Category Archives: Supreme Court

She is.. She is.. NO, NO, NO, NOTORIOUS (R.B.G.)

Photo Credit: Angie Gottschalk, Ithaca Journal

Thirty years ago, before a sparse audience scattered throughout a cavernous auditorium at Cornell University, a petite woman argued passionately about the meaning of the U.S. Constitution. As her fellow symposium panelists — Cornell professors of law, government, and history — debated the technicalities of the document, she pushed for broader questions to be asked on issues that the Constitution is silent on, including “affirmative rights” and “cultural and social guarantees.”  ‘’ ‘Our Constitution is defective in that respect’ she said. ‘Why should the U.S. Constitution be a model for the world? Who needs freedom of speech when you have an empty belly?’ ” (Yaukey, Ithaca Journal, September 19, 1987, p. 4A)  

Much has changed in the intervening years. That appellate judge and pioneering women’s rights advocate who couldn’t draw a decent-sized crowd at her own alma mater, is now a pop culture icon.  Journalists breathlessly report on her fashion sensibilities (fishnet gloves anyone?) or when she is spotted carrying a tote bag with her own face on it.  Kids dress up as her for Halloween and adore her coloring book.

One thing hasn’t changed though: Ruth Bader Ginsburg still has plenty to say about the Constitution.

A lot has also been said and written about Justice Ginsburg, who holds an honorary degree from BLS.  The following are some relevant titles in the BLS Library collection to consider putting on your summer reading list:

Notorious RBG: The Life and Times of Ruth Bader Ginsburg by Irin Carmon & Shana Knizhnik (2015). [Call number: KF8745.G56 C37 2015]  The elevation of RBG to her current status as a cultural icon can be traced to the Notorious R.B.G. Tumblr created by Shana Knizhnik, one of the book’s co-authors, in 2013. This title is a colorful and entertaining look at Ginsburg’s life and career.  We get plenty of juicy nuggets about her Brooklyn childhood and nickname (Kiki), her favorite bathroom at Cornell where she could get schoolwork done (in the architecture school), the time she couldn’t check a citation as a Harvard Law Review member (the volume was located in a men-only library reading room), and how her mentor Prof. Gerald Gunther had to “blackmail” federal judge Edmund Palmieri so she could secure a clerkship (Justice Frankfurter flatly said no; Judge Learned Hand refused to hire women as he was “potty-mouthed” and did not want to watch his language around women.)   Notorious RBG remains accessible even when it starts covering the denser legal material from Ginsburg’s time as a law professor, at the ACLU Women’s Rights Project, and her judicial tenure.  Excerpts from the brief she authored in Reed v. Reed (1971), her majority opinion in the VMI gender discrimination case, United States v. Virginia (1996), and the dissent she read from the bench in the equal pay case Ledbetter v. Goodyear Tire & Rubber Co. (2007) (that helped spur passage of the Lilly Ledbetter Fair Pay Act of 2009) are all meticulously annotated so as to be readily understood by the layperson. RBG’s loving marriage to Marty Ginsburg shines through: the last note he wrote to her before he died from cancer, reproduced in the original, is especially touching.  Even if you don’t want to read all the material, skimming through the many photographs and illustrations in the volume can be a joy.

My Own Words by Ruth Bader Ginsburg, with Mary Hartnett and Wendy W. Williams (2016)  [Call number: KF373.G565 G56 2016]  My Own Words is a collection of Ginsburg’s writings and speeches which are given context by short introductory essays by her co-authors.  Especially interesting are the early documents: a school newspaper editorial from June 1946 that champions the new United Nations Charter; “One People”, a 1946 article for the East Midwood Jewish Center Bulletin (religious school graduation issue) discussing post-war unity; and a 1953 letter to the editor published in the Cornell Daily Sun titled “Wiretapping: Cure worse than Disease?” We get some insight into Ginsburg’s love for opera, friendship with Justice Antonin Scalia, and why her given name Joan never stuck.  Her family and marriage get some attention: husband Marty was a true partner, did all the cooking, and was the biggest champion of his wife — decades after the fact, he remained annoyed at Harvard Law School for not allowing RBG to be awarded a Harvard degree after completing her third year at Columbia.  Yet My Own Words feels incomplete: despite the many speeches, law review articles, briefs, and judicial opinions contained in the volume, Ginsburg’s personality and character remain elusive.  This is a function of the limited scope of the project: RBG’s co-authors Mary Hartnett and Wendy Williams are her official biographers, and one gets the sense that more personally revealing anecdotes and materials are being held back for the main publication that will follow.

