65 Am. U. L. Rev.  471 (2015)

*Editor-in-Chief, American University Law Review, Volume 65; J.D. candidate, 2016, American University, Washington College of Law; B.A. German and International Affairs, 2010, James Madison University.  I would like to thank my mother, Darlene Poucher, for her endless encouragement and support.  Her work-ethic, strength, and determination has made me the woman I am today.  I would also like to thank my brother, Jeremy Woodard, and my beloved dog, Cole, for always being there for me.  This Article was written in loving memory of my father, Paul Owen Poucher, whom I miss every day.