To paraphrase the classic Greg Kihn Band tune, "I was in jeopardy, baby, ooh-oh-ooh." Or not. United States v. Mondragon, 2013 WL 6726925 (9thCir. Dec. 23, 2013), decision available here.Players: Decision by Judge Graber, joined by Judges Tashima and Murguia. Facts: After a jury was empaneled Mondragon went to a settlement conference and then plead guilty: he did not object when the district court then declared a mistrial. Id. at *1. Mondragon then successfully moved to rescind his guilty plea. Id. Before the next trial was underway, Mondragon invoked the Double Jeopardy clause and demanded the original jury hear his case. Id. The district court denied the motion to dismiss the superseding indictment. Id.Mondragon filed an interlocutory appeal. Id.at *2. Issue(s): “[The] rule, that a declaration of mistrial at the behest or with the consent of the defendant stands as no obstacle to a new trial, has one ‘narrow exception’; the rule does not apply when the mistrial is caused by the misconduct of the prosecutor or judge and that misconduct is motivated by an intent to . . . subvert the protections afforded by the Double Jeopardy Clause.” Id.at *2 (internal quotations and citations omitted). “Here, Defendant argues that the district court engaged in misconduct because the settlement conference violated Federal Rule of Criminal Procedure 11. He further argues that the misconduct constituted ‘goading’ because the presiding judge intended that the settlement conference result in Defendant’s consent to a mistrial.” Id. at *3. “. . . [T]he relevant inquiry is whether the impropriety was an attempt to prevent the empaneled jury from reaching its verdict.” Id. at *4.Held: “Even if we assume that the district court violated the local settlement rule and Rule 11, we still conclude that the district court’s actions did not constitute ‘goading.’” Id. at *3. “Defendant leaps from the fact that a voluntary settlement conference may result in a plea agreement and a consequent mistrial to the conclusion that the judge necessarily sought to cause a mistrial. There is no support in the law, in logic, or in the record for that leap.” Id. Of Note: After Davila, 133 S. Ct. 2139 (2013), the significance of Mondragon in the context of mid-trial settlement conference is effectively moot: there aren’t any settlement conferences (or if there are, they are few and far between). The broader import or Mondragon is the “coerce to consent to mistrial” branch of the Double Jeopardy analysis. Id. at *2-*4. While it is not a terribly surprising result, Mondragon refuses to grow that branch beyond traditional bases for finding that jeopardy attached. Id. at *3.How to Use: Mondragongives a little primer for when jeopardy doesattach, when the court or prosecutor goads the defense into agreeing to a mistrial. The point of this line of law is to “’prevent[ ] prosecutors from sinking a case they knew was doomed to end in an acquittal in the hope of having better luck before a second jury.’” Id.at *4 (quoting United States v. Perlaza, 439 F.3d 1149, 1173 (9th Cir. 2006)). Examples? “[I]f the prosecutor thinks that the jury will acquit because the government’s star witness performed poorly on cross-examination, the prosecutor’s misconduct aimed at causing a mistrial would bar retrial. Or if a judge who disliked the jury’s racial or professional mix engaged in misconduct in order to seek a different mix in the jury pool, the judge’s misconduct leading to a mistrial would bar retrial.” Id. at *4. For Further Reading: A month or so ago we flagged buzz of a possible amendment to the drug guidelines. See blog here. That buzz became much more real last week, as the Commission sought comments on a proposed amendment that would knock 2 levels off drug guidelines. See press release here. Bring that certain reduction into current negotiations (or brush up on your Speedy Trial exclusions and stall drug cases until the amendments kick in). Finally, negotiate-out § 3582 resentencing waivers! (Or try to: the ability (or inability) to negotiate over § 3582 waivers in plea agreements is a topic of much interest in the ND Cal right now).Image of “Jeopardy” from http://globalstrategygroup.com/wp-content/uploads/2013/08/1280_jeo_alex-738030.jpgSteven Kalar, Federal Public Defender N.D. Cal. Website at www.ndcalfpd.org.