Brief for Appellant, Reed v. Reed

The Legacy of Ruth Bader Ginsburg by Scott Dodson (ed.) (2015)  [Call number: KF8745.G56 L4499 2015]  This volume is a collection of 16 essays from legal luminaries that include Herma Hill Kay, Nina Totenberg, Lani Guinier, Tom Goldstein, and many more.  Linda Kerber’s essay “Before Frontiero there was Reed” vividly traces the history of Reed v. Reed, the first case in which the Supreme Court held that arbitrary discrimination based on gender violated the Equal Protection clause. As Kerber writes, Ginsburg added the names of Pauli Murray and Dorothy Kenyon to her Reed brief; even though neither had written a word, RBG “understood more clearly than anyone of her time the debt that the women of her generation [ ] owed to those of preceding generations.” Many of the essays focus on doctrine — criminal procedure, jurisdiction, federalism — but the closing essays speak to her temperament and approach to life and the law. The closing essay “Fire and Ice: Ruth Bader Ginsburg, the Least Likely Firebrand” by Dahlia Lithwick is especially revealing. Lithwick describes how Ginsburg’s judicial voice grew exponentially after Justice O’Connor retired and RBG was left the only woman on the court.  Faced with the male Justices’ insensitivities during oral argument in Safford Unified School District v. Redding (2009), a case in which school officials strip searched a teenaged female student, RBG took the unprecedented step of granting an interview while the decision was still pending. In the interview, Ginsburg told Joan Biskupic of USA Today (who was also Justice O’Connor’s biographer) that her colleagues “have never been a 13-year-old girl” and that more women were needed on the court. The student prevailed 8-1 in her claim against the school district.  And perhaps it was no coincidence that just 3 weeks after the USA Today interview was published, President Obama nominated Sonia Sotomayor to the Supreme Court.

Sisters in Law: How Sandra Day O’Connor and Ruth Bader Ginsburg went to the Supreme Court and changed the world by Linda Hirshman (2015).  [Call number: KF8744 .H57 2015]  Sisters in Law traces the background of two ostensibly very different women, one a Goldwater Girl, the other a card-carrying member of the ACLU, who ended up as pioneers on the Supreme Court.  Justice O’Connor was known to be a centrist, a “justice-as-legislator” who believed in “playing defense” to protect hard-earned gains and who adhered to incrementalism. In contrast, Ginsburg with her litigation and advocacy background was used to “playing offense.” Nevertheless, once RBG reached the court, she quickly determined that of all the relationships she needed to develop, the most important was the one with O’Connor.  Justice O’Connor, who had over the years been fed many of RBG’s clerks, reciprocated.  Contrary to tradition, RBG’s first assigned majority opinion for the court was not a unanimous decision but rather a complex ERISA case on which the Justices had split 6-3.  After Ginsburg had successfully navigated her way through this first challenge, O’Connor, who had dissented, sent her a note that read: “This is your first opinion for the Court, it is a fine one, I look forward to many more.”  Hirshman also includes an anecdote about how RBG, as the first Jewish justice in a generation, helped change court practices. Upon joining the court, Ginsburg sent a letter to Chief Justice Rehnquist, siding with Orthodox Jewish lawyers who objected to the year on their certificates of admission being worded as “The Year of Our Lord.”  She encountered resistance from an unnamed colleague (the author suspects Rehnquist or Blackmun) “Why are you making a fuss about this? It was good enough for Brandeis, it was good enough for Cardozo and Frankfurter.” RBG’s response? “It’s not good enough for Ginsburg.”  The Court ultimately acquiesced.  There is plenty in this book to chew on about both the differences and shared experiences of the first two female Supreme Court Justices, and how they have changed the dynamic of the Court forever.

 

May New Book List: Fact and Fiction

The Brooklyn Law School Library May 1, 2017, New Book List is now online and has 52 print titles and 31 eBook titles. The subject areas consist of law, history and even fiction.   Subjects are Executive orders — United States – Corporate governance — United States; Judicial power — United States; Solo law practice — United States; War crime trials — History — 20th century; Sexual rights — United States — History; Scalia, Antonin; Trial practice — United States. Like law school libraries throughout the country, the BLS Library has scholarly material subjects for legal researchers in its collection and on the New Book List.

