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May 26, 2017

The Shifting Ground of Redistricting Law

(Cross-posted from Balkinization)

Chris Elmendorf

The tectonic plates of redistricting law are starting to slide—and quickly. Earlier this year, a three-judge district court struck down Wisconsin’s state legislative map as an unconstitutional partisan gerrymander, the first such holding by any federal court in more than a generation. Federal courts in Maryland and North Carolina have also issued supportive rulings in current partisan gerrymandering cases, allowing the plaintiffs' claims to proceed to trial.  

Meanwhile, yesterday’s Supreme Court decision in Cooper v. Harris, the North Carolina racial gerrymandering case, augurs a major recontouring of the redistricting landscape as the Equal Protection plate comes crashing into the Voting Rights Act (VRA) plate. Section 2 of the VRA has long been understood to require the drawing of electoral districts in which racial minorities can elect their “candidates of choice” in locales where white and minority voters have very different political preferences. Yet since the 1990s, the equal protection clause has required strict scrutiny of any district in whose design race was the “predominant factor.” The Constitution disfavors the intentional sorting of voters among districts on the basis of their race. Until recently, however, it was widely thought that the “predominant factor” test for racial sorting / equal protection claims would be met only as to districts in which both (1) minority citizens comprise a majority of the voting-age population, and (2) the district’s boundaries are wildly incongruent with “traditional districting principles,” such as compactness and respect for local government boundaries.

But in Bethune Hill v. Virginia, decided two months ago, the Supreme Court clarified that the “predominant factor” test is satisfied whenever race was the overriding reason for moving a group of voters into or out of a district, irrespective of the district’s apparent conformity to traditional criteria. Then, in the unanimous portion of Cooper v. Harris, the Court applied strict scrutiny to a district because the state had “purposefully established a racial target” for its composition, and selectively moved heavily black precincts into the district to achieve that target. In the Republican redistricting plan at issue in Cooper, the target was 50% black. In a Democratic gerrymander of North Carolina, the target would probably be smaller, perhaps 40% black, to more efficiently distribute reliable black Democratic voters while continuing to enable the election of some black candidates. But the actual threshold (50% vs. 40%) seems legally irrelevant.

How then is a state to comply with Section 2 of the Voting Rights Act, which, as noted above, has long required states to create districts with enough minority voters (a "racial target") to consistently elect minority “candidates of choice.” One unhappy possibility is that the Court will simply undertake to free redistricters from the latter obligation, holding Section 2 unconstitutional or narrowing it beyond recognition on the basis of an asserted conflict with the anti-sorting equal protection principle. 

Another possibility is that federal courts will require redistricters to follow a path established by Alaska's Supreme Court as a matter of state constitutional law. In Alaska, the state must first redistrict blind to race, then evaluate the resulting map for compliance with Section 2, and then make whatever minimal (?) changes are necessary prevent a Section 2 violation. Cooper v. Harris hints at this approach. Striking down District 1, the Court explained: "North Carolina can point to no meaningful legislative inquiry into what it now rightly identifies as the key issue: whether a new, enlarged District 1 [enlarged to comply with one person, one vote], created without a focus on race but however else the State would choose, could lead to § 2 liability.”

Insofar as today’s decision in Cooper advances the Alaska framework, the million dollar question will be how a state redistricting authority must assess its initial race-blind map for compliance with Section 2. Here the law could evolve in any number of directions, but given the Supreme Court’s aversion to racial targets, the Court may well allow states to count for Section 2 compliance purposes any district in which minority voters are likely to wield some influence (say, any district with a Democratic majority, or any district in which Democrats would lose their working majority if no minority voters went to the polls). This would represent a dramatic change in the law of Section 2, since until now nearly all courts have focused on the question of whether districts enable the election of authentic candidates of choice of the minority community, rather than minimally acceptable (and usually white) Democrats.

Of course, all of this is somewhat speculative. Writing at SCOTUSblog, Kristen Clarke and Ezra Rosenberg argue that Cooper and Bethune Hill, read together, require plaintiffs bringing a racial sorting / equal protection claim to show (as the trigger for strict scrutiny) quite a bit more than the existence of a firm racial-composition target plus the movement of voters to achieve the target. I’m not convinced, but for now, there’s enough looseness in the doctrine for lower courts to go either way on this question. 

