Where are they now? Supreme Court clerks, OT 2006

Following up on posts on a ten-year retrospective on the Supreme Court clerks from October Term 2003, October Term 2004, and October Term 2005, here's what the clerks from October Term 2006 are doing. This list is probably unreliable and has not been fact-checked in any way, except for the links provided (and these links often aren't the best source material).

Chief Justice John G. Roberts

Felicia H. Ellsworth (Chicago 2005 / Boudin), partner at WilmerHale

George W. Hicks, Jr. (Harvard 2005 / J.R. Brown), partner at Bancroft

Keenan D. Kmiec (Berkeley 2004 / Sentelle / Alito (3d Cir.)), partner at Hunter & Kmiec

Paul J. Nathanson (Harvard 2004 / Silberman / Niemeyer), AUSA, E.D. Va.

 

Justice John Paul Stevens

Nicholas J. Bagley (NYU 2005 / Tatel), professor at Michigan

Chad Golder (Yale 2005 / Garland), AUSA, E.D. Va.

Jamal Greene (Yale 2005 / Calabresi), professor at Columbia

Lauren Sudeall Lucas (Harvard 2005 / Reinhardt), professor at Georgia State

 

Justice Antonin Scalia

Daniel A. Bress (Virginia 2005 / Wilkinson), partner at Kirkland & Ellis

Louis A. Chaiten (Northwestern 1998 / Sutton), partner at Jones Day

Joshua S. Lipshutz (Stanford 2005 / Kozinski), partner at Gibson Dunn

Hashim Mooppan (Harvard 2005 / Luttig), partner at Jones Day

 

Justice Anthony Kennedy

David W. Foster (Harvard 2005 / Kozinski), partner at Skadden

Lisa Marshall Manheim (Yale 2005 / Leval), professor at University of Washington

Eric E. Murphy (Chicago 2005 / Wilkinson), Solicitor General of Ohio

Mark R. Yohalem (Harvard 2005 / Rymer), AUSA, C.D. Cal.

 

Justice David H. Souter

Boris Bershteyn (Yale 2004 / Cabranes), partner at Skadden

David S. Han (Harvard 2005 / Boudin), professor at Pepperdine

Bryan W. Leach (Yale 2005 / Cabranes), CEO at Ibotta

Daniel B. Tenny (Michigan 2005 / Tatel), civil division, appellate, DOJ

 

Justice Clarence Thomas

John D. Adams (Virginia 2003 / Sentelle), partner at McGuireWoods

David A. Bragdon (Virginia 2002 / S. Williams), AUSA, E.D.N.C.

Adam Conrad (Georgia 2005 / Sentelle), partner at King & Spalding

Brandt Leibe (Yale 2005 / Luttig), partner at King & Spalding

 

Justice Ruth Bader Ginsburg

Kate Andrias (Yale 2004 / Reinhardt), professor at Michigan

Scott Hershovitz (Yale 2004 / W. Fletcher), professor at Michigan

Daphna Renan (Yale 2004 / H. Edwards), professor at Harvard

Arun Subramanian (Columbia 2004 / Jacobs / G. Lynch (S.D.N.Y.)), partner at Susman Godfrey

 

Justice Stephen Breyer

Jaren Janghorbani (Columbia 2004 / Jacobs / K. Wood (S.D.N.Y.)), partner at Paul Weiss

Tacy F. Flint (Chicago 2004 / Posner), partner at Sidley

Stephen Shackelford (Harvard 2005 / Boudin), partner at Susman Godfrey

Thiru Vignarajah (Harvard 2005 / Calabresi), Deputy Attorney General of Maryland

 

Justice Samuel Alito

Michael S. Lee (BYU 1997 / Alito (3d Cir.) / Benson (D. Utah)), Senator from Utah

Christopher J. Paolella (Harvard 1999 / Alito (3d Cir.)), partner at Reich & Paolella

Matthew A. Schwartz (Columbia 2003 / Alito (3d Cir.)), partner at Sullivan & Cromwell

Gordon D. Todd (Virginia 2000 / Beam), partner at Sidley

 

Justice Sandra Day O'Connor

Justin Driver (Harvard 2004 / Garland), professor at Chicago

 

A few thoughts:

Law professors continue to flow from a few justices. Nine members of this class went on to be law professors, the same number as last year. Six of those came from two justices, Stevens and Ginsburg. (And it's worth noting that while Ginsburg placed three professors this year, it doesn't match the full four-professor slate from OT 2003!)