Consider these new acquisitions:

Calling the Shots: The President, Executive Orders, and Public Policy (Call No. KF5053. G58 2017) by Daniel P. Gitterman, Professor of Public Policy at University of North Carolina in Chapel Hill. This 288-page book explains how modern presidents have used the power as purchaser to require federal contractors to pay a minimum wage and to prohibit contracting with federal contractors that knowingly employ unauthorized alien workers. This book is very timely as that author believes that the current administration will likely use a mix of executive orders and memorandums. Unlike executive orders, memorandums aren’t thoroughly recorded by the government. He says that “Memorandums go below the radar much more and are harder for, I think, the news media and the public to track”

Dear Chairman: Boardroom Battles and the Rise of Shareholder Activism (Call No. HD2744. G73 2015) by Jeff Gramm, Adjunct Associate Professor of Finance and Economics at Columbia Business School. In 291 pages, the book gives a rich history of shareholder activism that has been described as “a grand story” and an “illuminating read” by the Wall Street Journal, “a revelation” by the Financial Times, and “an excellent read” by Andrew Ross Sorkin at the New York Times. Last month, the author presented a Book Talk sponsored by the Center for the Study of Business Law & Regulation at Brooklyn Law School. For details, see this link.

The Unexpected Scalia: A Conservative Justice’s Liberal Opinions (Call No. KF8745.S33 D67 2017) by David M. Dorsen, a Washington lawyer with Sedgwick, LLP. In 377 pages, the book by a close friend of Scalia describes the subject as a leader in opposing abortion, the right to die, affirmative action, and mandated equality for gays and lesbians, and was for virtually untrammeled gun rights, political expenditures, and the imposition of the death penalty. However, he usually followed where his doctrine would take him, leading him to write many liberal opinions.

Fiction is also on the New Book List. See, for example, The Advocate’s Daughter: A Thriller (Call No. PS3606.R4228 A67 2016) by Anthony J. Franze who tells a story of family, power, loss, and revenge set within the insular world of  Washington, D.C. The story focuses on Sean Serrat, a Supreme Court lawyer on the short list to be nominated to the U.S. Supreme Court. His daughter, Abby, a talented and dedicated law student, goes missing and her lifeless body is found in the library of the Supreme Court. Her boyfriend, Malik Montgomery, a law clerk at the high court, is immediately arrested. The media frenzy leads to allegations that Malik’s arrest was racially motivated, sparking a national controversy. While the Serrat family works through their grief, Sean begins to suspect the authorities arrested the wrong person. Delving into the mysteries of his daughter’s last days, Sean stumbles over secrets within his own family as well as the lies of some of the most powerful people in the country. People will stop at nothing to ensure that Sean never exposes the truth.

 

Episode 100 – Conversation with BLS Prof David Reiss

Episode 100 – Conversation with BLS Professor David Reiss.mp3

This conversation with Brooklyn Law School Professor David Reiss focuses on his recent article Gorsuch, CFPB and Future of the Administrative State. Prof. Reiss talks about the impact that U.S. Supreme Court nominee Judge Neil Gorsuch would have on the future of administrative law and, in particular, on federal consumer protection enforcement if he is confirmed. Prof. Reiss reviews the case PHH v. Consumer Financial Protection Bureau which the United States Court of Appeals, District of Columbia Circuit decided last year. It is likely the case will be appealed to the Supreme Court. If so, Justice Gorsuch may vote to curtail the independence of the Consumer Financial Protection Bureau and limit its enforcement powers. More generally, Prof. Reiss believes that, given previous rulings by Judge Gorsuch in cases dealing with administrative law, a Justice Gorsuch will be a skeptic of agency action and will support greater judicial review of agency actions.

Service Pets, the ADA and the Supreme Court

On Monday, October 31, the Supreme Court will hear oral argument in Fry v. Napoleon Community Schools, an appeal by a 12-year-old Michigan girl with cerebral palsy who was not allowed to bring her service dog to school. The Court will consider whether Ehlena Fry’s family can sue the school district for violations of federal disability laws. Fry’s family obtained a goldendoodle, Wonder, to help her open doors and retrieve items. Her school district initially refused to allow Wonder at school. Officials relented a bit in 2010, but they placed many restrictions on Wonder. Ehlena and her dog later transferred to another school.