Case o' The Week: Double or Nothing - Mondragon and Double Jeopardy
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Interview: Whitmire on Whitmire
Charles Kuffner has posted a 68-minute interview with Senate Criminal Justice Chairman John Whitmire. Go here to listen to the whole thing. Wrote Kuff, "Sen. Whitmire had a lot to say in the interview, so much so that I hardly had to ask any questions. He just got on a roll and went places that I wouldn’t have known to ask about if I’d been directing things." Whitmire opined on topics from the criminal justice system, adult and juvenile, to the budget, schools, park space, food banks, senate rules, and a variety of other subjects.The Dean of the Texas Senate has a Democratic primary opponent, Damian Lacroix, for the first time in recent memory. Listen to Kuff's interview with him here. Lacroix has blasted Whitmire for his criminal-justice record in terms that frankly were uninformed and disingenuous. I don't always agree with Chairman Whitmire, but he's directly or indirectly responsible for most of Texas' criminal-justice reforms in recent years. Without him, there's zero chance Texas would have closed three prison units over the last two sessions.As Texas' longest serving senator, a committee chairman, and Harris County's only senator on the budget conference committee last session, it'd be nuts for SD15 voters to replace John Whitmire with a rookie at this juncture. Judging from this interview, he appears to be taking the opposition seriously.
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"Kaleidoscopic Chaos: Understanding the Circuit Courts’ Various Interpretations of § 2255's Savings Clause"
The title of this post is the title of this informative and important new piece now available via SSRN and authored by Jennifer Case. Here is the abstract: More than 65 years ago, Congress enacted a short statute (codified at...
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Subpoenas and Social Websites
byJill Paperno, author ofRepresenting the Accused: A Practical Guide to Criminal DefenseThe subject of subpoenas used to obtain records (duces tecum) is one that you can spend a career trying to master, and never quite get there. Among the questions you may have to consider when issuing subpoenas are the following:Can you issue on your own authority or do you have to prepare a judicial subpoena duces tecum?Do you have to give notice to the other side or third parties?Do you have to file a motion?Are there specific laws that govern the type of records you are seeking - medical, mental health, Child Protective, etc.?Is there specific language that must be used or a specific showing in your application or motion?Is an order required in addition to the subpoena?Can you apply ex parte so as not to alert your opponent to the defense theory?If the material is considered discoverable, can you get it by subpoena?Does the prosecutor have standing to object? (Just because they have notice doesn't mean they have standing.)Where must the materials be sent? Are they properly certified so the records will be admissible if necessary?If the prosecutor is trying to subpoena records, in addition to some of the above, there are other issues to consider when trying to prevent issuance of subpoenas:Do they have the authority to get those records?Must they be on court order?Does the defense get notice?Does the defendant have standing to object?Does compliance with a prosecutor's subpoena for your client's records violate a privilege?The answers to these questions will vary from jurisdiction to jurisdiction, but there are some areas that we must all become familiar with no matter where we practice. One increasingly important area is social media content and metadata. How many times have we wanted to obtain and introduce the Facebook posts of a complaining witness, or prayed the prosecutor wouldn't see our clients' pages, replete with photos of weed and guns?If our clients' Facebook entries and Twitter tweets are communications between family and friends, isn't there a Fourth Amendment privacy issue? The following is a (non-exhaustive by any means) discussion of this burgeoning area of law. My familiarity with this area of law is about a week old, so if you find errors or have suggestions, please add them in the Facebook comments.There is a federal statute, the Stored Communications Act (SCA), that governs disclosure of social media information. Based on this law, these companies will not comply with non-judicial subpoenas for certain social media information. We must become familiar with it, both to obtain records and to oppose the disclosure of our clients' records. The law distinguishes between newer and older communications, and whether the material sought is content, or the information relating to times, dates, recipients, etc. (metadata). (Although we easily understand the importance of content, metadata can be very informative too. For an interesting short lecture on the significance of metadata, see "The Power of Metadata", a Ted talk that can be found on youtube.)The SCA, 18 U.S. Code Sections 2701 et. seq., governs disclosure by providers of communication services to the public. For an in-depth discussion of its history and interpretation, see "Discovering Facebook: Social Network Subpoenas and the Stored Communications Act", Harvard Journal of Law & Technology, Volume 24, Number 2 Spring 2011. http://jolt.law.harvard.edu/articles/pdf/v24/24HarvJLTech563.pdfSection 2703 addresses disclosure of information through subpoenas and search warrants. This statute was written years ago, well before social media became commonplace. So its application has required courts to interpret