More partners, and more boutiques. There were 19 law firm partners this time. Last year, a number were in an "attorney" or "counsel" role, but that doesn't seem to be the case for this class. Additionally, two clerks (Kmiec and Paolella) went on to start their own boutiques.

A Senator! A CEO! That's right, Senator Mike Lee of Utah is the first elected official I've run across in the last several years of doing this. Additionally, Bryan Leach is the CEO of a startup, another first in my review of Supreme Court clerks.

Public interest as government work. Usually, there are a couple clerks in a more policy-oriented public interest position, but this year it's pretty much limited to AUSAs, with an SG and a DAG thrown in for good measure.

Year-over-year LSAT test-takers flat as the new normal continues

Last year, I noted that the reports about the number of LSATs administered is only a partial picture of the present state of the law school admissions cycle. The latest numbers on the June 2016 LSAT are no different.

About 23,000 tests were administered, down 0.8% over last June. But the LSAC reports, circulated via PDF and not available on its website, tell a little more.

First-time test-takers in the United States declined slightly less than this, down 0.6% over last June, or close to the 0.8% overall decline reported in the top-line results. Repeaters were up slightly, 1.4% over last June. The real decline occurred in Canada, which saw a 15.7% drop in first-time test-takers.

For those who anticipated that law school applicants had "bottomed out," it appears that it's more a "new normal," as I've suggested before. The bottoming out does not appear to mean that law schools will experience a new upswing in applicants, a rebound to previous levels. Instead, it reflects another year of a rather flat market. And it's a sign that temporary structural changes instituted at many law schools will need to become more permanent to reflect this reality.

LSAC strikes back with bizarre charge in latest war over LSAT

The Law School Admission Council ("LSAC") administers the Law School Admission Test ("LSAT"). It also administers the admissions service that all law schools use to admit applicants. Recently, it was not very happy that Arizona Law planned on admitting some students using the Graduate Record Examination ("GRE") in lieu of the LSAT. It threatened to expel Arizona from LSAC. A number of law school deans pushed back. And LSAC backed down. But it chose another way of threatening law schools--one with a bizarre line of attack.

A few preliminary matters. It's not obvious to me that the GRE is comparable to the LSAT in predicting law school performance. But as LSAT is an imperfect tool at best, and the GRE may be slightly more imperfect, it may well be better at some schools for a handful of applicants. Indeed, I imagine the correlation between SAT and LSAT is quite high. And there are obvious advantages to using the GRE--it expands the pool of prospective law students to a more generalized pool of students interested in a degree after the bachelor's degree. And, perhaps more cynically, incoming students with a GRE score do not have an LSAT score, which is a significant category used in U.S. News & World Report ("USNWR") rankings. All this aside, I think there's no question schools should be permitted--and should--innovate with admissions criteria.

Further, LSAC has been diluting the value of the LSAT for some time. It reports the highest LSAT score of an applicant rather than the mean of all scores, which is the more accurate measure of success. It has agreed to stop "flagging" accommodated test-takers, whose scores are not as reliable a measure of law school success.

Additionally, schools have already been looking toward other measures beside the LSAT as a basis for admitting students. A few schools offer select programs admit students from their own undergraduate schools with no need of an LSAT score if they've achieved a high enough GPA.

Given all these changes, the LSAT is not a great measure for the quality of an incoming class right now. The median LSAT score is not a great measure of the quality of the class, even though USNWR uses it anyway.

But LSAC has decided otherwise. It used to provide reports about each school's 25th, 50th, and 75th percentile LSAT scores to the ABA. It will no longer do so. It explains, "Given the current uncertainty about the Section's position on the use of admission tests other than the LSAT, and the current or potential use by some law schools of admission tests other than the LSAT, we no longer believe that this goal can be met."

Pause and reflect on these remarks. Recall that, so far, only Arizona Law has overtly expressed a desire to use an alternative test (although others are considering it). Recall, too, the many, many present weaknesses in the LSAT scores, some of which have literally been caused by LSAC itself.

It's something of an absurd statement from LSAC. It reflects not a genuine concern about its data but a preemptive strike against the ABA or any law schools that intend to use any other admissions tests. It also reflects a rather unsophisticated cry against law schools--particularly in the event antitrust claims arose against such an organization that held such a powerful grip on law school admissions.