The family sued the school district in the US District Court for the Eastern District of Michigan for violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act. In January 2014, the court in EF ex rel. Fry v. Napoleon Community Schools, 2014 WL 106624 (subscription required) granted the defendant’s motion to dismiss the complaint ruling that the plaintiffs first had to seek an administrative hearing. In June 2015, the 6th Circuit Court of Appeals in Fry v. Napoleon Community Schools, 788 F. 3d 622 upheld that decision 2-1. The American Civil Liberties Union is representing the family. School districts around the country have repeatedly denied children with disabilities their right to bring service dogs to school often claiming the service animals are not necessary and that the schools can help the children through other means. The ACLU wants the justices to declare that children prevented from using service animals at school can proceed directly to court without having to go through administrative hearings that can be costly, time consuming and burdensome. The ACLU Petition for Certiorari is available here.  See also Ehlena and Wonder the Service Dog’s Incredible Journey to the Supreme Court and the video that the ACLU posted about her.

The school argues that exhausting administrative remedies encourages parents and schools to work together to determine the best plan for each child and are a cheaper way to resolve educational disputes. The Obama administration has backed the Fry family, saying the appeals court’s decision was wrong and “leads to unsound results.” The government said when the lawsuit was filed, Ehlena had already moved to a new school district and there was no ongoing dispute to compromise. Requiring her to go through administrative proceedings “would waste time and resources without offering any chance of resolving their actual dispute,” the Justice Department said in a brief to the court.

On the subject of service pets, SARA, the Brooklyn Law School Library catalog links to an online resource by the Office of the New York State Attorney General Civil Rights Bureau titled Freedom on Four Legs: Service Animals, Individuals with Disabilities, and the Law.

Miranda v. Arizona: Fifty Years Later

ernestomiranda640On June 13, 1966 the United States Supreme Court handed down the decision in Ernesto Miranda v. the State of Arizona, 384 U.S. 436 (1966). This case was actually consolidated with three others: Westover v. United States, Vignera v. State of New York and California v. Stewart, however, this case has become known to be simply Miranda v. Arizona.

Ernesto Miranda was arrested in Phoenix, Arizona in March 1963 based on circumstantial evidence linking him to the kidnapping and rape of an eighteen year old woman named Mary Adams ten days prior to his actual arrest.  At the police station, after hours of interrogation, he signed a confession. During the interrogation Miranda was not told of his right to counsel.  During the trial the prosecutor entered his confession as evidence; Miranda’s attorney objected, stating that the confession was not truly voluntary and should be excluded. This objection was overruled and Miranda was convicted of rape and kidnapping at trial. The Arizona Supreme Court affirmed the trial court’s decision.

Miranda’s case and three other similar cases were appealed to the United States Supreme Court, with the Court handing down their decision fifty years ago this month.  The Miranda case has become famous because it establishes a defendant’s right to counsel and of the right against self-incrimination.  Judge Earl Warren wrote for the majority, in the 5-4 decision, that these rights were guaranteed by the Fifth and Sixth Amendments to the Constitution.

After the Supreme Court’s decision, the state of Arizona retried Miranda without the confession, but he was convicted on the strength of a witness and sentenced to 20 to 30 years in prison. He served eleven years and died in 1976, after being stabbed in a bar fight.

“Miranda Rights” have come to be known by the public through television shows and movies as the “right to remain silent” and “anything said can and will be used against in a court of law.” Hundreds of law review articles have been written about this case and a defendant’s “Miranda Rights.”  The library also has a number of books about the Miranda case, including the titles listed below:

Miranda: the Story of America’s Right to Remain Silent by Gary Stuart (2004).

The Miranda Debate:  Law, Justice, and Policing by Richard Leo (1998).

The Miranda Ruling: Its, Past, Present, and Future by Lawrence Wrightsman (2010).

Miranda Revisited by Frank Schmalleger (2001).

Oyez Project Gets New Home

supremecourtThe Oyez Project, a free repository of more than 10,000 hours of U.S. Supreme Court oral-argument audio and other court resources, will be getting a new home.