and reinterpret the law. The statute distinguishes between information held on an RCS (Remote Computing Service) and ECS (Electronic Communication Services) - RCS's being entities that store information and ECS's being entities that provide services that enable communication. Some providers may be considered both.Seeking recordsSection 2703(f) requires that an entity that is subject to this law must preserve information upon request of a governmental entity. The statute (Section 2711) defines governmental entity as "a department or agency of the United States or any State or political subdivision thereof." Does this mean defense counsel cannot obtain the records? Maybe we can get a court to order the prosecution to subpoena. But more often, we will have to go after it. As defense counsel, we will have to raise the arguments we raise when seeking other records protected by statute, that the constitutional rights trump statutory protections. (See, e.g., Davis v. Alaska, 415 U.S. 308 and Pennsylvania v. Ritchie 480 U.S 39.) In the George Zimmermann prosecution, the trial judge granted defense subpoenas for social media records of Trayvon Martin and his girlfriend. So it can be done.In U.S. v. Zhuta, 2011 WL 1330855 (W.D.N.Y.), 2 (W.D.N.Y.,2011) Magistrate Judge Hugh Scott denied defendant's numerous subpoenas, including social media subpoenas, without prejudice and without reference to the SCA, instead considering constitutional grounds. But the case did not squarely address a defendant's rights to the material. We will have an uphill battle as we litigate these cases. We will have to urge courts to find that our clients' constitutional rights to Due Process, Fair Trial, Confrontation and Compulsory Process under the U.S. Constitution (and your state's parallel state constitutional rights) mandate disclosure.In "Social Media Evidence in Criminal Proceedings - An Uncertain Frontier", at http://about.bloomberglaw.com/practitioner-contributions/social-media-evidence-in-criminal-proceedings-an-uncertain-frontier-by-justin-p-murphy-and-adrian-fontecilla/, Justin Murphy and Adrian Fontecilla highlight the issues and arguments we will be facing and making.For some suggestions on how to obtain records by request, (remember metadata?), take a look at "Obtaining Records From Social Networking Websites", http://www.msba.org/sec_comm/sections/solo/docs/ObtainingRecordsFromSocialNetworkingWebsites.pdf.Opposing subpoenasIn Crispin v. Audigier a California District Court, citing two other federal court decisions, found the party whose records were sought had standing to contest the subpoenas. At least two district courts have concluded that individuals have standing to move to quash a subpoena seeking personal information protected by the SCA. In J.T. Shannon Lumber Co., Inc. v. Gilco Limber, Inc., Civil Action No. 2:07–CV–119, 2008 WL 3833216 (N.D.Miss. Aug. 14, 2008), the district court found that “because the documents sought by the plaintiff are the personal documents and the details of the email accounts of the defendant employees, the defendants have standing to seek to quash this subpoena as they have a personal interest in the documents sought from the internet service provider.” Id. at *1. The court finds J.T. Shannon Lumber persuasive. Specifically, it concludes that an individual has a personal right in information in his or her profile and inbox on a social networking site and his or her webmail inbox in the same way that an individual has a personal right in employment and bank records. Crispin v. Christian Audigier, Inc., 717 F.Supp.2d 965, 974 (C.D.Cal.,2010)Other courts have ruled there is no third party standing. See, e.g. People v. Harris, 36 Misc. 3d 868.Interestingly, the SCA does provide a basis for opposing subpoenas related to your client. If you learn of the subpoena and have standing - another question addressed by some courts - you can argue the prosecution has not made the proper application requiring factual assertions and the assertions do not meet the legal standard for disclosure under the statute:(d) Requirements for Court Order.—A court order for disclosure under subsection (b) or (c) may be issued by any court that is a court of competent jurisdiction and shall issue only if the governmental entity offers specific and articulable facts showing that there are reasonable grounds to believe that the contents of a wire or electronic communication, or the records or other information sought, are relevant and material to an ongoing criminal investigation. In the case of a State governmental authority, such a court order shall not issue if prohibited by the law of such State. A court issuing an order pursuant to this section, on a motion made promptly by the service provider, may quash or modify such order, if the information or records requested are unusually voluminous in nature or compliance with such order otherwise would cause an undue burden on such provider.Additionally, the Sixth Circuit in U.S. V. Warshack 631 F.3d 266 held that despite the SCA, defendant Warshack had a reasonable expectation of privacy protected by the Fourth Amendment, and the release of emails pursuant to the SCA without a warrant based on probable cause violated the defendant's Fourth Amendment rights (though the Court found that the police had a good faith basis to believe the search was lawful).Other challenges may involve arguing a provider is not covered by the definition of the statute, and therefore issuance of subpoenas or search warrants pursuant to the statute was unlawful, and evidence obtained should be suppressed. For a review of these (unsuccessful) efforts in one case, see U.S. V. Orisakwe, 2013 WL 4836084.
