2017 ABA Law Student Division Best Newspaper Award-Winner Law Weekly Wednesday, 21 March 2018 The Newspaper of the School of Law Since 1948 Volume 70, Number 20 “T” is for around north Thapar, grounds Thomas, and Congratulations FREE MEEK to Professor John C. Jeffries, Jr. on his Textualism elevation to Senior Lia-Michelle Keane ‘18 Vice President of Advance- Features Editor Emeritus ment for the University! ANG will cherish the disdain for In the past month, students Justice Kennedy that Profes- at UVa Law have had the op- sor Jeffries instilled in ANG’s portunity to hear remarks heart. ANG will not cherish his from several esteemed mem- comments that ANG “bring[s] bers of the judiciary. At the tremendous disrepute upon end of February, Judge Amul this institution” and “can’t be Thapar, a Judge on the Unit- drinking peach-flavored Bur- ed States Court of Appeals nett’s in class.” for the Sixth Circuit, visited the Law School to share his Thumbs up to thoughts on textualism and the UVa Men’s Bas- to critique former Seventh ketball team. ANG Circuit Judge Richard Pos- knew this team ner’s recent book, The Fed- would make history! eral Judiciary: Strengths and Weaknesses. Addition- Thumbs sideways ally, nearly thirty students, to the utter lack of including myself, made a Rotunda Cake af- trip to Washington, D.C., ter our erstwhile over spring break to listen to Deans overhyped its availabil- United States Supreme Court ity in MULTIPLE emails. The Justice Clarence Thomas Meek Mill. Photo courtesy of HypeBeast promise of frosting is the only speak at the Federalist Soci- reason ANG made it through ety’s 2018 National Student Julie Dostal ‘19 tion, a mere thirteen-minute may have alienated some ANG’s Monday afternoon Symposium. Features Editor Emeritus drive from the airport where Super Bowl viewers, but his classes. On the other hand, at his football team’s jet left the imprisonment should collec- least the admitted students Judge Amul Thapar As the eventual Super tarmac.4 Thirty minutes from tively repulse a country that didn’t get any cake! Bowl champion Philadelphia Broad Street where thousands believes in the “justice” part Judge Thapar’s event be- Eagles waited in the tunnel, would play “Dreams and of the criminal justice system. Thumbs down to gan with his admitting that, fans’ ears perked up. It was Nightmares” through phone Following his father’s mur- St. Patrick’s Day on despite their different judi- announced before the game speakers, car radios, or open der at age five, Meek Mill the corner. ANG’s cial philosophies, he agreed that the team would run onto apartment windows.5 Ac- moved with his mother and friends couldn’t find with several of the proposi- the field to a Philadelphia an- companying the music would sister to Berks Street in North ANG amidst all the green- tions in Judge Posner’s book. them.1 The intro dropped. The be chants of “Free Meek!” Philadelphia. Described as clad, hammered undergrads For instance, Judge Thapar relentless beat coupled with #FreeMeek trended on mul- the black sheep of the fam- carousing the Corner at 10 stated that Judge Posner the harsh voice of a 25-year- tiple social media platforms.6 ily, Meek Mill rarely spoke. a.m. ANG is thinking of suing was correct to criticize the old North Philadelphian filled The Eagles won. Fans flocked Only his special affection for the undergrads for stealing untimeliness of opinions is- U.S. Bank Stadium. For those to the streets. The city final- motor vehicles, specifically ANG’s trademark look. sued by courts because, in his not following the Eagles, the ly got a Super Bowl parade. dirt bikes, motivated him to view “justice delayed is jus- song caught them off guard. Robert Williams, known as speech. Instead, he remained Thumbs up to tice denied.” Further, Judge Despite the heavy editing, the Meek Mill, remains in prison. in his room filling journals Taxapalooza on Thapar and Judge Posner last line hung over the stadi- Another victim of a uniquely with words that rhymed, March 30--ANG agree that brevity in opinions um as the camera zoomed in spiteful judge. Another victim eventually developing verse hasn’t filed ANG’s is an essential component for a close up of Tom Brady: of a particularly corrupt nar- after verse for his rap battles.7 taxes in at least seven years in efficiency, particularly at “these ----- want me dead and cotics unit. Another victim of Philadelphia is not a kind and was starting to worry. the circuit court level. Judge I need to make it back home.”2 a system that punishes young city for aspiring MCs. Before ANG was assured that law Thapar suggested that overly Some viewers expressed feel- men for growing up in the Meek Mill, the city boasted school did not involve math. dense opinions increase the ing alienated by the choice of wrong neighborhoods, stand- Will Smith on its list of top likelihood of lower courts such a “violent rap song.”3 ing on the wrong corners, five hip-hop artists. It’s a Thumbs down misinterpreting the mean- For those familiar with but most apparently for be- city so lacking in success sto- to Claire’s filing for ing of the law and that judges this portion of Meek Mill’s ing black. Meek Mill’s words ries, Beanie Sigel tops the list Chapter 11 bank- should focus on emphasizing iconic “Dreams and Night- of rappers achieving main- ruptcy. ANG feels a clear holding. mares,” we continued the 4 “Directions from Chester stream success.8 For those the pain of all the tweens out Turning to where he verse in honor of one of the State Correctional Institution lucky enough to discover there who will no longer be and Judge Posner disagree, most notable Philadelphians to Center City Philadelphia,” Meek Mill on YouTube early able to show off the bodily evi- Judge Thapar stated that not physically present in Google Maps, (last visited in his career, each video was a dence of their weekend mall Judge Posner’s viewpoint ad- Minneapolis. Instead, Rob- 3/14/18). raw, lyrically quick recitation trips. Between this and Toys vances pragmatism over for- ert Rihmeek Williams, AKA of life in North Philly,9 one ‘R’ Us, it seems ANG’s child- malism, which he fears may Meek Mill, was in Chester 5 Keith Caulfield & Kevin of America’s most murder- hood has been completely de- lead judges to decide cases State Correctional Institu- Rutherford, Meek Mill’s Dreams ous localities. Meek had ten valued. based on what he termed the and Nightmares Earned 1.4 Mil- friends die while he lived in imaginary “Emotions Clause” 1 Chris Chavez, Watch Eagles lion Streams on Day After Su- North Philly, and another six Thumbs up to of the Constitution rather Take the Field to Meek Mills perbowl, Billboard, 2/7/2018, or seven while he was on the Snapchat’s value than the text itself. Judge Dreams and Nightmares, Sports https://www.billboard.com/ar- city’s south side.10 Meek Mill’s dropping $800M Posner’s book also argues Illustrated, (2/4/18), https:// ticles/news/8098626/meek-mill- after mocking do- FREE MEEK page 2 that judges should look to the www.si.com/nfl/2018/02/04/ dreams-and-nightmares-streams- mestic violence. ANG may not future rather than precedent philadelphia-eagles-meek-mill- day-after-super-bowl. understand Sec Reg, but ANG in order to reach the best super-bowl-lii-dreams-and-night- 7 Paul Solotaroff, #FreeMeek- knows better than to offend outcome in pending cases. mares-entrance. 