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2421 C O M M E N T When Stopping the Smuggler Means Repelling the Refugee: International Human Rights Law and the European Union’s Operation
Elements, 27 ABA J. LAB. & EMP. L. 149, 156 & n.55 (2012); Secunda, supra note 355, at 295-97. 357. See Secunda, supra note 355, at 293-94; see also
man-died -of-choke-hold-administered-by-nypd-officer-new-york-city-medical-examiner-140692220 0 [http://perma.cc/2AV5-3TDJ]. The grand jury did not
]. 46. See, e.g., U.S. Steel Corp. v. Multistate Tax Comm’n, 434 U.S. 452, 463 n.12 (1978) (noting that “Benjamin Franklin acknowledged receipt of
congressional map, which effectively gutted the voting power of Black residents in Charleston. Justice Kagan in dissent argued that “n every way, the
U.S.C. § 1596 stated that “n addition to any domestic or extra-territorial jurisdiction otherwise provided by law,” federal courts have jurisdiction
contract breach and found the connection between the interferer’s inducement and the plaintiff’s injury to be too remote. Id. at 1499 n.60 (citations