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Publicity Over Stamford Public School Violence Prompts Concern Among Local Parents
Last week the Stamford Advocate reported that several public high school principals will sit down with city officials to discuss the recent string of school violence arrests in the Stamford public high schools. These arrests—which stemmed from fights and bullying episodes at Stamford High School, Westhill High School and Stamford Academy—have caused concern among Stamford parents, […]
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Our Thoughts on Colorado Legalizing Small Quantities of Marijuana for Recreational Use (video)
Copyrighted Material by The Pate Law Firmhttps://www.youtube.com/watch?v=RYHUwD7vU_4 TRANSCRIPT – My name is Page Pate, and I’m a lawyer who practices Constitutional Law and Criminal Defense in Federal Court. A lot of people have asked me recently what I think...Read More »
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Father Pays His Child Support, But Still Jailed for Six Months
Texas father Clifford Hall has a great relationship with his 11-year-old son. He pays child support and sees his son regularly. So what’s the problem? In November 2013 Mr. Hall was in court where his ex-wife’s lawyer confirmed there were no arrears of child support. Fast forward to January 2014, when he reappeared in court […]
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People v. Romano
People v. Romano
Court Discusses Whether a Defendant can be Convicted on a Defective Information
The defendant, in an information was charged with Attempted Criminal Contempt in Second Degree and Aggravated Harassment. The alleged crimes were in violation of a protection order regarding a domestic dispute involving the defendant and the mother of his child, who was the complainant. The defendant requested the dismissal of the charge of Attempted Criminal Contempt in the Second Degree. The defendant contended that the charge was flawed within the meaning of the Criminal Procedure Law (100.15) as a vital component of the crime was not fulfilled.
The Penal Law (§ 215.50(3) for DUI provides the vital components of Criminal Contempt in the Second Degree where it states that a person must intentionally disobey or resist a legal process or a court order except where there is labor dispute as defined in section 753(a) of the Judiciary Law. The term labor dispute refers to disagreement regarding the terms or conditions of employment, or concerning the association or representation of persons in fixing, maintaining, negotiating, changing or in search of arranging terms or conditions of employment, or regarding employment relations, or any other disagreement involving the individual interests of employer and employee, regardless of whether or not the disputants stand in the relation of employer and employee. According to the defendant, neither the accusatory section nor the factual part of the information alleged that this case did not concern or develop from a labor dispute, a crucial element of the offense that the prosecution was obligated to plead and prove. Where legislation defines a crime that comprises of an exception, the exception would be included in the element of the offense; but when the exception is created in separate legislation, the defendant has the responsibility of raising the exception in his defense, either by favorable defense or under the general issue. Statutory exception for cases that developed from a labor disputes was a part of crime of Criminal Contempt in Second-Degree, and thus count of accusatory instrument that charged the defendant with Criminal contempt in Second Degree for disobeying protective order in favor of child's mother, without indicating whether case was result of labor dispute, was facially insufficient. DWAI was not involved.
The definition of a labor dispute is board and it was arguable that the relevant section of the Judiciary Law covered household members working in a business. However, this argument was flowed as the legislature could not have intended the section to be applied to prevent abuse from a family member. The legislative history of the statute and the literal interpretation of statute showed that the labor law language is a component of the crime. However, a dismissal of the criminal contempt count was inappropriate as there could be an amendment. The Criminal Procedure Law provides for the amendment to an information or a count where there is a defect or irregularity that can be cured. Since the defective information was curable, the court ordered that the defendant's motion to dismiss the charge of Criminal Contempt, not DWI, in the Second Degree is stayed for 15 days. Provided that the District Attorney amended the information, then the motion to dismiss the information would be denied. Where there was a failure to amend or supersede the information within 15 days of the decision then the defendant’s motion would be granted.
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Top-Ten Recent SSRN Downloads
in criminal law and procedure ejournals are here. The usual disclaimers apply. RankDownloadsPaper Title 1 205 The Mens Rea of Accomplice Liability: Supporting Intentions Sherif Girgis, Princeton University Department of Philosophy, Date posted to database: November 4, 2013 [3rd last...
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An American Horror Love Story
The following was sent to us via the CONTACT form and posted with the users permission.
NOTE: If you have read the book then please leave a review on Amazon.com.
By Anthony Jones:
(Amazon.com | Download from Scribd.com) A true story of two teen lovers who were both sex offenders who were being stalked by a deranged vigilante who was tracking their whereabouts off of their profiles on the Megan’s law public web site and terrorizing them!
The parents of the teens fearing for their children’s...