Developed by Prof. Jerry Goldman, Oyez has had its home at the IIT Chicago-Kent College of Law  for over 20 years.  It is a complete and authoritative source for all of the Supreme Court’s audio since the installation of a recording system in October 1955.  Oyez also provides detailed information on every justice throughout history and offers a panoramic tour of the Supreme Court building, including the chambers of several justices.

Prof. Goldman is retiring this month and a new arrangement for the Project has been formed with Cornell University’s Legal Information Institute and Justia.   All of the information of the Oyez Project will not be available at the Legal Information Institute website.

Chief Justice Earl Warren Biography

Today marks 125 years since the birth of Earl Warren, the 14th Chief Justice of the US Supreme Court, in Los Angeles, California. Warren’s tenure on the Court was from 1953 when President Dwight D. Eisenhower nominated him until his retirement in 1969. Earl Warren had enormous impact on the political and legal landscape of twentieth century America. In his long public service, Warren pursued a Progressive vision of ethical and effective government that brought moral integrity to the nation’s public policies, especially in the fields of racial relations, criminal justice, and freedom of marital association. Warren’s path-breaking approach to legal writing and his management of the responsibilities of the Office of Chief Justice encouraged public understanding of and support for the work of the Supreme Court.

A graduate of the University of California at Berkeley, he was elected district attorney of Alameda County in 1925 and continued to be reelected through 1938, when he was elected Attorney General of California. In 1942, Warren ran successfully for Governor of California as a Republican and was reelected in 1946 and 1950. He ran for Vice President of the United States in 1948 on the Republican ticket with Thomas Dewey, who lost to Harry Truman, the Democratic incumbent.

The Warren Court issued a host of notable decisions including decisions holding segregation policies in public schools (Brown v. Board of Education) and anti-miscegenation laws unconstitutional (Loving v. Virginia); ruling that the Constitution protects a general right to privacy (Griswold v. Connecticut); that states are bound by the decisions of the Supreme Court and cannot ignore them (Cooper v. Aaron); that public schools cannot have official prayer (Engel v. Vitale) or mandatory Bible readings (Abington School District v. Schempp); the scope of the doctrine of incorporation in state criminal matters (Mapp v. Ohio, Miranda v. Arizona) was dramatically increased; reading an equal protection clause into the Fifth Amendment (Bolling v. Sharpe); holding that the states may not apportion a chamber of their legislatures in the manner in which the United States Senate is apportioned (Reynolds v. Sims); and holding that the Constitution requires the states to provide defense attorneys to criminal defendants charged with serious offenses (Gideon v. Wainwright).

Warren wasWarren Chair of the Warren Commission on the Assassination of President Kennedy. Serious lapses in judgment and uncritical deference to authority regarding national security issues in the report have clouded his legacy. The Brooklyn Law School Library has in its collection Earl Warren and the Struggle for Justice by Paul Moke (Call # KF8745.W3 M65 2015), a highly readable biography that offers an updated and balanced appraisal of Warren’s leading social justice decisions and a liberal critique of his failings that provides new insights into Warren, the man, the jurist, and the leader.

First Woman Attorney before US Supreme Court

A Presidential Proclamation for Women’s History Month, 2016 states that “we remember the trailblazers of the past, including the women who are not recorded in our history books, and we honor their legacies by carrying forward the valuable lessons learned from the powerful.”

Rebels at the BarTo commemorate Women’s History Month, Brooklyn Law School Associate Librarian Linda Holmes has added some interesting titles in the display case on the first of the library opposite the elevator, including Rebels at the Bar: The Fascinating, Forgotten Stories of America’s First Women Lawyers by Jill Norgren (Call # KF367 .N67 2013). The book recounts the life stories of a small group of nineteenth century women who were among the first female attorneys in the United States. Beginning in the late 1860s, these pioneers, motivated by a love of learning, pursued the radical ambition of entering the then all-male profession of law. They desired recognition as professionals and the ability to earn a good living. One prominent early woman attorney was Belva Lockwood, born in New York State in the Niagara County town of Royalton on October 24, 1830. In 1879, a bill was passed in both houses of Congress and signed by President Rutherford B. Hayes allowing Lockwood to become the first woman to practice before the Supreme Court of the United States. On March 3, 1879, she became the first woman admitted to practice before the United States Supreme Court. One of her first actions was to nominate a black Southern colleague for admissions to the court.