What is clear is that the Supreme Court, unhappy about racial sorting, is on guard against pretextual justifications for the practice. As Justice Kennedy for the Court remarked in Bethune Hill, “Traditional redistricting principles . . . are numerous and malleable . . . . By deploying those factors in various combinations and permutations, a State could construct a plethora of potential maps that look consistent with traditional, race-neutral principles. But if race for its own sake is the overriding reason for choosing one map over others, race still may predominate.”

Going forward, any redistricters who undertake to draw districts with a racial-composition target (majority-minority or otherwise) would do well to announce that the target is merely one objective to be considered and balanced alongside many others, rather than a categorical command. The crossing of fingers is also recommended.
May 19, 2017

Guest Blogging on Concurring Opinions about Whiteness, Class, Rurality

I've been guest blogging for the past few weeks over at Concurring Opinions and invite you over to that blog, on "the law, the universe, and everything" to see what I've been writing.  I've done a four-installment review/commentary on J.D. Vance's Hillbilly Elegy:  A Memoir of a Family and Culture in Crisis.  Spoiler Alert:  I'm not a big fan but, in the end, suggest that the book can help law profs better understand the low-income white students who (thankfully, yes, thankfully!) show up in our classrooms from time to time.  My posts are:

On Donald Trump, J.D. Vance, and the White Working Class

Hillbilly Elegy as Rorschach Test

The "Shock and Awe" Response to Hillbilly Elegy:  Pondering the Role of Race

On Ree Dolly, J.D. Vance and Empathy for Low-Income Whites (or, What Hillbilly Elegy is Good for)

I've also done a bit of writing about rurality, with these posts:

Rurality and Government Retreat

Local Journalism as Antidote to Echo Chambers and Fake News

Also related to rurality are these posts about spatiality and abortion access. 

Did You Hear the One About the Alaska Legislator Who Said ... 

Sanger's Tour de Force on Abortion (with a Blind Spot for Geography)

Carol Sanger of Columbia Law responded to my post about her new book, About Abortion:  Terminating Pregnancy in the 21st Century, here.  I love the fact she says I get the "last word" in our exchange over the significance of geography.

I expect to post another item or two before my term as a guest blogger expires in about a week. 

May 16, 2017

Supreme Court Immigration Watch: The 2016 Term -- Look Out for Six Decisions

(Cross-posted from Immigration Prof)

There are a number of immigrations cases currently before the Supreme Court (and here).  We should get decisions by the end of the Term in June and will should get a better idea of how the newest Supreme Court Justice, Neil Gorsuch, looks at immigration law.

The cases before the Court raise a variety of different types of issues.  The decisions could affect the direction of judicial review of the constitutionality of immigration laws and policies.  In recent years, as explained in this article, the Supreme Court has slowly but surely moved immigration law into the mainstream of American jurisprudence. 

The cases, which have been discussed regularly on this blog, include:

1.  Sessions v. Morales-Santana Argued November 2016.  Gender Distinctions in Derivative Citizenship.

Issue(s): (1) Whether Congress’s decision to impose a different physical-presence requirement on unwed citizen mothers of foreign-born children than on other citizen parents of foreign-born children through 8 U.S.C. 1401 and 1409 (1958) violates the Fifth Amendment’s guarantee of equal protection; and (2) whether the court of appeals erred in conferring U.S. citizenship on respondent, in the absence of any express statutory authority to do so.    The Second Circuit, in an opinion by Judge Loheir, found that the gender distinction for citizenship was unconstitutional. 

The Supreme Court has been divided on the constitutionality of gender distinctions in the citizenship laws in previous cases.  See, e.g., Nguyen v. INS (2001); Miller v. Albright (1998).  This case allows the Court to reconsider the issue.

 

2.  Jennings v. Rodriquez Argued November 2016.  Constitutionality of Immigration Detention.

Issue(s): (1) Whether noncitizens seeking admission to the United States who are subject to mandatory detention under 8 U.S.C. § 1225(b) must be afforded bond hearings, with the possibility of release into the United States, if detention lasts six months; (2) whether criminal or terrorist noncitizens who are subject to mandatory detention under Section 1226(c) must be afforded bond hearings, with the possibility of release, if detention lasts six months; and (3) whether, in bond hearings for noncitizens detained for six months under Sections 1225(b), 1226(c), or 1226(a), the noncitizen is entitled to release unless the government demonstrates by clear and convincing evidence that the noncitizen is a flight risk or a danger to the community, whether the length of the noncitizen’s detention must be weighed in favor of release, and whether new bond hearings must be afforded automatically every six months. 