This is hardly the first bizarre letter from LSAC this cycle, as my colleague Rob Anderson has explained over a 2015 letter concerning the usefulness of LSAT scores.

But I thought I would highlight the disingenuous attack on the use of the GRE. While I'm inclined to agree that the GRE has not been demonstrated to be as predictive, the non-sequitur claiming that this is the one thing that renders LSAT scores at law schools essentially meaningless is, I think, not accurate.

A Trojan Electoral College

The Trojan horse is one of the world's greatest myths. The Greeks, thwarted after many years waging war against Troy, built a horse as a gift and pretended to sail away. But soldiers were hidden inside the horse. When Troy brought the horse into the city, the Greek soldiers slipped out in the middle of the night, opened the gates for the Greek army, and defeated the Trojans.

The horse was not a gift. It looked like a gift. But hidden within it was the undoing of the city of the Troy.

Given recent events surrounding Donald Trump, it might be time for some state Republican parties to consider the Electoral College as their Trojan horse.

(If I had time to polish or thought such wonkiness would be the stuff of an editorial, I might publish this otherwise. But consider how this might work.)

Recently, reports have surfaced wondering how the Republican National Committee might replace Mr. Trump if he declined the nomination (details of the RNC process here). But the prospects of Mr. Trump stepping down are, shall we say, slim.

There is also the safety valve of the Electoral College. I've suggested that state legislatures could simply appoint electors instead of holding a popular vote--that idea hasn't exactly caught on.

Still another option would be to have "faithless" Republican electors (i.e., ostensibly pledged to support Mr. Trump but actually vote in late December for some other candidate)--but this assumes a couple of things. First, it assumes the electors would be "faithless." A report on one likely Georgia elector already presages this idea, but it's far from guaranteed that many, if any, would be "faithless." Second, it assumes those electors are selected in that state! If the Georgia popular vote tilts toward Hillary Clinton, then Mrs. Clinton's slate of electors votes, and there is no opportunity for a "faithless" Georgia elector.

But how are these electors chosen, anyway? As the GOP frets that Mr. Trump has already been chosen by its convention, few recognize that almost every Republican presidential elector has not yet been formally selected.

Today, the selection of presidential electors is usually a pro forma process. Party loyalists are named and invariably cast votes (absent extremely unusual circumstances) for the party's nominee.

That selection almost always occurs at the discretion of the state party. Consider a few state laws on the subject. I mean, let's start with Georgia Official Code 21-2-130:

Candidates may qualify for an election by virtue of:

...

(4) In the case of an election for presidential electors, nomination as prescribed by rules of a political party;

That's right. The Georgia Republican Party, by its own rules, picks its presidential electors.

Or, how about Alabama Code 17-19-2:

(b) . . . Such certificates and petitions must be filed in the office of the Secretary of State no later than the 6th day of September next preceding the day fixed for the election.
(c) Each certificate of nomination and nominating petition must be accompanied by a list of the names and addresses of persons, who shall be qualified voters of this state, equal in number to the number of presidential electors to be chosen.

Again, left to the party to name the electors, with an express date of September 6.

How about New Hampshire Revised Statutes 667-21?

Not earlier than the third Tuesday of September following any primary, and not later than the last Tuesday of October, upon the call of the chairman of the state committee of the party, the nominees of each party for the offices of governor, United States senator, United States representative, [etc.] . . . shall meet in state convention for the purpose of . . . nominating presidential electors.

Left to the party (consisting of nominees for offices in New Hampshire), between late September and late October, to gather together and name electors.

One more. North Carolina General Statutes 163-1(c):

Presidential electors shall not be nominated by primary election; instead, they shall be nominated in a State convention of each political party as defined [another section] unless otherwise provided by the plan of organization of the political party;

A default rule of a party state convention, but may be nominated however else the party chooses.

You can peruse a whole list of these options for more information. But the overwhelming discretion resides in state political parties, and the overwhelming discretion occurs in the next several weeks.

So, suppose you're running one of these parties. Your first concern is your state's slate of electors will not be chosen. What do you do?

You appoint a Trojan slate of electors, of course!

You could choose presidential electors who expressly intend to support another ticket. Say, "Flip the Ticket! Pence-Trump!" (Perhaps on the assumption someone like Trump would resign rather than serve as someone's second-in-command?) Or, see if a pair of party statesmen would support "Romney-McCain." Whatever it might be.

