Justia Law, Technology & Legal Marketing Blog

Writer’s Picks for February 17, 2012: Mafiosos and more

2012-02-17T17:55:49Z

I’m from Chicago, where everyone knows someone who knows someone in the mob. That’s why I loved this case, U.S. v Ambrose, sent to me by Laurel. It’s chock full of good mafia stories and lingo involving a crooked Deputy U.S. Marshal and a made guy in the “Chicago outfit” who turned state’s evidence.

In other criminal law cases, a defendant in the 10th Circuit was convicted of selling drugs at his apartment and for selling them within 1000 feet of a playground. Defendant challenged the definition of playground, which the court did not find convincing, holding that even if there was “one apparatus…intended for recreation of children,” then the place was a playground under the statutes. US v. West. In other words, “that’s nice.”

The Connecticut Supreme Court ruled in Univ. of Conn. v. Freedom of Info. Comm’nr that public agencies can create trade secrets entitled to protection from disclosure under FOIA. This seems like a pretty big deal.

Finally, the 9th Circuit issued an interesting case that dealt with wildlife management and press rights. The court remanded a case back to the district court to determine whether the public had a First Amendment right of access to the Bureau of Land Management’s wild horse roundups and, if so, whether the viewing restrictions were narrowly tailored to serve the government’s overriding interests. Leigh v. Salazar. The opinion doesn’t mention what they do with the horses when they round them up–I’m not sure I want to know.

Enjoy your weekend, everyone.

Whitey Bulger’s Defense Lawyers Want Time “to Review a Tsunami’s Worth” of Material

2012-02-13T20:13:01Z

Whitey Bulger, the indicted and apprehended alleged ringleader of Boston’s notorious ‘Winter Hill Gang’ organized crime family, needs “a reasonable amount of time to review a tsunami’s worth of discovery,” according to Bulger’s defense lawyers J.W. Carney, Jr. and and Henry B. Brennan.

The statement was made in a filing with the Massachusetts federal court this morning (read the legal filing below).

Just how much material?

According to Bulger’s defense attorneys, they need to review roughly 580,000 pages of documents and 921 government wiretaps, “with only a few transcribed.” Reviewing 2.5 wiretaps a day, every day of the year (including weekends) — focusing on nothing else — still wouldn’t be enough time, and would not even cover the 580,0000 pages of documents

Bulger’s attorneys’ request for a “reasonable amount of time” appears to be just that: a reasonable request given the number of witnesses, documentation, electronic evidence, and more.

THey also hint that at least one defense strategy will be to probe “the FBI regarding its relationship with” Bulger.

You can read Whitey Bulger’s indictment here:

Third Superseding Indictment (U.S. v. Bulger, et al.)

See Bulger’s defense lawyer’s request for more time to prepare for trial here:

Defendant’s Memorandum Regarding Estimated time Required to Review and Analyze Discovery (U.S. v. Bulger, et al.)

Writer’s Picks

2012-02-10T18:56:59Z

This was kind of a slow week for our Daily Summary writers, but we did have a blockbuster from the 9th Circuit Court of Appeals: Perry v. Brown. This case involved Proposition 8, which amended the California state constitution to eliminate the right of same-sex couples to marry. The 9th Cir. chose to address the constitutionality of Prop. 8 and declined to address the broader question of whether same-sex couples had the right to marry. As a preliminary matter, the 9th Cir. held that proponents of the ballot measure had standing. The 9th Cir. held that Prop. 8 was unconstitutional because it violated the Equal Protection Clause by targeting a minority group and withdrawing a right that the group possessed without a legitimate reason for doing so. The court also affirmed the denial of a motion to vacate former Chief Judge Walker on the basis of his purported interest in being allowed to marry his same-sex partner.

The mainstream media extensively covered this case — for more information, check out the New York Times article.

The Iowa Supreme Court ruled on the First Amendment and its Free Exercise clause in Mitchell County v. Zimmerman. This case involved a Mennonite resident whose religion forbade the use of steel cleats on tires of his tractor wheels, which conflicted with a local county ordinance requiring them. The Iowa Supreme Court held that the ordinance as applied to church members violated the free exercise clause of the First Amendment where the ordinance (1) was not of general applicability because it contained exemptions that were inconsistent with its stated purpose of protecting Mitchell County’s roads; and (2) did not survive strict scrutiny because it was not the least restrictive means of serving what was claimed to be a compelling governmental interest in road protection.