The Ninth Circuit, in an opinion by Judge Kim McLane Wardlaw, affirmed the district court’s permanent injunction insofar as it required automatic bond hearings and required Immigration Judges to consider alternatives to detention.  The panel also held that immigration judges must consider the length of detention and provide bond hearings every six months for class members detained longer than twelve months, but rejected the class’s request for additional procedural requirements.

 

3.  Sessions v. Dimaya Argued January 2017.  Constitutionality of Criminal Removal Provisions.

Issue(s): Whether 18 U.S.C. 16(b), as incorporated into the Immigration and Nationality Act's provisions governing an immigrant's removal from the United States, is unconstitutionally vague.  In a rare move, the Ninth Circuit, in an opinion by Judge Stephen Reinhardt, stuck down a statute including the reference "crime of violence" as unconstitutionally vague.   The Board of Immigration Appeals had found that  burglary was a "crime of violence" for removal purposes.  Dimaya was a lawful permanent resident from the Philippines who had lived in the United States since 1992. 

 

4.  Esquivel-Quintana v. Sessions  Argued February 2017.  Interpretation of "Sexual Abuse of Minor" for Removal.

Issue:  Whether a conviction under one of the seven state statutes criminalizing consensual sexual intercourse between a 21-year-old and someone almost 18 constitutes an “aggravated felony” of “sexual abuse of a minor” under 8 U.S.C. § 1101(a)(43)(A) of the Immigration and Nationality Act – and therefore constitutes grounds for mandatory removal.

 

5.  Hernandez v. Mesa Argued February 2017.  Liability for Cross Border Shooting by Immigration Officer.

This case raises the following questions (1) Whether a formalist or functionalist analysis governs the extraterritorial application of the Fourth Amendment’s prohibition on unjustified deadly force, as applied to a cross-border shooting of an unarmed Mexican citizen in an enclosed area controlled by the United States; (2) whether qualified immunity may be granted or denied based on facts – such as the victim’s legal status – unknown to the officer at the time of the incident; and (3) whether the claim in this case may be asserted under Bivens v. Six Unknown Federal Narcotics Agents.

 

6.  Maslenjak v. United States Argued April 2017.  Impact of Misrepresentation for Purposes of Denaturalization. 

The denaturalization case raises the question whether the U.S. Court of Appeals for the 6th Circuit erred by holding, in direct conflict with the U.S. Courts of Appeals for the 1st, 4th, 7th and 9th Circuits, that a naturalized American citizen can be stripped of her citizenship in a criminal proceeding based on an immaterial false statement.  Amy Howe in a preview to the argument on SCOTUSBlog concludes:

"The stakes in this case are high, not just for Divna Maslenjak but also for the millions of people who became naturalized U.S. citizens in recent years. Most of those naturalized citizens, of course, did not make false statements during the process of securing citizenship. But a ruling in the government’s favor could potentially expose many new citizens to the possibility of losing their right to live in the United States, even if their false statements did not necessarily influence the government’s decision to give them citizenship."

Maslenjak v. United States makes it six immigration cases before the Supreme Court this Term, a large number compared to the   immigration cases reviewed the last few Terms.

***

The Court will consider the six immigration cases against a backdrop of considerable public discussion -- and many legal challenges -- to President Trump's executive orders on immigration enforcement.    The role of the courts in reviewing the immigration actions of the President have been debated publicly over the last few months.

Stay tuned as we will see decisions in those cases, which involve crime-based removals, constitutional challenges to provisions of the Immigration and Nationality Act, a cross-border shooting, deference to agencies, and more.

Part of the reason that we see extreme measures in the immigration laws is the limited scope of constitutional rights of immigrants recognized by the Supreme Court. Historically, under the plenary power doctrine, noncitizens outside the United States have had few, if any, rights to enter the country. In contrast, noncitizens inside the country have seen the steady expansion over time of rights, especially to procedural due process.

Over the last fifty years, the Supreme Court has moved toward a more normal immigration jurisprudence and away from the plenary power doctrine. That trajectory has been marked by the use of ordinary methods of statutory interpretation in interpreting the immigration statute; the Supreme Court also has adhered to ordinary administrative deference doctrines in the review of immigration decisions. Moreover, the Court on a number of occasions has applied routine constitutional avoidance doctrines to avoid invoking the plenary power doctrine, which is out of synch with modern constitutional jurisprudence, and its harsh results. This pattern of avoiding the decision of constitutional questions in ensuring judicial review of immigration matters can be understood as an effort by the Court to avoid invoking the plenary power doctrine and its stark outcomes.