Then, parade out the electors on stage and explain, very clearly to voters in your state, "The ballot says 'Trump-Pence.' View those words as something like hieroglyphics.  They stand for something else--they stand for X-Y. When these men and women gather in late December to vote, they're voting for X-Y. So vote for them, using the code name 'Trump-Pence.'"

Is such a decision legal? Of course, with a few caveats.

First, it's important to explain historically that such Trojan electors do exist! Consider Roger Calero, a Nicaraguan who ran for President on the Socialist Workers Party ticket in 2004 and 2008. He's from Nicaragua--clearly ineligible. His name was still printed on the ballot in several states, however--after all, it's the electors' ultimate choice. And in state that didn't permit his name on the ballot? The party printed James Harris, its 2000 candidate, in the slot for President. But the party assured its voters, "Look, we just can't put this name on the ballot, but know that when you're voting for Harris, you're really voting for Calero, because that's who our electors will vote for in late December."

Second, imagine what would happen if, say, a candidate died the week before the election, after all the ballots are printed. The campaign would go around (a la Mel Carnahan 2000) and assure voters, "When you're voting for A-B, you're actually going to be voting for B-C, because our electors will all now vote for B for President instead of Vice President, and new candidate C for Vice President."

Admittedly, these are cases where the candidate is no longer eligible, or is in agreement with the Trojan electors. This would be a rather novel decision for the electors to stage a rebellion--brought on by party leaders.

But aren't electors required to vote for the candidate on the ticket? In most places, no. Most states do have a pledge electors are required to take, but it is wholly unenforceable. A few states have such rules that try to enforce the pledge, but they may well be an unconstitutional (for another time).

Would this help Mr. Trump's opponent Mrs. Clinton win? Not necessarily. A presidential candidate needs an outright majority of electors. So electors switching their votes from Trump-Pence to Pence-Trump would not help Mrs. Clinton. Indeed, if the concern in some states is that Mr.s Clinton's slate of electors might win, this might be seen as a better way of thwarting her ability to secure a majority!

But what if nobody secures 270 electoral votes? Then the race would be thrown to the House, and the top three vote-getters would be candidates to win.

Would state parties need to agree on the new X-Y ticket? To be most effective? Undoubtedly yes. They could scatter their electoral votes to miscellaneous candidates. But if the parties could (quickly!) agree on a new ticket, it would have much more resounding force with the voters in their state, who would not sense that they were alone. Further, it would increase the likelihood that, in the event no one secured 270 electoral votes, a single third candidate would be presented to the House.

Does this make the election "rigged"? Well, this is completely within the rules of the game. In fact, it's in a sense more consistent with the design of the Electoral College--a group of individuals, more dispassionate, exercising independent judgment in their selection of president. (Less "independent," I suppose, if they're all conspiring months in advance on a preferred candidate!)

But it does undermines the quasi-direct election of the president we've come to expect for decades. And it certainly undermines the political primary process that played out over the last year. Whether the American people are able to recognize such a moral distinction is, I think, beyond my ability to know.

Is the Green Party's vice presidential nominee Ajamu Baraka ineligible for office?

Perhaps you thought the constitutional eligibility concerns for 2016 had reached their end (and you'd no longer have any reason to read my article on the process behind challenges over such disputes), but perhaps they continue....

Jill Stein, the presumptive Green Party nominee, just named her vice presidential running mate--Ajamu Baraka, a Chicago native and human rights activist who now lives in Atlanta.

But quite recently, Mr. Baraka lived in Colombia. A 2015 blog entry on his site describes him as someone who lives in Cali, Colombia. And other media mentions around that time mention him as someone from Colombia.

The eligibility concern relates his residency at that time. (Recall that vice presidents must be not be ineligible for the office of president.) Article II provides among other qualifications that a candidate must be "fourteen Years a resident within the United States."

There is some evidence, but certainly not unanimous, that these fourteen years must be accumulated consecutively prior to securing office. But there is some evidence that the requirement can be met cumulatively, over the total course of one's life prior to securing the office.

Additionally, there is the question of what "resident" means. Does living for a stretch of time in Colombia mean one is no longer a "resident" of the United States? It may well mean something like domicile, and a temporary, even extended, presence in another country would not thwart such residency. (James Ho succinctly summarizes some of these views here.)

