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Phonetele, 664 F.2d at 727 n.31. 63. Id. at 728. 64. See sources cited supra note 6. 65. See Chubbuck, supra note 6, at 161; Kahn, supra note
Younger says it is “nonsense” to characterize it as an “indictment” of people he calls “nonlawyers.” Younger, supra note 24, at 287 n.154. Instead
prefer to work less–or more). 19. See French, supra note 10, at 397 n.2. 20. Gopi Shah Goda, John B. Shoven & Sita Nataraj Slavov, A Tax on Work for
creation’”); Sunstein, supra note 19, at 1839 n.3 (noting that “the so-called independent agencies are not subject to OIRA review”). In this context
with injured parties. See, e.g., Immigration & Naturalization Serv. v. Chadha, 462 U.S. 919, 927 & n.3 (1983) (noting Congress’s lack of attention when
believe that ultimately the doctrine should be Constitution, N.Y. REV. BOOKS, Feb. 23, 2006, at 25, 25-27 (“[A]n extraordinarily full, rich, and
e.g., In re Guzman-Gomez, 24 I. & N. Dec. 824, 826 n.3 (B.I.A. May 8, 2009) (“We have no occasion to opine as to the merits of [Scales and Solis
al., supra note 1, at 1714, 1747 n.247. 56. DANIEL PATRICK MOYNIHAN, U.S. DEP’T OF LAB., THE NEGRO FAMILY: THE CASE FOR NA- TIONAL ACTION 29 (1965
Gallup (June 23, 202… As Hasen has aptly put this point, “n thinking about how to minimize the risk of election sub… Social Media and Democracy: The
3d 248, 251-52 & 252 n.8 (3d Cir. 2005). 15. See, e.g., Stoll v. Runyon, 165 F.3d 1238, 1242 (9th Cir. 1999). 16. Cada v. Baxter Healthcare Corp