Commentators have observed the slow movement of immigration law toward the mainstream of constitutional jurisprudence. In essence, the plenary power doctrine is slowly but surely eroding away. In a number of cases, the Supreme Court effectively moved toward expanding the rights of noncitizens seeking admission into the United States.] Among other indications, in Kerry v. Din (2012), six Justices found that a State Department consular officer's denial of a visa was subject to rational basis review, which is a move away from the doctrine of consular non-reviewability.

One possibility is that, in the current cases before the Court, the decisions will move us toward a more unexceptional immigration law that is more consistent with general American constitutional law.

President Trump’s immigration initiatives push the envelope of contemporary constitutional norms, virtually daring the courts to address their constitutionality. By taking brash immigration policy measures that test constitutional limits, such as the travel ban and expanded expedited removal, the Trump administration ultimately may force the Supreme Court to reconsider the plenary power doctrine.Conclusion

The aggressive Trump immigration measures likely will continue to generate legal challenges centering on the rights of immigrants. Courts, which have been moving in a direction toward further recognition of immigrant rights for at least a generation, may intervene – as some have already – to curb some of the excesses of the Trump immigration initiatives. However, the long term solution to the problems of the modern immigration system is legislative reform of the immigration law. Deep and enduring reform of the comprehensive immigration statute forged in the Cold War is necessary for the nation to effectively and fairly address the immigration realties of the 21st century.

 In short, the coming weeks may tell us a good deal about the future of immigration law in the United States.  Stay tuned.

 

 

May 4, 2017

Plenary Session on Being Undocumented at UC in the Trump Era

Maria Blanco of the UC Immigrant Legal Services Center (housed at UC Davis School of Law) is speaking at the 8th Annual University of California International Migration Conference at UC Berkeley on May 13.

The topic is "Being Undocumented at UC in the Trump Era."

Find more information and registration details at haasinstitute.berkeley.edu/undocu2017.

 

 

May 4, 2017

Commentary on the California State Constitution, Co-authored by Darien Shanske, Is New in Paperback

This announcement from Oxford University Press:

Oxford University Press is happy to present the first paperback edition of the Oxford Commentaries on the State Constitutions of the US: The California State Constitution by Joseph R. Grodin, Darien Shanske, and Michael B. Salerno.

The California State Constitution provides an outstanding constitutional and historical account of the state's basic governing charter. In addition to an overview of California's constitutional history, it offers an in-depth, section-by-section analysis of the entire constitution, detailing the many significant changes that have been made since its initial drafting in 1849. This treatment, along with a table of cases, index, and the bibliography provides an unsurpassed reference guide for students, scholars, and practitioners of California's constitution.

The second edition updates and expands the previous edition published in 1993. The book provides new analysis, with citations to court decisions and relevant scholarly commentary, as well as accompanying explanations and a lengthy introduction to provide historical and thematic context. This new edition also contains a foreword by the current Chief Justice of California, Tani Cantil-Sakauye.

April 27, 2017

UC Davis School of Law Launches New Water Justice Clinic

(Cross-posted from Legal Planet.)

UC Davis School of Law has launched an exciting new Water Justice Clinic designed to advocate for clean, healthy and adequate water supplies for all Californians.  The new Clinic is a project of the Aoki Center for Critical Race and Nation Studies, in partnership with the  California Environmental Law and Policy Center, and will offer unique environmental justice advocacy opportunities for King Hall students.

Currently, over one million California residents lack access to clean, safe, and affordable drinking water.  An overwhelming percentage of those residents live in rural California, and represent communities of color.  The barriers to accessing clean water are not limited to environmental issues, and lack of access to water imposes a significant financial burden on low-income families, while also resulting in increased rates of obesity, shorter life expectancies and decreased learning outcomes for children.

However, very few rural legal services attorneys are able to litigate water law cases, and no legal services attorneys offer transactional legal support to these California residents.  King Hall's Water Justice Clinic seeks to fill that gap by identifying viable drinking water solutions and then implementing those solutions by providing transactional legal support to the affected low-income, rural communities.