In short, there is probably good evidence that Mr. Baraka was a resident fourteen years consecutively, and even if he wasn't, that the Constitution permits such residence to be acquired cumulatively. But in the event one concludes that the Constitution requires consecutive residency and that his time in Colombia broke up that residency, then Mr. Baraka would be ineligible.

That might lead to interesting disputes in the event someone sought to challenge Mr. Baraka to keep him--and half of the Green Party's ticket--off the ballot in states that permitted such challenges. Might--one never knows where such challenges to candidate eligibility may lead.

Fictional Attorney of the Month: Mr. Briggs

Charlotte Brontë's Jane Eyre may not be remembered as a legal thriller, but an attorney does seem to intervene at some of the most crucial moments of the novel. Mr. Briggs is John Eyre's attorney, and John Eyre is Jane's aunt.

He ably handles the estate when Mr. Eyre passes and leaves much to Jane. But it also means he has a curious ability to find out all of the important details of the goings-on surrounding Jane, especially concerning Mr. Rochester.

When Jane prepares to wed Mr. Rochester midway through the novel, Mr. Briggs swiftly arrives to inform her of Mr. Rochester's living wife. In "a sort of official, nasal voice," he read out the details of the wedding. When pressed that it did not prove she was alive (told to produce or go to hell, Mr. Briggs dryly opts for the former option), Mr. Briggs, ever prepared, called forward a witness who, encouraged by Mr. Briggs to have courage and "speak out," described the living wife.

Leave it to the lawyer to arrive well-armed with the facts and law to thwart an otherwise happy marriage.

The Commission on Presidential Debates may have a Gary Johnson problem

The Commission on Presidential Debates has taken control of televised presidential debates over the last twenty years. It is formally a non-partisan organization, but it is in reality a bipartisan organization--its current co-chairs are the former chair of the Republican National Committee and the former press secretary to Democratic president Bill Clinton.

It has long established neutral criteria designed to whittle the candidates who appear in the debate to those who are deemed sufficiently "serious" to merit the debate platform. This caused something of a stir in 1992, with the invitation of independent candidate H. Ross Perot, and the waffling over whether to invite him in 1996.

Recently, the criteria have been more objective than some of the earlier balancing tests--but they are also notoriously challenging for any non-Republican-or-Democrat to achieve. It standards for 2016:

[I]n addition to being Constitutionally eligible, candidates must appear on a sufficient number of state ballots to have a mathematical chance of winning a majority vote in the Electoral College, and have a level of support of at least 15% of the national electorate as determined by five selected national public opinion polling organizations, using the average of those organizations' most recently publicly-reported results at the time of the determination. The polls to be relied upon will be selected based on the quality of the methodology employed, the reputation of the polling organizations and the frequency of the polling conducted. CPD will identify the selected polling organizations well in advance of the time the criteria are applied.

A serious problem is what the "five selected national public opinion poll[s]" may mean. That's because, to my knowledge, the CPD has never disclosed its results in recent years when concluding that the two major party candidates have met the criteria. (Consider the generic boilerplate language before the first debate in 2012 here.)

Enter Gary Johnson, the former Republican governor, briefly a 2012 Republican presidential primary candidate, the 2012 Libertarian presidential nominee, and the 2016 Libertarian presidential nominee. Many have hyped that he could attract significant support given the sheer unpopularity of Donald Trump and Hillary Clinton. But would he attract the 15% level of support needed to participate in the presidential debates?

If I had to guess, I'd say no. But Mr. Johnson is currently polling at 8.5% in four-way polling (along with Green Party presumptive nominee Jill Stein) in the Real Clear Politics average. But some polls are as high as 13%; others as low as 5%. In the event he drifts upward a few points, the sample of "five selected" polls matters significantly.

Additionally, his average is slightly higher in three-way polling matchups, polls that exclude Ms. Stein (in part, I think, because the Green Party is not expected to secure ballot access in all fifty states and the District of Columbia)--8.9% in a recent average. While four-tenths of a point may not seem like much, his polling has been about half a point better on average for some time now in the three-way race over the four-way race. Use the three-way polling, or the four-way polling?

