rebuke of Colorado brings us to NIFLA and California’s Reproductive FACT Act. The act targets non-medical, unlicensed pro-life organizations that provide emotional and financial support to pregnant mothers who elect to keep their babies rather than abort them. The act requires these organizations to provide extensive, written disclaimers stating that they are not licensed medical organizations, and it requires licensed medical centers that do not provide abortion to provide written notice to all clients about how the clients can obtain a state-funded abortion. These obligations are not imposed on any other organizations and are only targeted at those committed to fostering life from conception.

The act is one of numerous pro-choice laws California has enacted. California clinics and healthcare providers are prohibited from giving parents any information about their children’s medi­cal treatment, questions or prescriptions for contracep­tion unless the child consents. Minors can also obtain an abortion without notifying their parents or any other adult. If a minor is unable to pay, California will provide the funding. California has enacted statutes that “protect” pregnant mothers from pro-life counselors who seek to communicate truthful information about the conse­quences of abortion. And a 2014 California law dramatically expanded the supply of abortion providers in California by authorizing nurse practitioners, certified nurse midwives and physician assistants to perform first-trimester abortions through “vacuum aspiration,” a procedure in which a suction catheter is inserted in utero to extract a preborn baby. In the words of the National Abortion Federation’s president, this law cements California’s reputation as “the gold standard” for access to abortion.

In thinking about California’s compelled-speech law for pregnancy resource centers and Kennedy’s lecture to Colorado in the Masterpiece case, one can’t help but be reminded of the Supreme Court’s poetic 1943 statement in West Virginia Board. of Education. v. Barnette: “If there is any fixed star in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be orthodox in politics, national­ism, religion or other matters of opinion, or force citizens to confess by word or act their faith therein.”

It seems likely, then, that Kennedy will conclude that such orthodoxy is precisely what California politicians prescribed with the Reproductive FACT Act. The act was passed with the admitted purpose of targeting pro-life pregnancy resource centers — whose views often flow from their religious faith — based on the centers’ viewpoint that “discour­age[s] abortion.” The act forces the centers to be spokespersons for the abortion industry via compelled speech — specifically, the posting of notices directing women how to obtain a state-funded abortion, and the required utterance of the obvious fact that the centers do not provide medical treatment. The second provision is a command to dissuade clients; the first is anathema to organizations whose religiously motivated speech and conduct are intended to save lives, not to take them.

In 2013, in Agency for International Development v. Alliance for Open Society International, the Supreme Court said that the government could not condition funding on a recipient’s promise to express a message; had such a policy been enacted as a direct speech regulation, it would “plainly violate the First Amendment,” because “freedom of speech prohibits the govern­ment from telling people what they must say.” Yet telling pregnancy resource centers what they must say is the Reproductive FACT Act’s entire purpose.

Perhaps the most famous of the Supreme Court’s decisions involving government-compelled speech is Wooley v. Maynard, the 1977 citizen challenge to New Hampshire’s statute making it a crime to obscure the words “Live Free or Die” on the state’s license plates. As it struck down the New Hampshire statute, the court recognized that a “system which secures the right to proselytize religious, politi­cal and ideological causes must also guarantee the concomitant right to decline to foster such concepts.” In other words, the “right to speak and the right to refrain from speak­ing are complementary components of the broader concept of ‘individual freedom of mind.’”

Describing New Hampshire’s requirement, the Supreme Court noted that it had the effect of “requir[ing] [state citizens to] use their private property as a ‘mobile billboard’ for the State’s ideological message or suffer a penalty.” Such coercive conduct is unconstitutional: “The First Amendment protects the right of individuals to hold a point of view different from the majority and to refuse to foster, in the way New Hampshire commands, an idea they find morally objectionable.”

The Wooley court acknowledged New Hampshire’s professed interest in requiring the license-plate speech — promoting appreciation of history, individual­ism and state pride — but did not find the interest sufficiently compelling to justify the regulation. “[W]here the State’s interest is to disseminate an ideol­ogy, no matter how acceptable to some, such interest cannot outweigh an individual’s First Amendment right to avoid becoming the courier for such message.”

It is difficult to escape the conclusion that, notwithstanding California’s protestations that pregnancy resource centers engage in misleading advertising, the Reproductive FACT Act was motivated by an interest in disseminating a pro-choice ideology. As a result, California can expect tough sledding at the argument, which will likely take place in late February. You can almost hear Kennedy: “It seems to me that California has been neither tolerant nor respectful of these centers’ religious beliefs. Did you not hear what I said on this topic in Masterpiece?!”

Assuming NIFLA prevails, the aftermath may actually be more interesting. Some commentators have suggested that if California cannot force pregnancy resource centers to proclaim how to procure a government-paid abortion, then pro-life states cannot force abortion clinics to conduct ultrasounds and provide truthful information about the growing baby at its particular gestational age. There is some intuitive appeal to that suggestion, but it fades with a little more consideration. Abortion clinics engage in surgical medical procedures. If the government cannot force doctors and surgeons to disclose truthful, relevant information about a medical procedure so the patient can make an informed decision, then we all have big problems. In contrast, the entire purpose of a pregnancy resource center is to support a mother in her choice not to undergo a medical procedure. Hence the difference in what the government can require.

