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that his own opinion rejecting the Commerce Clause justification rendered them irrelevant. See King, 135 S. Ct. at 2486-87, 2494 n.4. Murphy v. Nat’l
Pa. J.L. & Soc. Change 53, 55 n.11 (2015) (collecting examples of such legislation). See Marina Lao, Workers in the “Gig” Economy: The Case for
Mark, Studying the “New” Civil Judges, 2018 Wis. L. Rev. 249, 262-63, 263 n.54 (detailing the challenges judges face when dealing with pro se litigants
”). 54. Cf. Epps & Sitaraman, supra note 11, 159 n.44 (citing opinion pieces by Bruce Ackerman and Er… 54. Cf. Epps & Sitaraman, supra note 11, 159 n.44
Inc., No. 15-05592… Indeed, some courts have taken this tack. See, e.g., L. Luviano v. Multi Cable, Inc., No. 15-05592, 2017 WL 3017195, at 16 n.20
public-rights doctrine have ‘not been entirely consistent.’” Id. (quoting N. Pipeline Constr. Co. v. Marathon Pipe Line Co., 458 U.S. 50, 69 (1982)). It
focused on privacy rights, calling for hearings on the Fourth Amendment Is Not for Sale Act). See Jonathan M. Gaffney, Chris D. Linebaugh & Eric N. Holmes
”); Palmiter, supra note 101, at 884 n.19 (referencing investors’ use of Rule 14a-8 “to reach negotiated agreements with management without formally
228 n.1. In many states, the state bar association has no such authority. Rather, it is the state’s highest court that is empowered to regulate
also Kiobel, 569 U.S. at 124-25 (noting there was n… Id. (citing RJR Nabisco, 579 U.S. at 337); see also Kiobel, 569 U.S. at 124-25 (noting there was