6 Deena Zaru, Phildelphia Mill, Rolling Stone, 3/14/2018. Bad Girl Riri/mock domestic Judge Thapar criticized this Eagles Show Solidarity with violence. because doing so would likely 2 Id. Imprisoned Meek Mill Dur- 8 Ryan Beagle, Top 10 Hip have a negative impact on ing Super Bowl Entrance, Cnn, Hop Artists From Philadelphia, Thumbs down to lower court judges. In Judge 3 Warren Tudd Huston, The 2/5/2018; Specific Philadelphia Hip Hop Golden age, (Last vis- Uber’s self-driving Thapar’s opinion, backward- Philadelphia Eagles have An- Eagles have showed continued ited 3/16/18), http://hiphopgold- car killing a pedes- looking interpretations in- nounced the Team Will Run out support for Meek Mill, showing enage.com/list/top-10-hip-hop- trian. ANG thought crease overall efficiency be- onto the Field at Super Bowl LII up at a rally protesting the rap- artists-philadelphia/. ANG had already ridden with cause members of society can to a Highly Controversial rap per’s latest prison sentence. See the worst Uber has to offer rely on precedent to predict song that Critics call Sexist, Rac- Evan Grossman, Eagles Using 9 13 of Meek Mill’s Best and is frankly terrified to learn the legality of their actions. ist, and Violent, Breitbart News, Meek Mill as Their Super Bowl Throwback Freestyles, You- that is not the case. This reliance, in turn, de- (2/4/18), http://www.breitbart. Soundtrack, and the Motivation is tube, (Last visited 3/15/18), creases the need of parties to com/sports/2018/02/04/eagles- Mutual, (1/26/2018), http://www. https://www.youtube.com/ Thumbs up to mac litigate disputes because they pick-super-bowl-song-jailed- nydailynews.com/sports/football/ watch?v=B7_N_CZ_tRo. n’ cheese. No specific rapper-meek-mills-sexist-violent- eagles-meek-mill-motivating-su- reason--ANG just JUDGES page 5 song-dreams-nightmares-intro/. per-bowl-run-article-1.3780914. 10 Solotaroff, supra note 7. wants to thank you. Guest Opinion: Tainted Love 2 Columns VIRGINIA LAW WEEKLY Wednesday, 21 March 2018 Four Machiavellian Reasons To Rescue A Dog There are a lot of dogs out cuing: pretty badly, so now he’s a little is probably most effective when just ralphed on my living room there in need of a decent human Rescues can get away with be- starved for affection.” you get a spur-of-the-moment rug. I better stay home and keep Hutton Marshall ‘19 having terribly all the time. This Rescue growls at the helpless invite somewhere (“Sorry, I’d an eye on her.”). Feel free to be Guest Columnist creative here. Most people don’t know jack about your dog, so it’s to look out for usually a pretty safe excuse. them. The Ameri- Excellent effort-to-love ratio can Society for the When you adopt a rescue dog, Prevention of Cru- chances are that they weren’t elty to Animals in a great situation before their estimates that approximately rescuing (hence the term “rescu- 3.3 million dogs enter U.S. ani- ing”). I know, I know, it’s terrible mal shelters each year.1 Nearly a that Arty spent the first three quarter of them are euthanized years of her life living outside, annually.2 receiving little affection—or even That reality wasn’t on our acknowledgement of her exis- minds when my partner Kelly tence—but, on the flipside, Casa and I decided to adopt our first Hutton is basically her definition pooch, Jocoté, in 2015 when we of paradise because of that. Res- were living down in Costa Rica cuing sets the bar low on my end. (where the reality for homeless I’m basically the second coming dogs is even grimmer). We just of Christ to my dog because I let wanted a good boy to hang out her inside my apartment and with, and a friend pointed us in give her water on the regular. Joco’s direction. The point isn’t that you can Joco passed away last Decem- skate by as a mediocre dog own- ber, but during the last few years, er with rescues. Although even if Kelly and I came to appreciate you’re going to be a pretty me- the dire predicament many dogs diocre dog parent, that’ll prob- spend their entire life enduring. ably be an upgrade from your While losing Joco after just two would-be rescue’s current pre- years with him was a shock, res- dicament, maybe? I don’t know, cuing is a no-brainer for us now. I don’t want to get into all that. Jocoté. Courtesy Hutton Marshall. Earlier this week, we signed the The point is, from an effort-to- official paperwork to adopt our is probably my favorite reason, poodle at the dog park? “Sorry, love to, but I actually have to love standpoint, if you’re going foster Artemis (Arty). if I’m being honest. Rescues she was in a rough situation be- run home and let Arty out.”), to put in X amount of effort as a I’m clearly in the camp that are stereotyped as these crazily fore coming to us.” or when you want to wrap up dog parent regardless of where there are plenty of good reasons damaged creatures—to be sure, Avoid social obligations with an evening early (“Welp, Arty’s they come from, you’re going to rescue, but in case the tradi- many of them have scars from little consequence been cooped up at home for a to get exponentially more love tional benefits haven’t swayed past trauma—but this results in This is more universal to dog while now, so I should go make and affection back from a res- you, here are a few of the more them getting so much leeway in ownership, but having a rescue sure she’s doing okay.”). But it cue. With a puppy who’s never Machiavellian advantages to res- public. is a full-proof get-out-of-[thing can even be used to get out of known hardship, you’re going Rescue urinates indoors you don’t want to go to]-free pre-planned events (“Guys, Arty to be setting that baseline pretty 1 https://www.aspca.org/ani- somewhere? “Sorry, she’s spent card playable at any time.3 This high for them.4 mal-homelessness/shelter-intake- her whole life outside, so we’re son 1, Ep. 3 (Communications RESCUES page 3 and-surrender/pet-statistics still working on house training.” 3 In fact, you don’t really director has an imaginary dog, Rescue jumps up on strang- even need to actually own a a “Bullshitzu,” to evade social 4 General disclaimer that this 2 Id. ers? “Sorry, he was neglected dog to do this. See, Veep, Sea- and professional obligations). article is grounded in baseless FREE MEEK Street.12 Meek insists he was in the ground.17 The police then Mill guilty of seven charges, delphia International Airport a Center City courtroom with lifted his body and, using his four involving the weapon. to attempt to fly through Hur- continued from page 1 a large group of family mem- head as a truncheon, bashed She sentenced Meek Mill to ricane Sandy to make a show bers watching the trial of his in the door of his cousin’s two years in prison and eight in Atlanta, Meek Mill was adolescence coincided with cousin Thelonious. The trial home. The police confiscated years of strict probation.21 pulled over by the police. The an unprecedented rise in vio- lasted from 10 a.m. to 5 p.m. $30,000 from Meek’s cousin’s This was Meek Mill’s first officers stated that his win- lent crimes in Philadelphia.11 Multiple witnesses corrobo- room.18 His cousin dealt mari- conviction. dows were tinted and they His raps are saturated with rate Meek’s whereabouts.13 juana for a living. No crack In the fall of 2009, after smelled marijuana. The offi- this struggle to survive within The Center City courthouse was found in the home.19 almost two years in prison, cers arrested the rapper and the violence of his city. is a minimum thirty-minute As a result of the raid, Meek Mill walked out a free impounded his car. Hours of By 2007, Meek Mill was commute from the location Meek Mill faced nineteen man, a free man very aware searching produced no evi- achieving more mainstream of the alleged crime.14 There counts in the Court of Com- of his eight years of strict pro- dence. After an evening in jail, success. He released a well-re- is no forensic evidence Meek mon Pleas. Roughly a third bation. He went right to work Meek Mill was