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The judge did not mention any particular potential conditions of probation....cont
Similarly, we have held that "a SORA risk-level determination is not part of a defendant's sentence it is a collateral consequence of a conviction for a sex crimes offense designed not to punish, but rather to protect the public....
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When Is a Weapon Considered a "Deadly Weapon"?
Lawyers play games with words, it's in the job description. Don't hate the player, hate the game. Sure, we lawyers are easy targets for any number of legitimate complaints, but it becomes about as tiresome as hearing new comedians telling dick jokes for 30 minutes. Yes, I've seen plenty of stand-up comics grab their crotch, and I'm even tired of women comics doing it (I admit, it was funny for a little while to see the ladies join in the fun, but they all owe Joan Rivers a royalty for paving the way for crude lady humor).
So, getting back to my first sentence, "games with words". The reason we lawyers play word games is because the legislature writes crappy vague laws. Now, without vague laws, attorneys would have less to argue about--and hence, make less money. So, the ambiguity found in our laws is just fine with me. But, it's annoying when prosecutors use this vagueness to enhance criminal charges. So, let's talk about the term "deadly weapon". The term is used to transform a variety of misdemeanors into felonies. To an intellectually lazy prosecutor, this term could mean just about anything. Today we're going to examine a misdemeanor assault case which was upgraded to a felony aggravated assault with a deadly weapon.
In J.P. v. State, 2013 Fla. App. LEXIS 10095 (Fla. 3rd DCA 2013), J.P. appealed his conviction for aggravated assault with a deadly weapon. At trial, testimony revealed that J.P. was throwing rocks at the alleged victim. Now, you may be asking yourself, not all rocks are created equal, right? I mean, if J.P. was throwing rocks off a bridge on the turnpike into oncoming traffic that could get him a felony, right? Well, probably. But, J.P. was simply "tossing [rocks] softly with one hand", and the rocks were "quarter-sized". Id. Accordingly, issue on appeal revolved around whether or not quarter sized rocks softly thrown constitute deadly weapons. Yes, leave it to the mind of a prosecutor to think that such small rocks constitute a "deadly weapon".
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Manhattan Psychiatric ...cont
On 10 December 2007, the court held a probable cause hearing related to K.A., who is now being held at Manhattan Psychiatric. At the outset, the State proffered two certificates of conviction, which were received into evidence without objection....
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North Carolina Bank To Pay $1.2 Million Penalty For Role in Ponzi Scheme, Payday Loans
A North Carolina bank will pay a $1.2 million fine after authorities accused it of failing to maintain proper controls to prevent a payday lender and massive Ponzi scheme from defrauding thousands of customers. Four Oaks Fincorp, Inc., and Four Oaks Bank & Trust Company (“Four Oaks Bank” or the “Bank”), agreed to pay the penalty in connection with civl charges unveiled by the Department of Justice, which accused the bank of violations of the Anti-Fraud Injunction Act and the Financial Institutions Reform, Recovery and Enforcement Act ("FIRREA"). In addition to the fine, the Bank, which neither admitted nor denied wrongdoing, agreed to assist authorities in any ensuing criminal investigations.
According to authorities, Four Oaks Bank began a relationship with a privately-owned Texas third-party payment processor the ("3rd Party Processor") in 2009. As part of the relationship, the Bank gave the 3rd Party Processor direct access to the Federal Reserve Bank in Atlanta, which allowed the 3rd Party Processor to directly submit Automated Clearinghouse ("ACH") requests for payment to the Federal Reserve. This differed from the typical scenario where the Bank would serve as the intermediary between the 3rd Party Processor and the Federal Reserve, allowing the Bank to employ a variety of controls to ensure that the transactions are not suspicious or potentially fraudulent. Indeed, these controls are required under the Bank Secrecy Act to ensure that the Bank has a customer identification program ("CIP") that sufficiently allows the Bank to verify the identity of each customer. By providing the 3rd Party Processor direct access to the Federal Reserve, the DOJ alleged that the Bank failed to satisfy its "know-your-customer" obligations.
Under the arrangement with the Bank, the 3rd Party Processor was able to originate nearly 10 million ACH transactions on behalf of its merchants for a total dollar value of nearly $2.5 billion. This resulted in the generation of nearly $1 million of fees for the Bank. While the majority of ACH transactions were connected to the 3rd Party Processor's relationship with various payday lenders, authorities also discovered that, in Spring 2012, 3rd Party Processor began allowing direct ACH access to a client named Rex Venture Group, LLC ("RVG"). RVG was the parent company of ZeekRewards, a massive Ponzi scheme that was shut down in August 2012 and which is estimated to have caused over $500 million in losses. According to authorities, the Bank allowed direct ACH access to RVG despite the inability to verify (1) the identity of RVG's principals; and (2) the nature of RVG's business. As a result, RVG was able to use the Bank to raise more than $60 million in just a short span before the Ponzi scheme was discovered.