Regardless, the Reproductive FACT Act is unlikely to stand.

The post Symposium: If Justice Kennedy thought Colorado was “neither tolerant nor respectful” of a baker’s religious beliefs, how will he feel about California’s attack on pro-life pregnancy centers? appeared first on SCOTUSblog.

from http://www.scotusblog.com

Man whose crude exchange with judge went viral gets life

A Georgia man — whose extraordinarily vulgar courtroom exchange with a judge was immortalized by the hit TV show “Rick and Morty” — has pleaded guilty but mentally ill to killing his cellmate. Denver Fenton Allen, 33, pleaded guilty Monday after Judge Billy Sparks denied Allen’s  motion that he killed Stephen Rudolph Nalley in self-defense…

A Georgia man — whose extraordinarily vulgar courtroom exchange with a judge was immortalized by the hit TV show “Rick and Morty” — has pleaded guilty but mentally ill to killing his cellmate. Denver Fenton Allen, 33, pleaded guilty Monday after Judge Billy Sparks denied Allen’s  motion that he killed Stephen Rudolph Nalley in self-defense...

from https://nypost.com

Categories: Uncategorized

NY Terror Suspect’s Actions Baffle Acquaintances

Authorities say Akayed Ullah, 27, set off a bomb in retaliation for American airstrikes in Syria and elsewhere, targeting members of the Islamic State. He said he had been radicalized online and had made a number of trips overseas in the past five years.

Akayed Ullah seemed an ordinary member of a Bangladeshi enclave in Brooklyn. He often prayed at a mosque in the Kensington neighborhood, where a few thousand of his countrymen reside. He worked for a car service. On Monday morning, Ullah, 27, strapped a pipe bomb to his body and set out to detonate it in a Times Square subway station, causing chaos among commuters and leaving what the New York Times calls “a trail of mystery that baffled those who knew him.” “He was a good guy,” said Mohammad Yousuf, a cabdriver who prayed with Ullah. “I can’t believe he would do anything like this.” Law enforcement officials quoted Ullah as saying that he set off the bomb in retaliation for American airstrikes in Syria and elsewhere, targeting members of the Islamic State. He said he had been radicalized online and had made a number of trips overseas in the past five years.

Ullah looked up online how to build the bomb and assembled it in his residence, purchasing all of the materials except the pipe, which he found at a job site where he was working as an electrician. Ullah lived in Brooklyn’s Flatlands neighborhood for seven years. On Sunday night, a neighbor said, a tenant heard the sounds of “big fighting” from Ullah’s house. Kensington is home to more than 3,000 Bangladeshi-born New Yorkers, making it the largest Bangladeshi enclave in Brooklyn. Mian Quadry, a representative of the Bangladesh Muslim Center in Kensington who did not know Ullah, said, “This is not what and who we are.”

from https://thecrimereport.org

Why DA Objects to More Freedom for Middle School Shooter Bruco Eastwood

Reading from the Voice Media empire: On Friday, December 15, a judge will determine if Bruco Strong Eagle Eastwood will be allowed to venture unsupervised off the grounds of a state mental hospital, where he’s resided since being found not guilty by reason of insanity for shooting and wounding two students at Deer Creek Middle School seven years […]

The post Why DA Objects to More Freedom for Middle School Shooter Bruco Eastwood appeared first on True Crime Report.

Reading from the Voice Media empire: On Friday, December 15, a judge will determine if Bruco Strong Eagle Eastwood will be allowed to venture unsupervised off the grounds of a state mental hospital, where he’s resided since being found not guilty by reason of insanity for shooting and wounding two students at Deer Creek Middle School seven years [...]

The post Why DA Objects to More Freedom for Middle School Shooter Bruco Eastwood appeared first on True Crime Report.

from http://www.truecrimereport.com

Trump Cites Terror Attack in Call for Immigration Overhaul

President says New York City terrorism suspect Akayad Ullah “entered our country through extended-family chain migration, which is incompatible with national security.”

President Trump said Monday’s attempted New York City terrorist attack is more evidence that the U.S. immigration system needs a total overhaul to end immigration based on family relationships, the Wall Street Journal reports. Suspect Akayad Ullah “entered our country through extended-family chain migration, which is incompatible with national security,” Trump said. Ullah emigrated to the U.S. in 2011 from Bangladesh. He received a visa for relatives of U.S. citizens and is a legal permanent resident. The issue of “chain migration” has taken on currency among Republicans, with many suggesting that ending the practice should be coupled with legalization for so-called Dreamers, who were brought to the U.S. as children and are living here illegally.