released with ceived mixtape and hoped to Mill was in court that day. of the charges involved carry- selling mixtapes of songs he no charges. But Judge Brin- sign with fellow rapper T.I.’s Neither is there forensic evi- ing an unlicensed gun. Other wrote in prison with the help kley was so aggravated by the label. Then, the testimony of a dence from the alleged drug charges involved drugs and of new manager Charlie Mack. last-minute changes to Meek’s crooked Philadelphia cop sent bust. Detective Graham either assault. Detective Graham Again, his story may seem travel plans (his involuntary Meek Mill to prison for the failed to lab-test the crack also claimed Meek Mill point- alienating. He suffered an overnight stay in prison), she first time. What follows is a he allegedly seized from the ed his weapon at Graham and injustice—one so common it requested he take a drug test. chronological account of how Jackson Street bust or the lab another officer. Mill waived captivated listeners across the The test came back clean. She the criminal justice system test failed to be transferred his right to a jury trial, due DMV area, catapulting Meek ordered another test. The sec- has not just continued to fail to the court.15 Based on his to the thousands of dollars it Mill to more mainstream pop- ond test also came back clean. Meek Mill, but further how testimony of the purported generates in additional legal ularity.22 In 2011, he signed Yet Judge Brinkley barred Philadelphia police and one drug bust, Detective Graham fees. He claims he barely saw with Rick Ross’s Maybach Meek Mill from touring—a Philadelphia judge exploited received a warrant to search his lawyer before trial; a situ- Music Group. Meek Mill then decision that likely cost him the law—specifically the pa- Meek Mill’s cousin’s home, ation that likely contributed released “Dreams and Night- $6 to $8 million dollars.24 She role system—to continually where Meek spent a majority to the wholly inadequate de- mares,” his debut album, an assigned him a new parole of- imprison an individual typify- of his time.16 fense offered by his attorney. absolutely epic “freshman” ficer, who demanded an hour- ing the type of rehabilitation The following night, of- Meek’s defense lawyer failed effort from such a seasoned by-hour schedule of the rap- allegedly envisioned by the ficers from Philadelphia’s to call witnesses that would MC. Meek Mill ascended to per’s daily life.25 creators of the criminal jus- Narcotics Field Unit arrived contradict Graham’s initial the throne of Philly rap and tice system. at the home. Based on Meek’s timeline of the crack sale. He seemed destined for more na- A more bizarre turn oc- At 4:45pm on January 27, own testimony, he was sit- also failed to question other tional acclaim. “Dreams and curred when both the Judge 2007, Philadelphia Narcotics ting on the front stoop when officers from the day of the Nightmares” peaked as the and Meek Mill’s new parole Field Unit (NFU) detective the officers arrived. He tossed arrest at Meek Mill’s cousin’s number-two album in Ameri- officer, Treas Underwood, Reggie Graham claimed to see the gun he carried for protec- home.20 Judge Genece Brin- ca.23 began praising the rapper’s Meek Mill selling crack to a tion from his person and hit kley acquitted Meek’s co- On his way to the Phila- former manager, Charlie confidential informant on the defendants. She found Meek Mack, during Meek’s subse- corner of Jackson and 22nd 12 Solotaroff, supra note 7. 21 Id. quent court appearances.26 17 “First day I ever felt Meek Mill was managed by 13 Id. safe outside was when I got me 22 Jake Denton, The Crim- Mack during his initial rise to 11 Jon Hurdle, Philadelphia that Sig Sauer.” Id. inal Justice Data Behind Meek popularity from when he was to Quell an Epidemic of Gun 14 “Directions from Center Mill’s Latest Prison Sentence, FREE MEEK page 8 Violence, N.Y. Times, 4/15/2007 City Court of Common Pleas to 18 Id. Pacific Standard, 11/9/2017, (“From 2004 to 2006, the number the Corner of Jackson and 22nd https://psmag.com/social-justice/ 24 Solotraoff, supra note 5. of homicides in the city rose 22 Street,” Google Maps, (last vis- 19 Id. the-criminal-justice-data-behind- percent.”). See also Murder Rates ited 3/14/18). meek-mills-latest-prison-sen- 25 Id. in 50 American Cities, The Econ- 20 Officers on the scene tence. omist, 2/17/2017, https://www. 15 Solotaroff, supra note 7. that day have since signed sworn 26 Id. economist.com/blogs/graphicde- affidavits they never witnessed 23 Caulfield and Ruther- tail/2017/02/daily-chart-3. 16 Id. Meek Mill raise his weapon. Id. ford, supra note 5. Wednesday, 21 March 2018 VIRGINIA LAW WEEKLY Features 3 Murder in Antarctica: Just Asking Questions Over winter break I took recognized their claims. In tories on the original treaty, exploiting Antarctic natural So what happens when a cruise to Antarctica. The that year, twelve countries— representing remarkable co- resources and protected ma- people in Antarctica commit wildlife and natural won- including the seven claim- operation during the heart rine life, but the core of the crimes against each other? Is holders—signed the Antarc- of the Cold War. The Cold treaty has always governed it possible to get away with Eric Hall ‘18 murder in the most remote Editor Emeritus, Jr. Jr. location on Earth? The an- swer appears to depend on ders were life- who you are and what you’re changing. I doing down there. saw glaciers Most people go to Antarc- that engulfed tica on a cruise, like I did. whole mountain ranges, and Therefore, in the most likely icebergs the size of aircraft criminal scenario, a tour- carriers. I waded through ist voyages to the bottom of seas of penguins, tiptoed the world, beyond the reach by snoring elephant seals, of airports or cell towers and photographed a ballet to dispose of an enemy or of breaching blue whales. loved one. This is not recom- In law school, people always mended. If you’re an Ameri- talk about escaping to nature can on board an American to find “perspective.” In Ant- vessel, you generally bring arctica, I took a heavy dose. your criminal laws with you Grades, the bar, even the law as you travel south. In 2010, itself felt vanishingly insig- President Obama signed the nificant while I was down Cruise Vessel Safety and Se- there, like warm breath on a curity Act. The law requires glacier. cruise lines to provide pas- Regrettably, we’re not in sengers a “security guide” school for marine biology that reveals which jurisdic- or environmental science. tion applies on board. The Although I’d love to write law also requires cruise about playful seal pups, and ship personnel to report any calving glaciers, we are law crimes to the FBI immedi- students and this is the Law ately after an incident, and Weekly. Thus, with some ca- provides criminal and civil sual research, I discovered penalties for failure to com- that even at the frozen end If this penguin committed murder, who would prosecute? The answer may surprise you. ply. When I asked him, the of the world, where there are Photo courtesy Eric Hall / Virginia Law Weekly safety officer on board my no courts, police, or politi- tic Treaty which continues to War hints at the original the relationship between ship confirmed (with some cians, there is law. govern land and sea south of treaty’s purpose and scope. people and nature in Ant- suspicion) that he had a There is no government of the 60th southern latitude. Its key stipulation provides arctica. Thus, the primary pair of handcuffs and a jail Antarctica. Argentina, Aus- The treaty guaranteed that that Antarctica will be used source of law below the 60th he