The settlement comes as authorities are increasingly scrutinizing the compliance of banking institutions with federal laws. These laws, including federal anti-money laundering statutes, require banks to institute sufficient controls to identify and report suspicious activity to authorities. The settlement by Four Oaks Bank comes days after financial juggernaut JP Morgan Chase agreed to a record-$2.6 billion fine for its role in the massive Ponzi scheme perpetrated by Bernard Madoff. Other recent and notable settlements by high-profile banks include a $55 million fine by American Express Bank, a $1.256 billion fine by HSBC, and a $160 million fine by Wells Fargo/Wachovia. Such cases make it clear that authorities are devoting increasing resources to policing banks, and it appears certain that the Bank's settlement is indicative of additional action.
A copy of the DOJ's complaint is below (thanks to ASDUpdates):
Doc 1 (1)
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Drugs Seized in Traffic Stop Near American Falls
IDAHO STATE POLICE NEWS RELEASE - generated by our News Release ListServer
DO NOT REPLY
---------------------------------------------------------------------------
Idaho State Police
District 5 5205 South 5th Ave.
Pocatello, Idaho 83204-2299
(208) 236-6466 FAX: (208) 236-6068
For Immediate Release: 01/12/14 18:56
Please direct questions to the District Office
On Sunday, January 12th, 2014, at approximately 11:07 am, Idaho State Police conducted a traffic stop on a 2005 Chrysler Town and Country on Interstate 86 near milepost 30, near American Falls in Power County, Idaho. The vehicle was traveling east and was stopped for a traffic violation. The driver was identified as 35 year old male Daniel Sewell, from New Rockford, ND. The passenger was identified as 30 year-old male Timothy Scott, from Fargo, ND. Pursuant to the traffic stop, 14.6 pounds of suspected marijuana was found and seized, Schedule 2 narcotics was found and seized, drug paraphernalia was found and seized, and two handguns were seized. Sewell and Scott were incarcerated in the Power County Jail where they are being charged with trafficking a controlled substance, felony possession of marijuana, felony possession of a controlled substance, unlawful possession of firearms, and possession of drug paraphernalia.
Spot what you think might be an impaired driver? Use the Idaho State Police REDDI (Report Every Drunk Driver Immediately) hotline. Dial *477 from your cell phone anywhere in Idaho.
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SEC Charges Diamond Foods and Former Executives with Accounting Fraud
Earlier this week, the SEC charged Diamond Foods, a San Francisco-based company known for selling nuts, and two of its former executives, CEO Michael Mendes and CFO Steven Neil, with alleged accounting fraud in violation of the federal securities laws. In a suit filed in the United States District Court for the Northern District of California, the SEC claims that to meet quarterly earnings-per-share targets in 2010 and 2011, Neil led Diamond to misrepresent the cost of walnuts in certain financial statements. When Diamond corrected its statements in 2012, its stock price fell from a 2011 high of over $90 per share to $17...
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Sunday Night TV and Open Thread
The Golden Globes: Breaking Bad wins Best TV Drama, Bryan Cranston wins Best Actor. In a surprise win, Robin Wright wins Best Actress for House of Cards over Julianna Margolies for Good Wife. Jared Leto won Best Supporting Actor in a movie (Dallas...
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Book Review: The Spark, by John Kenny
Action, intrigue, and romance are the only words to describe The Spark, a novel by John Kenny. As a firefighter for 25 years, Kenny uses his expertise to create an exciting look into the life of a firefighter, as well as a thrilling detective story. After an action-packed first scene, The Spark starts off more slowly, [...]
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Inequality in the Workplace and Beyond
Michael J. Zimmer, Inequality, Individualized Risk, and Insecurity, 2013 Wis. L. Rev. 1 (2013).Joseph SeinerIn his paper, which was presented as the Thomas E. Fairchild Lecture at the University of Wisconsin Law School, Professor Michael Zimmer does a superb job of explaining how employment has factored into the economic inequality that is so prevalent in our society. Professor Zimmer explains how the middle class is quickly disappearing from the workplace, and how economic mobility is quickly on the decline. [...]
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What's Up in the 8th
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