Prominent environmental justice expert Camille Pannu has been recruited to lead the Water Justice Clinic as its inaugural director.  Pannu, a Berkeley Law alum, was passionate about environmental justice issues even as a law student.  After law school, Pannu worked on environmental justice cases for the Center on Race, Poverty & the Environment as an Equal Justice Works Fellow in the San Joaquin Valley.  Before coming to King Hall, she also clerked for District Judge Stefan Underhill in Connecticut and Ninth Circuit Court of Appeals Judge Richard Paez.

The overarching goal of the new Clinic is to insure that all Californians have access to clean, affordable and safe drinking water, primarily by strengthening rural community water systems.  The Clinic will also advocate for policies that fund needed improvements to those systems, address groundwater contamination, and ensure that rural voices are fully represented in future California water management decisions.

Recent headlines about the drinking water scandal in Flint, Michigan and--closer to home--the water crisis faced by East Porterville residents in the southern San Joaquin Valley have prompted action by California legislators and voters to confront those problems directly.  Proposition 1A on California's November 2014 ballot contained funding to provide assistance to California's disadvantaged communities, and King Hall's Water Justice Clinic is made possible by a three-year grant of Proposition 1A funds by the State Water Resources Control Board.  Indeed, the Clinic is the primary legal services provider among the organizations funded by these Proposition 1A grants.

Clinic Director Pannu reports that King Hall students will play a critical role in assisting these communities by enrolling in the clinical program each semester.  There they will partner with grassroots community organizations such as the Community Water Center, while also obtaining classroom training from Pannu in water justice and related issues.

April 21, 2017

Flores v. Sessions: UC Davis Immigration Law Clinic goes to the Ninth Circuit, Defending the Rights of Detained Children

Cross-posted from Immigration Prof Blog.

Earlier this week, the U.S. Court of Appeals for the Ninth Circuit heard oral arguments in Flores v. Sesssions in which the U.S. government seeks an emergency stay in an action involving the 1997 Flores Settlement Agreement, which addressed the treatment of minors in custody of the Department of Homeland Security.  The Flores litigation has been going on for years and this appears to be a last ditch attempt by the U.S. government to detain noncitizen minors -- which increased with the increase in Central American asylum-seekers in 2014.   The panel that heard arguments were Judges Stephen Reinhardt, A. Wallace Tashima, and Martha Berzon.   

Law student Fabián Sánchez Coronado '18 attended the argument and wrote about the experience.

From L-R: Michael Benassini '18, Holly Cooper '98 of the Immigration Law Clinic, Carlos R. Holguín of the Center for Human Rights and Constitutional Law, Eduardo Osorio '18, and Fabián Sánchez Coronado '18.

On April 18, 2017, myself and other students from the Immigration Law Clinic and Civil Rights Clinic had the opportunity to attend Oral Argument at the Ninth Circuit Court of Appeals for Jenny Flores v. Jefferson Sessions, III, a case dealing with the rights of children in immigrant detention. 

The case arises out of a 20-year settlement agreement - the "Flores Settlement" - between plaintiffs and the government. At issue is Paragraph 24 of the Flores Settlement, which guarantees minors in detention the right to a bond redetermination hearing.

Last summer, the Immigration Law Clinic's Co-Director, Holly S. Cooper '98, teamed up with Carlos R. Holguín, General Counsel at the Center for Human Rights and Constitutional Law, to bring an enforcement action in federal court after the government refused to comply with its duties under the settlement, thereby denying detained children basic due process. 

On January 20 of this year, Judge Dolly M. Gee of the U.S. District Court for the Central District of California granted the motion to enforce the settlement. Weeks later, the government filed an emergency motion in the Ninth Circuit to stay the District Court's order, paving the way for a renewed fight over the rights of children in immigrant detention. 

After the Ninth Circuit granted the stay and expedited briefing, a group of us from the Immigration Law Clinic and the Civil Rights Clinic rolled up our sleeves and got to work, helping Professor Cooper and Carlos Holguín prepare the case. Wesley Cheung '18, Eduardo Osorio '18, Michael Benassini '18 and I helped ready the Plaintiffs' brief and prepare the materials for Oral Argument. 

The experience of working on an appellate brief - and attending oral argument at the Ninth Circuit - was a highlight for me, as I'm sure it was for my fellow law students. After spending the academic year working on various immigration and civil rights cases with our respective clinics, it was great to sit at counsel's table for this particular occasion.