could use for such an oc- tralia, Chile, France, New no country would enlarge its for peaceful purposes only, southern latitude offers little casion. Although data on Zealand, Norway, and the claim while it was in effect. and that no military pres- to govern the relationships the incidence of cruise ship United Kingdom each claim Despite having no claims, ence can be installed there. between people and other crimes are scarce, what hap- a slice of it, but since 1961, both the United States and Later amendments prohib- people in Antarctica. the rest of the world has not the Soviet Union were signa- ited member nations from ANTARCTICLE page 5 RESCUES 5. What’s your favorite hob- day. It was really special because I continued from page 2 want to be too obvious about it, HOT continued from page by to avoid the stress of law was named after her, but I never you know? Much to our relief, school? got to meet her. I don’t really be- Moral superiority we quickly realized that there BENCH I’m a major homebody, so I love lieve in superstition, but I call it This one really doesn’t need were myriad opportunities for to just chill out and watch Netflix my lucky ring and freak out a little much explanation, but once you communicating the fact that we to de-stress. I’m currently binging if I don’t have it on whenever I adopt a rescue, you’re really on had a rescue dog, and that the Friends. have something big to do. a different moral playing field implication that we were good than other dog owners. Like I people would naturally follow. 6. Where is your favorite 12. Backstreet Boys or mentioned above, it didn’t even For those hesitant about follow- place to vacation? *NSYNC? occur to Kelly and me that we ing this step: whenever you get Anywhere with a beach! I went Backstreet Boys obviously. were doing anything altruistic asked “Oh, how old is your dog?” on a cruise last year that stopped in They’re iconic. Do people actually Turks and Caicos and I think that pick *NSYNC? takes the cake as far as beaches go. 13. What is the best 7. What did you have for concert you have ever been breakfast this morning? to? Coffee and a banana. I saw Luke Bryan a few years ago, and he was a lot of fun. Nellie Black ‘20 8. What’s your most inter- esting two-truths- and-a- lie? 14. What’s your spirit 1. What are you most ex- (And what’s the lie?) animal? cited for during your first I’ve never left the country, I hate My dog, Princess. summer in Richmond, Vir- peanut butter, and I’m scared of ginia? cats. The lie is that I’ve never left 15. What’s your favor- I’m really excited to explore the country: I left once and went to ite food? the city and learn more about the Ecuador and almost didn’t make it I really love pasta. In case you area. It’s somewhere that I think I back because we missed our flight haven’t noticed by now, I’m not might like to live long term, so I’m and spent twelve hours stranded in really the picture of healthy eat- super excited to get a feel for the the airport. ing. area. 9. If you could live any- 16. If you could be in 2. What is your favorite where, where would it be? the winter Olympics, which word? Somewhere where there is no sport would you compete This is probably so cliché, but I snow and next door to Wegmans. in? love the word reasonable. I passionately hate snow and Artemis. Courtesy Hutton Marshall. 10. What’s your least fa- the cold, so whatever winter when we got Joco for free. Soon, or “What breed is she?” it’s im- 3. Where did you grow up? vorite sound? Olympic sport involves neither however, we learned to embrace portant to never know the an- I grew up in a super small town My alarm in the morning. I’ve of those things. But I’m not very the fact that by doing so, we had swer to these questions. Not only called Ontario in New York. It’s a had to make it this really obnox- athletic, so probably not compet- become better people than many will this make clear to the fellow rural suburb about forty minutes ious noise because I’m paranoid ing at all. of you all. dog owner that you are an al- outside of Rochester, NY (other- I’ll oversleep, and every morning It was at first unclear how to truistic dog-rescuer, but that by wise known as the Ra-cha-cha for when it goes off it gives me a mini 17. What’s your #1 convey our moral superiority to knowing this information about all my Rochesterians out there). heart attack. skill? all those we encountered, espe- their own dog, they have in fact Sounding like I know what the cially at the dog park where our unwittingly outed themselves 4. What’s the best meal 11. What’s the best gift reading meant even when I can’t selfless nature really had the as a morally depraved dog-pur- you’ve ever had? you’ve ever received? actually figure out what the pro- chance to shine. We wanted to chaser. Every Wegmans’ sub I’ve ever For my 16 birthday, my grandma fessor is asking me. make sure people knew we were ---- had. got the diamond from my great- ---- better than them, but didn’t [email protected] grandma’s wedding ring reset into [email protected] a new ring for me that I wear every speculation. 4 Colophon VIRGINIA LAW WEEKLY Wednesday, 21 March 2018 Letters to the Editor She Doesn’t Even Go don’t do well with married, In Defense of Blood gue that the Law School, or of rights when two compet- Here: Clinton’s Speech at white women. Part of that Drives anywhere else, should not ing rights come into conflict Today Conclave 2018 is an identification with the host blood drives at all un- is hardly novel. In this cir- Republican Party and a sort Last week’s opinion col- til this discriminatory prac- cumstance, those competing Raise your hand if you’ve of ongoing pressure to vote umn featured a piece by tice ends. As long as there is rights are the right not to be ever been personally de- the way that your husband, Kyle O’Malley bemoaning a legal obligation for blood discriminated against and monized by Hillary Rodham your boss, your son, who- discriminatory blood dona- drives to abide by the FDA the right to life. Both are im- Clinton. I know it’s not just ever, believes you should.” Taylor guidelines on the subject, portant, but one also weighs (emphasis added). Kordsiemon ‘19 then they should not be heavier on the scale. Pre- Christy Allen ‘19 The hypocrisy of such a hosted even if necessary to venting someone from re- statement by a self-pro- tion polices and “[secure] an adequate blood ceiving lifesaving treatment me. claimed feminist is shock- criticizing the supply.”4 Undeterred, he results in a greater injury In Mrs. Clin- ing. Apparently only Demo- law school for carries the argument to its than facing discrimination ton’s recent cratic women are capable of hosting a blood logical conclusion to suggest at a blood drive. Therefore, trip to Mum- exercising their vote inde- drive while that blood donation current- the proper course is to en- bai, India, she pendently. such policies are in place.1 I ly represents an impermis- courage blood drives and in- gave a speech at Today Con- Perhaps one day Mrs. Clin- agree with O’Malley’s views sible form of discrimination crease blood donation even clave 2018 where she once ton will realize that blaming on blood donation regula- that is “substantively wrong, though it comes at a price. again blamed her loss in the her loss on everyone and tion, but believe that he no matter how important Again, that price is not nec- 2016 Presidential election to their brother (or, literally, takes his argument several [its] ends.”5 essary, and the blood ban Donald Trump on everything their husband, boss, or son) steps too far and reaches a As the father of a son who should end, but it would be save her poor