By David Manno | 65 Am. U. L. Rev. 675 (2016) 

*Junior Staff Member, American University Law Review, Volume 65; J.D. Candidate, 2018, American University Washington College of Law; B.A. Justice, 2006, American University.  I would like to thank Professor Macarena Sáez and my Note & Comment Editor, Beth Fisher, for their guidance, and the American University Law Review staff for their diligent efforts in preparing this piece for publication.  Finally, a special thanks to my family—particularly my wife, Elizabeth, and my daughter, Vivian, for their unwavering support, encouragement, and inspiration.