The Trump administration has made cracking down on immigration—both legal and illegal—a priority. Officials argue that vetting procedures for foreigners trying to come to the U.S. haven’t been stringent enough in the past. Foreigners asking to move to the U.S. are subject to extensive vetting, including background checks with law enforcement and the intelligence community. People with criminal histories are generally not allowed into the U.S., even if they are sponsored by a relative. Foreigners being sponsored by their U.S citizen relatives also must provide evidence of their relationship, affidavits of support from their American relatives, and sit for an interview with U.S. State Department officials. Family visas like the one Ullah used are subject to a cap of 226,000 a year.

from https://thecrimereport.org

Tuesday round-up

Tuesday round-upYesterday the court issued additional orders from its December 8 conference; the justices did not add any cases to their docket, and they declined to review a case asking whether federal law prohibits employment discrimination on the basis of sexual orientation. Amy Howe has this blog’s coverage, which first appeared at Howe on the Court. […]

The post Tuesday round-up appeared first on SCOTUSblog.

Tuesday round-up

Yesterday the court issued additional orders from its December 8 conference; the justices did not add any cases to their docket, and they declined to review a case asking whether federal law prohibits employment discrimination on the basis of sexual orientation. Amy Howe has this blog’s coverage, which first appeared at Howe on the Court. Additional coverage of the cert denial in Evans v. Georgia Regional Hospital comes from Greg Stohr at Bloomberg, Andrew Chung at Reuters, Adam Liptak for The New York Times, Richard Wolf for USA Today, Lyle Denniston at his eponymous blog, and Robert Barnes for The Washington Post, who reports that “the case at hand … had procedural problems that some argued made it a troublesome test case for the issue.” Commentary comes from Ross Runkel at his eponymous blog.

Benisek v. Lamone, a partisan-gerrymandering challenge by Republican voters to a congressional district in Maryland that the justices added to their docket last Friday, is drawing comment. At the Election Law Blog, Rick Pildes observes that “[d]eciding to hear the Maryland case is a significant signal that a majority of the Court is not going to hold partisan gerrymandering claims to be non-justiciable (that is, inappropriate for judicial resolution)” in the first partisan-gerrymandering case this term, Gill v. Whitford, a challenge by Democratic voters to Wisconsin’s electoral maps. In an op-ed for the Los Angeles Times, Richard Hasen suggests that “[d]eciding Gill and Benisek together would allow the court, in announcing a new partisan-gerrymandering rule, to say that sometimes the rule favors one party and sometimes it favors the other.” Steven Mazie at The Economist’s Democracy in America blog agrees that “[b]eing perceived by the public as an honest broker unwedded to party or ideology is an increasingly elusive but fervent wish of many of the justices—particularly the chief.”

At Law.com, Tony Mauro reports on research showing that Supreme Court law clerks belong to “an elite club still dominated by white men,” and that although “some variables are outside the court’s control, few justices seem to be going out of their way to help boost diversity.” Additional reporting on the research comes from Tony Mauro and Vanessa Blum at The National Law Journal (subscription or registration required). Also at The National Law Journal, Mauro breaks down the findings on gender imbalance among Supreme Court clerks here and racial diversity here, and identifies the most prolific “feeder” judges here and law schools here, while Karen Sloan reports that Justice Clarence Thomas “casts the widest net” in venturing beyond elite law schools when hiring his law clerks.

For The Los Angeles Times, David Savage reports that a 1990 opinion by the late Justice Antonin Scalia “looms uncomfortably over the court these days as conservative Christians seek a religious exemption from anti-discrimination laws adopted in liberal states” in cases like Masterpiece Cakeshop v. Colorado Civil Rights Commission, in which the court will decide whether the First Amendment bars Colorado from requiring a baker to create a cake for a same-sex wedding. At The World and Everything In It, Mary Reichard reviews the legal arguments in Masterpiece Cakeshop.

Briefly:

  • In an op-ed at the Huffington Post, Tim Lynch looks at a cert petition in a criminal case “that raises fundamental constitutional questions concerning federal power and police accountability for civilian deaths.”
  • At Horvitz & Levy’s At the Lectern blog, David Ettinger notes that the solicitor general has recommended that the court deny review of a California Supreme Court decision holding that “California’s temporary ban on a particular method of gold mining pending adoption of suitable regulations is not preempted by federal law.”
  • At Law360 (subscription required), Daniel Walfish explains why “[t]he Trump administration’s new position on the constitutionality of the S. Securities and Exchange Commission’s administrative law judges is more far-reaching and potentially consequential than is generally understood.”
  • US Law Week Blog’s Court Reporter salutes the achievement of second-time Supreme Court litigant Fane Lozman, noting that “[f]or private citizens, winning cert. even once is about as difficult as cutting down the mightiest tree in the forest with a herring.”

 

We rely on our readers to send us links for our round-up.  If you have or know of a recent (published in the last two or three days) article, post, podcast, or op-ed relating to the Supreme Court that you’d like us to consider for inclusion in the round-up, please send it to roundup [at] scotusblog.com. Thank you!

 

The post Tuesday round-up appeared first on SCOTUSblog.

from http://www.scotusblog.com