candidacy. is an unattractive look. She rather disturbing conclu- is alive today only because a horrific policy to end blood This time, however, she not is pathologically demeaning sion. As he concluded his of blood transfusions made drives generally until that only insulted those who did to women who disagree with piece with an invitation for available by donors, I find should happen. not vote for her—especially her and the contempt that a discussion on the subject, this conclusion offensive. I hope that the Law School women who did not vote for she continues to rain upon I hope to be able to add a It suggests that it would be will continue the invalu- her—but entire sections of half of America is, quite hon- different viewpoint to the better to have let my son and able service of hosting blood the country. Indeed, accord- estly, pathetic. conversation. other patients die for lack drives in the coming months ing to her estimation, if she Hillary Clinton represents Current FDA regulations of an adequate blood sup- and years while still express- did not win your state, your everything that is wrong with require gay men to have ply than for LGBT people ing support and sympathy state is not “optimistic, di- politics today. That is, if you abstained from sexual in- to suffer the indignity of for our LGBT classmates. It verse, dynamic, [or] moving disagree on an issue (or all of tercourse for at least one witnessing blood drives at would be unfortunate if the forward.” them, as it were with Clinton year to be eligible to donate which they cannot partici- blood drives here ended as She claimed that Trump’s and I), you are a bad person, blood.2 While an improve- pate. While the damage to a result of O’Malley’s criti- “Make America Great Again” an ignorant person, a stupid, ment upon the previous the LGBT community caused cism. Furthermore, I hope message was not only about racist, bigoted, perhaps even lifetime blood donation ban by the blood ban is real, it is that the rising generation of looking “backwards,” but ir- evil person. In her view, the imposed upon gay men, the not comparable to the harm lawyers being educated at responsibly claimed it was states that did not go for her regulation still stigmatizes that would result from effec- the law school will rise to the about not liking “black peo- are not simply composed of and harms the LGBT com- tively eliminating the supply challenge of making public ple getting rights” or women reasonable people who dis- munity with little to no ben- of donated blood to those policy more equal and just “getting jobs.”1 It is incon- agree on policy, but instead efit to public health.3 Had who need transfusions. The for all. ceivable to Mrs. Clinton that of “backward” people. O’Malley taken the blood lives of patients in need of ---- some Americans disagreed In Clinton’s estimation, drive simply as an oppor- donor blood should not op- [email protected] with her policy positions I’m still a “deplorable.”2 This tunity to raise awareness of erate as bargaining chips in and, instead, wished to slash is not because of any “ongo- this injustice or even to en- the quest to achieve societal the administrative state, re- ing pressure” but because I courage the SBA not to host equality. It is a death sen- build the military, cut tax- value and believe in certain the drive during Diversity tence imposed on patients es, restore local control to things dearly—things like Week, then I would hap- for the sins of the FDA. It is schools, or halt illegal immi- limited government, Sec- pily sign on as an ally to his an immoral, unjust, and re- gration. That many of those ond Amendment rights, and cause. Unfortunately, how- gressive proposition. people live in America’s economic and religious lib- ever, this is not the course That public policy often heartland is not surprising, erties. As a young woman, I taken. necessitates the balancing nor cause for denigration. would hope a feminist like Instead, he seems to ar- Next, Mrs. Clinton was Mrs. Clinton could at the 4 O’Malley, supra n.1. asked why she thinks over very least respect that. But 1 Kyle O’Malley, Tainted 50 percent of white women instead, the demonization Love, Virginia Law Weekly. 5 Id. voted for Donald Trump. continues. Her demeaning, absurd, and Thank goodness deplor- 2 Available at, https:// wholly anti-feminist answer able votes still count. www.fda.gov/downloads/ proves too much. Clinton BiologicsBloodVaccines/ Faculty Quotes responded: “We don’t do ---- GuidanceComplianceRegula- M. Robinson: “I will review well with white men and we [email protected] toryInformation/Guidances/ the point we made last Thurs- C. Nicoletti: “My advice: Blood/UCM446580.pdf. day, when life was still full of don’t take your husband to the 1 http://www.busi- promise.” doctor, and be annoying.” nessinsider.com/ 2 https://www.nytimes. 3 Zhou & Berkman, Ban hillary-clinton-says- com/2016/09/11/us/politics/ the Ban, at https://medical- J.C. Jeffries, Jr.: “Well this K. Kordana: “Casebooks and trump-won-backwards-states- hillary-clinton-basket-of-de- review.columbia.edu/article/ is my last class . . . and it may laptops make excellent weap- in-2016-2018-3?r=UK&IR=T. plorables.html. ban-the-ban/. well be my last class ever. It’s ons” probably a mystery to you but I’m in perfect health, thank J. Setear: “like explosive di- you. [laughter] But I’m taking arrhea, there used to be things a job at the University and will that were special” Virginia Law Weekly not be back in the classroom, at least some years. And, after J. Harrison: “The future COLOPHON that, God may have a say about will resemble the past, except it. And I’m sorry to end.” when it’s different.” Jansen VanderMeulen ‘19 Editor-in-Chief

M. Eleanor Schmalzl ’20 Executive Editor Anand Jani ‘19 David Ranzini ‘20 Kim Hopkin ‘19 Managing Editor Production Editor Development Editor Ali Zablocki ‘19 Alison Malkowski ‘19 Katherine Mann ’19 Articles Editor Format Editor Features Editor

Jenny Lamberth ‘19 Cartoonist-in-Chief

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EDITORIAL POLICY: The Virginia Law Weekly publishes letters and columns of interest to the Law School and the legal community at large. Views expressed in such submissions are those of the author(s) and not necessarily those of the Law Weekly or the Editorial Board. Letters from organizations must bear the name, signature, and title of the person authorizing the submission. All letters and columns must either be submitted in hardcopy bearing a handwritten signature along with an electronic version, or be mailed from the author’s e-mail account. Sub- missions must be received by 12 p.m. Sunday before publication and must be in accordance with the submission guidelines. Letters and/or columns over 1200 words may not be accepted. The Editorial Board reserves the right to edit all submissions for length, grammar, and clarity. Although every effort is made to publish all materials meeting our guidelines, we regret that not all submissions received can be published. Wednesday, 21 March 2018 VIRGINIA LAW WEEKLY Columns 5 JUDGES Law Emeritus Lillian BeVier, py about the popular criti- Justice Scalia’s presence on ed the uniqueness of Justice continued from page 1 which he hopes students— cism that he was viewed as the Court “a lot.” Thomas’ clerks often com- whether they are formalists Justice Thomas’ “boss” on the Despite typically aligning ing from law schools outside can better guess the outcome or not—will take before grad- Court, according to Justice with Justice Scalia’s judicial the T14, Justice Thomas re- in advance. Moreover, Judge uating. Thomas, from the moment he philosophy, Justice