If Mr. Johnson experiences some modest improvement in the polls, then the CPD will have almost entirely subjective discretion to decide whether to include or exclude him--if it were include to include him, sample his best-performing three-way polls; if it were to exclude him, sample his worst-performing four-way polls. It's a problem that may not come to fruition if Mr. Johnson's support hovers where it is right now--and maybe that's what the CPD is hoping for.

The twenty-two (or twenty-three) law reviews you should follow on Twitter (2016)

While you could follow a pretty sizeable list of law reviews I've maintained on Twitter, there are a handful of law reviews that rise above the rest.

Last year, I listed the twenty-two law reviews to follow on Twitter. I've modified the criteria slightly and updated it. I've mentioned that I find Twitter one of the best places to stumble upon scholarship and engage in a first layer of discussion about new ideas.

In my view, it continues to surprise me how challenging it is to find recently journal content. Many journals don't maintain a Twitter feed, much less a decent web site--most lack an RSS, are updated infrequently at best, and often include stock art (because, apparently, law reviews are into stock art?). Given scarce resources that law schools have today, one might expect schools to find ways of maximizing the value from their investments in their journals. (More on this soon.)

Alas, I'll settle for the occasional tweet on the subject. I looked at the flagship law reviews at the 106 law schools with a U.S. News & World Report peer score of 2.2 or higher.  If I found their Twitter accounts, I included them. I then examined how many tweets they had, how many followers they had, and when their last tweet (not a retweet) took place. I then created a benchmark, modified slightly from last year: the law reviews "worth following" are those with at least 200 tweets, at least 200 followers, and at least one tweet (not a retweet or direct reply) in the last 45 days (as of July 1, 2016). I thought that would be a pretty minimal standard for level of engagement and recency of engagement. This 200/200/45 standard reduces the list to 23 accounts worth following (UPDATE: the original list was just 22, but I found one more thanks to Elli Olson):

Harvard Law Review

Yale Law Journal

University of Chicago Law Review

NYU Law Review

California Law Review

Penn Law Review

Michigan Law Review

Northwestern University Law Review

Georgetown Law Journal

UCLA Law Review

George Washington Law Review

Ohio State Law Journal

Iowa Law Review

University of Illinois Law Review

Hastings Law Journal

Washington & Lee Law Review

Connecticut Law Review

Case Western Reserve Law Review

Georgia State University Law Review

Nebraska Law Review

St. Louis University Law Journal

Syracuse Law Review

Michigan State Law Review

It's fairly notable, I think, that a majority of the schools on this list have a top-30 peer reputation score. Indeed, follower count is highly correlated with peer score (0.59)! There is also a high degree of continuity between last year's list and this year's list, showing, I think, that continuity matters for many of these journals' social media presence--and, perhaps, that it's harder for many journals to get anything started with a lasting institutional memory.

Below is the complete list of these journals, with 200/200/45 law reviews highlighted. If you see a journal not listed, tweet me about it @derektmuller.