April 21, 2017

My Testimony before the Assembly Higher Education Committee

Earlier this week, I testified before the California Assembly Higher Education Committee on April 18 in support of Assembly Bill 856, which seeks to diversity faculty and athletic coaches at California universities. These were my remarks.

***

Thank you, Chair and Members.

My name is Rose Cuison Villazor and I am a Professor of Law at UC Davis.

I have been a law professor for eleven years and I have been teaching at UC Davis for five years. 

As the only Filipino American law professor in a public university and, indeed, the entire state of California, I come before you today in support of AB 856, which would increase faculty diversity at California public Universities and Colleges.

I have seen first hand the need to increase diversity amongst faculty at California schools.

According to the Association of American Colleges and Universities, "Faculty, along with staff, serve as an institution's front-line representatives, and in the academic realm, faculty are also the embodiment of authority on campus. Having a diverse faculty ensures that students see people of color in roles of authority and as role models or mentors. Faculty of color are also more likely than other faculty to include content related to diversity in their curricula and to utilize active learning and student-centered teaching techniques."

A diverse faculty helps close achievement gaps, improves campus climate, and creates new curriculum and research.

Having a faculty reflect the student population benefits students' growth and has a positive impact on their learning experience. 

Currently, in states where affirmative action has been banned, including California, universities have introduced new admissions and financial aid strategies based on socioeconomic status.

Similar initiatives can be applied to the hiring process at California schools.

I thank the author for bringing this measure forward and respectfully ask for your AYE vote.

April 21, 2017

Study Finds Litigants Are in the Dark about Court Dispute Resolution Programs

As court systems throughout the country struggle to deliver civil justice in the face of major budget cuts, a new study by a University of California, Davis, law professor finds that fewer than one-third of people with cases filed in state court even know about their court's mediation and arbitration programs.

In recent years, state courts have been overburdened with litigants seeking civil justice in a system still recovering from the economic downturn. In many cases, alternative dispute resolution procedures such as mediation and nonbinding arbitration can provide litigants with relief from the expense and waiting time associated with trial. However, such procedures provide little opportunity for justice to litigants who are unaware of their existence.

Over 330 litigants from three state courts were asked in a phone survey, after their cases ended, whether their court offered mediation or arbitration. All study participants had cases that were eligible for both procedures through their court.

"The findings from this study raise serious questions about whether plaintiffs and defendants understand what procedures are available to them, and how meaningfully they participate in decisions about how to handle their legal conflicts," said Donna Shestowsky, a UC Davis professor of law who is the report's author.

The study, forthcoming in Harvard Negotiation Law Review, found that only 24 percent of litigants correctly reported that their court sponsored mediation, and only 27 percent correctly stated that their court offered arbitration.

Even worse, represented litigants were not significantly more likely to know about their court's procedures than were those who handled their case without a lawyer.

Litigants who knew their court offered mediation had more favorable views of their court, but a similar result did not emerge for arbitration.

The study also found that when litigants correctly identified their court as offering arbitration, they were more than twice as likely to consider using arbitration for their case.

"The study suggests that courts should invest resources to ensure that litigants know about their procedures. By making these efforts, litigants might be more apt to consider using the programs in which the courts have already invested, and give courts the credit they deserve," said Shestowsky.

Shestowsky's project is the first known multijurisdictional study to explore how civil litigants assess procedures at various points of time during the same lawsuit. 

The article, "When Ignorance Is Not Bliss: An Empirical Study of Litigants' Awareness of Court-Sponsored Alternative Dispute Resolution Programs," is forthcoming in volume 22 (spring 2017) of the Harvard Negotiation Law Review.

The study was funded by grants from the National Science Foundation, the American Bar Association Section on Litigation, the Norm Brand '75 & Nancy Spero ADR Research Fund, and UC Davis.

April 13, 2017

King Hall Faculty Wow the Crowd at Aokirama, Are Featured in Above the Law

Last weekend brought one of the most-anticipated student events of the academic year: Aokirama (formely Cardozorama), the law school talent show!

One of the biggest hits of the evening was the band Negotiable Instruments, featuring:

Prof. Angela Harris (vocals) as law professor
Prof. William Dodge (vocals) as law student
Prof. Rose Cuison Villazor (drums)
Prof. Thomas Joo (guitar)
Prof. Carlton Larson (piano)

Check them out here on YouTube!

Popular legal blog Above the Law took notice, soliciting submissions for its annual video contest by writing, "Hey law students - if your professors can do it, so can you!"