Thomas plied that he is interested in Thapar expressed concern took his place on the bench, stated that there is no rea- working with people from a that a pragmatic approach in Justice Clarence Thomas there was a trust between son why collegiality cannot wide variety of backgrounds the judiciary branch would the two men. “Unlike much exist between justices with and that there are many elevate judges to the posi- Justice Clarence Thomas’ of society,” Justice Thomas different viewpoints. He said bright students outside the tion of “co-legislator.” The event spanned a vast spec- said, “[Justice Scalia] never that, ultimately, what mat- Ivy League. Notably, he cur- problem with this, according trum of topics, including his had an image of me [that] I ters is that justices decide rently has no clerks from an to Judge Thapar, is that, “at approach to judging and is- was to live up to. He never cases based on their commit- Ivy League law school, and no point in time have judges sues related to race. Much had a stereotype, like much ment to what they believe is he said that he particularly been infallible,” and taking like Judge Thapar, Justice of what you see in the me- the correct method of judicial enjoys hiring students who policy decisions away from come from “modest back- politically accountable mem- grounds,” as well as from bers of the legislative branch different regions, because could result in unpopular they tend to have different and unwanted decisions be- perspectives on the issues coming law. that come before the Court. In his concluding com- He also encouraged students ments, Judge Thapar stated to look beyond “faux diver- that he agrees with former sity,” which he described as Supreme Court Justice Sca- an overemphasis on immu- lia’s view that liberties are table characteristics, and to best protected by following instead engage with people the separation of powers, and who hold differing intellec- that the different branches tual ideas and interests. should “stay in their lanes.” Finally, Justice Thomas He acknowledged that “tex- offered insight into his per- tualism is hard,” but argued sonal life. He spoke about that it is not the responsibil- his wife with great esteem ity of the judiciary to amend and described the fun they poor legislative drafting, have on the cross-country even if judges would person- trips that they take in their ally prefer a different out- motorhome. He also noted come than what is required the importance of his faith by a statute’s text. According and his reliance upon it dur- to Judge Thapar, when courts Judge Amul Thapar. ing tough times. Throughout apply a consistent interpreta- Photo courtesy of the Universal News Network the event, it became apparent tion of the law, it pressures Thomas’ remarks at the dia, or the country now—they interpretation. He said that, that Justice Thomas’ reputa- Congress to pay more atten- Federalist Society’s Student have an image of what I’m even when his interpreta- tion for having a great sense tion to how they write. Symposium included praise supposed to be, and if I de- tion of the law results in his of humor is wholly justified, For those interested in of Justice Scalia, though his viate from that, something’s ending up in the minority of and it was a tremendous learning more about Judge comments emphasized the wrong with me [. . .] He never a decision, he prefers that privilege to hear him share Thapar’s judicial philoso- close personal relationship did.” Justice Thomas went on outcome to deviating from his thoughts. phy, he regularly co-teaches he developed with his former to say that even when he dis- his principles. In his words, ---- a popular J-Term with UVa’s colleague over the years. Al- agreed with Justice Scalia in “Why do the job if you can’t [email protected] David and Mary Harrison though he joked that Justice an opinion, their friendship do it in an honorable way?” Distinguished Professor of Scalia had once been unhap- never wavered and he misses When the moderator not-

staff members had to carry the murderous cook, locking on for months not knowing him in a supply shed. This whether a murderer was in time, the U.S. was able to their midst! When they fi- immediately dispatch three nally completed the autopsy, FBI agents to investigate and they concluded that the man take the cook into custody. died from methanol poison- Inexplicably, Australia sent ing, but without examining a mediator. the crime scene it was im- Thus, it seems to matter in possible to determine if it what season and on which was a suicide, and accident, country’s base the murder or the continent’s first re- takes place, but generally, corded murder. investigating violent crime In October 1996, on a huge in Antarctica is ad hoc, and American base called Mc- relies on international coop- Murdo Station that also sits eration. It’s a dissatisfying on land claimed by New Zea- answer born of the conti- land, one American cook at- nent’s extreme remoteness tacked another with the claw and weather, the same con- end of a hammer. On Ameri- ditions that make Antarctica can bases, the station chief so worthwhile to visit in the is commonly deputized as a first place. Potential crime scene Palmer Station. U.S. Marshal. In this case, he ---- Photo courtesy of Law Weekly used his authority to arrest [email protected] country for all “acts and ANTARCTICLE omissions occurring while continued from page 3 they are in Antarctica for the pens to such criminals is purpose of exercising their well-settled and the same no functions.” The treaty is si- matter where you sail. The lent on tourists, however. more interesting question— And regarding scientific per- and the one savvy killers sonnel, the treaty appears should be asking—is what limited to acts that fall with- happens when someone is in the scope of their employ- murdered on continental ment in Antarctica, i.e. not Antarctica. homicide. Unfortunately (or fortu- In the year 2000, an Aus- nately), Antarctic homicide tralian astrophysicist myste- is too uncommon to offer riously died after a coughing well-settled answers. The fit in the middle of the Ant- Antarctic Treaty offers mini- arctic winter. He was work- mal guidance. And the few ing on an American Base in examples since its ratifica- territory claimed by New tion generate conflicting re- Zealand. Interestingly, the sults. The Treaty specifies New Zealand authorities that scientific personnel investigated. But since the and “observers” (officials scientist died in the winter, designated by each signa- they couldn’t retrieve the tory to enforce the terms of body to perform an autopsy the treaty) are subject to the until October. Consider that The author mugs for the camera, thinking little of the legalities that would complicate investigation of his murder. jurisdiction of their home for a moment, the other 50 Photo courtesy of Law Weekly 6 Ad VIRGINIA LAW WEEKLY Wednesday, 21 March 2018 :BETTERTOGETHER UVA Law Class of 2018 Graduation Gift Pledge Drive I J T F E G D H A B C SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTION SECTI ON SECTI Wednesday, 21 March 2018 VIRGINIA LAW WEEKLY Ad 7 Law Weekly Special Sponsored Content In the spring of 2017, the Court of Petty Appeals ruled in favor of Professor Anne Coughlin in her ongoing dispute with Paw Review. The speciesist cretins at Paw Review refused to expand their categories beyond “Best Dog” and “Best Cat.” Siding with justice, the Court of Petty Appeals ordered Paw Review to include Pro- fessor Coughlin’s toad, Gary. At Professor Coughlin’s request, the Law Weekly reproduces that opinion here. For the last time, Paw Review, include Gary. Or else.