In 1884, Lockwood was nominated for president of the United States by the National Equal Rights Party along with Harriet Stow as the vice presidential candidate. Running against James G. Blaine (Republican) and Grover Cleveland (Democrat) at a time when women were not allowed to vote, she received 4,194 votes. She ran for president again in 1888. Lockwood’s professional life focused on women’s rights and she helped women gain equal property rights and equal guardianship of children. She served as president of the Women’s National Press Association, commissioner of the International Peace Bureau in Berne, president of the White House chapter of the American Woman’s League, a senator for the District of Columbia Federal Women’s Republic, chairman of the committee on industrial police for the National Council for Women, and president of the National Arbitration Society of the District of Columbia. She died on May 19, 1917. In 1983 she was inducted into the National Women’s Hall of Fame and on June 18, 1986, the United States Postal Service issued a memorial stamp. For more on Lockwood, see the entry at the New York State Library at this link.

New Limits on Insider Trading?

A Wall Street Journal article reports that the U.S. Supreme Court has granted a writ of certiorari to review the ruling by Judge Jed Rakoff in the case of Salman v. US, 792 F.3d 1087 (9th Cir. 2015). Judge Rakoff, who usually sits on bench of the Southern District of New York, served as a visiting judge temporarily assigned to the Ninth Circuit and wrote the opinion in Salman, which disagreed with last year’s Second Circuit ruling in US v. Newman, 773 F. 3d 438 (2d Cir. 2014). The Newman decision overturned the insider trading convictions of former hedge-fund traders articulating a narrower definition of the crime. The issue in Salman is what constitutes insider trading in a case involving an Illinois businessman’s appeal of his conviction for making $1.2 million trading on tips about mergers from his brother-in-law, a Citigroup banker. With the grant of certiorari, the Supreme Court may now decide a key question in insider trading cases, namely what benefits corporate insiders need to receive for any information they disclose to traders to be illegal. The Justice Department warned that overturning the convictions in Newman prosecution could hinder the government’s campaign to curb insider trading on Wall Street. The Supreme Court denied certiorari in Newman.

Salman was convicted of 2013 of making investments based on confidential information he received from a family member who worked in the health care investment banking group at Citigroup Global Markets in NY. Co-defendants pleaded guilty in 2011 and were sentenced to probation. Salman was sentenced to 36 months in federal prison and ordered to pay more than $738,000 in restitution. His appeal cites the Second Circuit decision in Newman where the court ruled that prosecutors must prove that a defendant had direct knowledge of the leaker, realize that a breach of fiduciary duty occurred and know that the leaker received a personal benefit in exchange for the information. In Newman, the Second Circuit held that the evidence was insufficient to establish that the tippers received a personal benefit in exchange for the tip. The court also explained that there needed to be “proof of a meaningfully close personal relationship that generates an exchange that is objective, consequential, and represents at least a potential gain of a pecuniary or similarly valuable nature.” In other words,  the relationship should suggest a quid pro quo from the recipient.

InsiderBrooklyn Law School Library has an extensive collection of material on  insider trading, the latest of which is Insider Trading Law and Policy by Stephen Bainbridge (Call # KF1073.I5 B35 2014). The textbook is for use in law school classes on insider trading, securities regulation, or business associations. It offers a clear and direct exposition of the law and policy concerns raised by this important and hcircleigh-profile area of the law. The author provides sufficient detail for a complete understanding of the subject without getting bogged down in minutiae. A second item in the BLS Library collection is  worth reading: Circle of Friends: The Massive Federal Crackdown on Insider Trading—and Why the Markets Always Work Against the Little Guy by Charles Gasparino (Call # HG4928.5 .G38 2013). It is a riveting work of narrative nonfiction, as engrossing and explosive as fictional thrillers of the finest magnitude and should serve as a wake-up call to the investing public.

Supreme Court To Decide If and When RICO Reaches Extraterritorially

On October 1, 2015, the United States Supreme Court granted certiorari to the Second Circuit decision in European Community v. RJR Nabisco, 764 F.3d 129 (2d Cir. 2014). In granting review, the Court will determine whether or not RICO has extraterritorial reach. In examining this issue, the Court may also rule on how to decide whether RICO claims involving multinational parties are domestic ones, and how to determine whether it is an improper or proper extraterritorial claim.

If you would like to learn more about the Racketeer Influenced and Corrupt Organization Act (RICO), check out the library resources below.