Peer score Journal Tweets Followers Last tweet (not RT)
4.8 @HarvLRev 850 18900 June 23, 2016
4.8 @YaleLJournal 792 8676 June 23, 2016
4.8 @StanLRev 458 5722 April 29, 2016
4.6 @UChiLRev 349 4666 June 27, 2016
4.6 @ColumLRev 294 3747 October 31, 2015
4.5 @nyulawreview 1415 6390 June 29, 2016
4.5 @CalifLRev 398 2918 May 20, 2016
4.4 @PennLawReview 413 2837 May 21, 2016
4.4 @michlawreview 265 2254 June 21, 2016
4.3 @VirginiaLawRev 42 670 June 1, 2016
4.2 @NULRev 241 1015 June 30, 2016
4.2 @DukeLawJournal 66 1172 June 13, 2016
4.2 @CornellLRev 0 11 n/a
4.1 @GeorgetownLJ 325 1080 June 23, 2016
4.0 @TexasLRev 458 2059 April 28, 2016
3.9 @UCLALawReview 223 2332 June 23, 2016
3.9 Vanderbilt  
3.6 @emorylawjournal 85 211 June 28, 2016
3.5 @MinnesotaLawRev 112 625 June 29, 2016
3.5 Washington (St. Louis)  
3.4 @BULawReview 530 1232 October 19, 2015
3.4 @nclrev 76 160 March 28, 2016
3.4 @NotreDameLawRev 52 532 April 22, 2016
3.4 @SCalLRev 11 108 May 3, 2016
3.4 Wisconsin  
3.3 @GWLawReview 670 710 June 15, 2016
3.3 @OhioStateLJ 627 1486 June 29, 2016
3.3 @IowaLawReview 273 1196 May 16, 2016
3.3 @UCDavisLawRev 166 430 January 29, 2016
3.3 Indiana (Bloomington)  
3.2 @BCLawReview 372 1439 April 4, 2016
3.2 @WashLawReview 126 1175 May 21, 2015
3.2 @AlaLawReview 44 633 March 28, 2016
3.2 @GaLRev 32 411 April 4, 2016
3.2 Irvine  
3.2 William & Mary  
3.1 @fordhamlrev 381 2010 May 2, 2016
3.1 @UIllLRev 259 1202 May 29, 2016
3.1 @HastingsLJ 207 518 June 29, 2016
3.1 @FloridaLawRev 122 306 June 28, 2016
3.1 @arizlrev 32 242 July 1, 2015
3.1 @ArizStLJ 29 10 April 18, 2016
3.1 Colorado  
3.0 @WFULawReview 793 694 April 23, 2016
3.0 @WLU_LawReview 279 225 June 28, 2016
3.0 @TulaneLawReview 40 611 March 6, 2015
3.0 Maryland  
2.9 Florida State  
2.8 @BYULRev 42 103 May 11, 2016
2.8 @UtahLawReview 0 6 n/a
2.7 @ConnLRev 854 1188 May 25, 2016
2.7 @AmULRev 356 935 November 13, 2015
2.7 @geomasonlrev 219 258 February 18, 2016
2.7 @UMLawReview 193 946 June 3, 2016
2.7 @denverlawreview 153 686 April 26, 2016
2.7 @CardozoLRev 118 1079 June 28, 2016
2.7 @ukanlrev 105 528 September 25, 2014
2.7 @OregonLawReview 7 372 April 7, 2015
2.7 Tennessee  
2.6 @CaseWResLRev 821 840 June 23, 2016
2.6 @GSULawReview 646 268 June 29, 2016
2.6 @PeppLawReview 604 751 April 1, 2016
2.6 @TempleLawReview 38 67 May 18, 2016
2.6 @KYLawJournal 17 157 March 20, 2012
2.6 @LLSlawreview 11 25 March 23, 2016
2.6 @MoLawRev 11 42 June 7, 2016
2.6 @Houston_L_Rev 5 35 April 28, 2016
2.6 @PittLawReview 0 15 n/a
2.6 San Diego  
2.6 SMU  
2.5 @NebLRev 253 258 June 23, 2016
2.5 @LUCLawJournal 169 131 May 21, 2014
2.5 Chicago-Kent  
2.5 Hawaii  
2.4 @SCLawReview 541 892 April 14, 2016
2.4 @NevLawJournal 70 145 May 22, 2016
2.4 @RutgersLRev 63 631 April 3, 2015
2.4 @nuljournal 47 346 June 22, 2016
2.4 @RutgersLJ 12 526 May 2, 2014
2.4 @BrookLRev 0 4 n/a
2.4 Baylor  
2.4 Cincinnati  
2.4 Indiana (Indianapolis)  
2.4 Lewis & Clark  
2.4 Oklahoma  
2.4 Richmond  
2.4 Santa Clara  
2.3 @SLULawJournal 639 558 June 7, 2016
2.3 @SyracuseLRev 538 946 June 26, 2016
2.3 @HULawJournal 532 715 November 4, 2015
2.3 @MichStLRev 402 780 June 11, 2016
2.3 @SULawRev 53 91 February 20, 2016
2.3 @VillanovaLawRev 44 150 June 25, 2016
2.3 @SHULawReview 22 203 January 28, 2014
2.3 Marquette  
2.3 New Mexico  
2.2 @arklawrev 165 1839 February 15, 2016
2.2 @MaineLawReview 103 650 December 3, 2015
2.2 @lalawreview 95 910 March 24, 2016
2.2 @MSLawJournal 70 223 April 13, 2016
2.2 @UofL_Law_Review 16 46 March 31, 2016
2.2 @UMKCLawReview 5 91 April 22, 2016
2.2 @WVU_Law_Rev 4 26 Jule 28, 2013
2.2 DePaul  
2.2 Hofstra  
2.2 SUNY (Buffalo)