Coughlin v. Virginia Animal the contest is over. Judge Napier Gary, but they also raised money are beloved by their owners. To- we are badasses”). See also Com- Law Society agreed, and dismissed the case. through his participation in Paw day, we are able to support that mon Sense v. Scott Commons 90 U.Va 403 (2017) Professor Coughlin timely ap- Review. foundation and provide needed 475 U.Va 322 (“Because this pealed. Allowing Gary to compete in justice for Gary. The judgment court is f**ing awesome”). “To HADEN, J., joined by GOLD- At the outset, under the Gol- Paw Review but limiting winners of the lower court should be re- save everyone some money” is MAN, C.J., and PICKUS and uboff Suggestion, we note that to only cats and dogs discrimi- versed. It is so ordered. an improper standard to war- THORNTON, JJ., announcing we have jurisdiction because this nates against these non-furry rant de novo review. In fact, the the opinion of the Court. case arises out of the Law School; friends. This discrimination is JANI, J., dissenting. costs of litigation have been sub- the parties are a professor and a unlawful, and allows VALS and Here we have a question of stantially lowered since Student Petitioner Coughlin appeals student group at UVa Law. cats and dogs to benefit at the whether a toad, “Gary,” was Affairs cancelled SBA’s weekly to this Court, asking us to recog- VALS has asked that we expense of Gary. Even petty law unduly discriminated against keg (see figure 1). nize a discrimination claim on give deference to their adjudi- cannot allow such a scheme to by VALS in their annual Paw In giving deference to student behalf of her pet, Gary. Based on cation of Coughlin’s original continue. Review contest. I stand alone organizations’ independent de- the following, we reverse. administrative complaint. They VALS argues that, by revers- in saying the Court erred in its cision making, it is imperative The facts of this case are not argue that in Law Weekly v. ing the dismissal of the com- judgment. that the record reflect VALS’s in dispute. Every year, the Vir- ABC Store #1782, we recognized plaint, they will have to give an Today we see an activist Court reasoning behind creating only ginia Animal Law Society (VALS) that student groups should have award for every kind of animal overstepping its authority by is- two awards, “Best Cat” and “Best conducts a “Paw Review” event, large authority to run their in- to avoid alleged discrimination. suing an affirmative injunction Dog.” While Paw Review only which they hold right after jour- ternal affairs and deal with out- We agree that if they choose to against a student group. The awarded cats and dogs, it also nal tryouts to remind 1Ls of their side groups in a representative give an equal award to each par- question this court must ask is featured some type of rodent (the traumatic experience trying to capacity. 123 U.Va 201 (2014). ticipant of Paw Review, they will not whether or not Petitioner record is unclear as to whether write on to Law Review.1 The They ask that we review that re- avoid future discrimination law- Coughlin’s pet was discrimi- this was a gerbil or some other purpose of the event is to raise cord under an “arbitrary and ca- suits. However, there are a num- nated against, but rather if there type of unfun pet). So this was money for a no-kill shelter for pricious” standard. ber of other solutions that will was a rational basis for VALS not, strictly speaking, a student- animals in Fluvanna County. Ac- Coughlin has argued that reach a similar goal. They can choosing not to include addi- on-frog crime. Perhaps VALS cording to the event description we should review the record de simply give prizes for the Best tional categories. has a policy of not awarding par- made public to the Law School: novo. She points to Petty Rule of Animal, and give that to the ani- The Court correctly rules that ticipation trophies, or awarding “[T]he pets of student [sic] and Civil Procedure 1: “We do what mal with the most money in its the remedy does not define the animals that are not strictly pets faculty compete to receive the ti- we want.” She also argues that jar. They can give out no prizes right and that the lower court (the record reflects that Gary is tle of the law school’s most loved in In re Virginia Law Women’s and simply donate the money. erred in dismissing the com- not a cherished pet but rather a pet.” Funding, this Court noted that Or, they can come up with silly plaint for failing to state a claim trespasser in an otherwise love- VALS sets up the event as without a strong external re- categories, like Best Smile, and upon which relief can be grant- ly garden). The proper ruling follows. They solicit members view of certain kinds of actions, make all animals eligible for that ed. See UVa Law v. UVa Under- should be to remand the com- of the student body and faculty student groups might deprive prize. graduates 917 U.Va 322 (2015) plaint with a directive that VALS to submit photos of “pets”2 for others (or, as was the case in We close by remarking that, However, the Court then sheds submit, in writing, the rationale the competition. Then, each Virginia Law Women’s Fund- for future Paw Review discrimi- itself of the robe and becomes a behind their conclusion to the pet’s photo is placed inside of a ing, be deprived) of important nation claims, damages are not de facto legislator. Rather than court of original jurisdiction. jar, and all of the jars are put on resources. available as relief, because that correctly remanding the case, Finally, I would like to add that display in Hunton & Williams. We do not think that it is in money should go to the shelter. the court decides to review the there are only two types of cats: People are encouraged to vote VALS’ interest for us to review Only injunctive relief preventing record de novo. bad cats and ok cats. Therefore, I for the pet that they like the most the record under their suggested continuing discrimination shall Here the Court errs in allow- suggest to VALS that next year’s by placing money in that pet’s standard. The record they pres- be available. ing de novo review, as this case Paw Review award be changed jar. See also Citizens United ent is rather scant, and there is This Law School was found- does not meet the high threshold to simply, “Cat.” v. Federal Election Commis- little to no basis upon which we ed on the principle that all pets for de novo review. Id. (“Because sion, 588 U.S. 310, 313 (2010) can affirm their dismissal of the (“Money=votes”). complaint. Rather than remand Professor Coughlin submit- this case back to them for an- ted a photo of her pet Gary, a other proceeding, further litiga- toad, for Paw Review, and VALS tion, and another appeal back accepted the submission and al- to this Court, we will review this lowed Gary to be entered into the case de novo and save everyone competition. At the end of the some money. Especially VALS, PASSIONATE. voting period, VALS calculated who has spent all $122 of their the winners, and announced two student affairs’ money allocation separate winners: Best Dog and on this lawsuit. Best Cat. The winners were de- VALS argues that it could INDUSTRIOUS. termined based on the amount have chosen not to have a Paw of money that their jars had col- Review at all, or to have given lected. prizes to every pet candidate. Professor Coughlin lodged They argue that because they a complaint with VALS regard- have these larger powers, they ing the results of Paw Review. must also have the included less- She does not dispute that the er power to give some candidates Best Dog and Best Cat received prizes and not others. We have more money than any other cat recognized this “greater includes or dog, or indeed, any other pet, the lesser” argument in other including Gary. Rather, she ar- contexts. See Holsapple v. Rod gued that the categories of Best and Gun Club, 23 U.Va 1452 Cat and Best Dog discriminate (2016) (“Room reservation con- against non-furry pets, and that ditionally denied until you are there was no way Gary could actually a club again.”). Howev- have won, even if he did earn er, we have also recognized that the most money. She argues that in other cases, the greater does there should be a separate cat- not include the lesser when the egory that her pet could win, like lesser is chosen in a discrimina- Best Reptile. tory or harmful way. Collins v. VALS ignored the com- Elections Committee, 165 U.Va plaint, feeling that they had no 83 (2017) (“You really shouldn’t power to make any changes make appointments to commit- after the winners had been an- tees based on their knowledge nounced. Having exhausted her of Survivor and RuPaul’s Drag Tell your Paw Review representatives to administrative routes, Professor Race.”). end the speciesism. Coughlin filed suit in the Court VALS knew that Gary was of Student Affairs. VALS argued a toad, but accepted him into that they did not discriminate Paw Review anyway. VALS has against Gary in selecting the win- carefully avoided answering ning categories, because the vast Coughlin’s contention that even majority of pets are either cats or if Gary had the most money, he dogs. They also argue that there still couldn’t win Paw Review. is no remedy available now that We think VALS refuses to an- swer that contention because it 1 At least, I think that’s where they is damning to their case. VALS got the name. could have rejected Gary if they 2 These aren’t meant to be sketchy felt that Paw Review was only quote marks, they’re just for emphasis. for cats and dogs. However, not Keep reading, you’ll understand. only did they knowingly accept 8 The Back Page VIRGINIA LAW WEEKLY Wednesday, 21 March 2018 FREE MEEK Attorney and Meek Mill’s known liar and his partners he has released three albums, lematic sentencing habits. In continued from page 2 parole officer opposed jail testified to his dishonesty. toured the world, and at- 2016, the agency asked Meek time.28 A list recently leaked from tempted to start a record label Mill to wear a wire while The NFU detective who the Philadelphia District At- to help other up-and-coming meeting with Judge Brinkley. released from prison in 2009 originally testified to Meek torney’s office placed Reggie artists. Meek Mill has not Meek Mill refused.35 The Phil- to when he signed with May- Mill selling crack on the cor- Graham on a list of officers been convicted of so much as a adelphia prosecutors’ office is bach Music Group in 2011. ner of 22nd and Jefferson too dishonest to be trusted misdemeanor during his time reconsidering the case in light For the next five years, Judge Street quietly retired last year as a source of testimony.31 It outside of Chester State.33 of the new report from the Brinkley would systematically from the force, plagued by ru- is especially damning infor- In an exclusive interview District Attorney concerning stop Meek Mill from touring, mors of dishonesty and deceit. mation considering the word with Rolling Stone, he re- Graham’s trustworthiness. send him back to jail, and In early 2009, as Meek Mill of Detective Graham was the vealed he doesn’t allow many There may be hope for Meek extend his probation. These continued to serve out his first sole evidence in the granting visitors to Chester State Cor- Mill. Until his release, Meek events often occurred parallel sentence, a group of Philadel- of the original search warrant. rectional. He says he’s not Mill’s case demonstrates the to an album release. phia NFU officers were caught Since his original convic- alive in prison.34 Meek Mill corruption and abuse of the The latest example of on security cameras robbing tion, Meek Mill has been sent is currently appealing the criminal justice system by Judge Brinkley’s abuse of the bodegas in North Philadel- back to prison four times. His probation violation sentence. individuals in positions of system happened just last phia. All members involved in original sentence called for His attorneys have requested power in Philadelphia. Meek year. Meek Mill was in New the scandal maintained their twenty-three months in pris- Judge Brinkley recuse herself. Mill’s music may alienate York City to film a segment positions, while taxpayers on. He has served almost four The FBI is aware of her prob- some listeners. The night- of The Tonight Show. As he shelled out almost $2 million years and earned an addition- mares of his reality should was driving uptown, a group in damages to the robbery vic- al fourteen years of probation. 33 Meek Mill has failed to alienate everyone. Free Meek. of kids on dirt bikes pulled tims.29 Many see Meek Mill’s case as notify his parole officer of trips --- alongside his Rolls Royce. The NFU has appeared re- a stark example of Pennsylva- outside of Philadelphia, failed to [email protected] Meek rolled down his window peatedly in the news for in- nia’s broken parole system.32 make court appearances, and test- and asked if he could borrow tentionally robbing people’s In his moments of freedom, ed positive for Percocet in a 2015 one of the bikes for a ride. A homes, usually in North drug test. Each minor infraction kid happily obliged and Meek Philadelphia.30 The detective 31 Julie Shaw and Chris led to additional prison time or Mill joyfully popped wheelies at the center of Meek Mill’s Palmer, Here are the 29 Philly additional probation. Id. down the streets of New York arrest was corrupt. He was a Cops on the DA’s ‘Do Not with his cameraman filming Call’ List, Philly Inquirer, 34 Solotraoff, supra note 5. 35 Id. for his Instagram followers. 28 Id. 3/6/2018, http://www.philly.com/ The next day Meek Mill was philly/news/crime/29-philly- arrested by the NYPD on a 29 Solotraoff, supra note officers-do-not-call-list-kras- Cartoon By Jenny felony count of reckless en- 5. See also Walter Olson, Cops ner-20180306.html. dangerment. The charge was Walk in Philadelphia Bodega later downgraded to a misde- Robbery Scandal, Cato Institute, 32 “The problem with meanor, then dropped. Meek 5/14/2014, https://www.cato.org/ Pennsylvania’s laws are that they Mill was then ordered back blog/philly-cops-will-walk-bode- allow probation to exist in per- to Philadelphia, after being ga-robbery-scandal petuity. You can be on probation found in violation of his pro- forever in Pennsylvania because bation. Judge Brinkley sen- 30 Haimy Assefa, Six you do not receive time served tenced Meek Mill to two-to- Philadelphia Officers Arrested for being on probation.” Sidney four more years in prison.27 on Corruption-Related Charges, Madden, Meek Mill’s Sentenc- Both the Philadelphia District Cnn, 7/30/14, https://www.cnn. ing Generates Protest, Calls for com/2014/07/30/justice/phila- Probation and Parole Reform, 27 Kristine Phillips, Meek delphia-police-corruption/index. NPR Music, 11/15/2017, https:// Mill Denied Bail Again as Judge html; See also Melissa Hellman, www.npr.org/sections/ther- Calls Rapper a “Danger to Philadelphia Narcotics Cops ecord/2017/11/15/564385830/ the Community,” Wash. Post., Charged with Stealing Drugs and meek-mill-sentencing-protest- 12/4/17. Money, Time, 8/1/2014. probation-parole-reform.

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