In Holt v. 2011 Legislative Reapportionment Comm’n, the Pennsylvania Supreme Court considered the issue of redistricting. A state official had sued the official commission charged with redistricting. The court issued, as our writer Leslie tells us, “an incredibly long opinion that points to the simplest answer: ‘this is a good start, but try again.’”

Finally, the U.S. Court of Appeals for the Federal Circuit issued an opinion on a patent matter for AstraZeneca, the makers of Crestor. In AstraZeneca Pharmaceuticals, L.P. v Apotex Corp., the Court held for defendant generic manufacturers on the grounds that Plaintiff failed to state a 35 U.S.C. 271(e)(2) claim based on defendants’ existing ANDA filings, and claims premised on presumed future labeling amendments were not ripe for adjudication.

Prop. 8 Unconstitutional, Federal Appeals Court Rules

2012-02-07T18:50:19Z

Proposition 8 (‘Prop 8′), the California voter amendment that sought to ban same-sex marriages in the state is unconstitutional, the U.S. Court of Appeals for the Ninth Circuit ruled in a 128-page opinion issued this morning.

You can read the complete decision below:

Download PDF

Opinion (Perry v. Brown)

Writer’s Picks: The Stolen Valor Act, Sarah Palin email hacker, and more

2012-02-06T21:56:23Z

Here are some of last week’s highlights from our Daily Opinion Summaries writers.

US v. Strandhof, US Ct. App. 10th Cir., 1/27/12
The 10th Circuit Court of Appeals upheld the Stolen Valor Act (18 U.S.C. 704(b)) which makes it illegal to falsely claim to have received a military award or honor. The district court found that appellant’s false claims to a Purple Heart, Silver Star, and rank of Marine Corps captain were protected by the First Amendment, but the 10th Circuit relied on SCOTUS precedent to overturn that ruling.

Wipf v. Hutterville Hutterian Brethren, Inc., 2012 S.D. 4
In a ruling involving the separation of church and state, the Court refused to dissolve a corporation in a Hutterite community, holding that the underlying religious controversies over church leadership so pervaded the dissolution of the religious corporation that the dissolution required an unconstitutional entanglement in a religious dispute and was beyond a secular court’s jurisdiction.

Fowlkes v. Thomas, U.S. Ct. App 2nd Cir. (01/31/2012)
The Second Circuit, interpreting the 2009 No Social Security Benefits for Prisoners Act, Pub. L. No. 111-114, 123 Stat. 3029, denied retroactive supplemental social security benefits that plaintiff allegedly was owed. The law bars the SSA from making any payment to an incarcerated individual covered by the Act, regardless of when the underlying obligation to pay the individual arose.

United States v. Kernell, U.S. Ct. App. 6th Cir, 1/30/12.
In this case, the court upheld the conviction of the man accused of hacking Sarah Palin’s email account. He was charged with identity theft, but only convicted of obstruction of justice, 18 U.S.C. 1519. Section 1519, part of the Sarbanes-Oxley Act of 2002, prohibits knowing destruction or alteration of any record with intent to impede, obstruct, or influence investigation of any matter within the jurisdiction of any federal department or agency or in relation to or in contemplation of any such matter or case.

What I Learned From Facebook’s S-1 Registration Statement

2012-02-02T08:09:37Z

Today, Facebook, Inc. filed a Form S-1 Registration Statement [PDF] with the U.S. Securities and Exchange Commission in preparation for its initial public offering. Here are some observations from reading this interesting filing.

Billion with a B. Companies that manufacture and sell tangible products are easy to understand. For a company like Facebook, you may be scratching your head wondering if they are making any money at all. In 2011, Facebook reported $1 billion in net income from $3.7 billion in revenue.

Beware of Trolls. Facebook lists patent trolls as a potential risk factor: “[V]arious ‘non-practicing entities’ that own patents and other intellectual property rights often attempt to aggressively assert their rights in order to extract value from technology companies.”

Dislike. If Facebook had a dislike button, China, Iran, North Korea, and Syria would certainly be the target of its disaffection. All of these countries have past or current restrictions on accessing Facebook.

FacebookVille. Last year, Zynga accounted for about 12% of Facebook’s revenue, “which amount was comprised of revenue derived from payments processing fees related to Zynga’s sales of virtual goods and from direct advertising purchased by Zynga.” Since Facebook had revenues of $3.711 billion in 2011, the Zynga-related share was $445 million. That’s a lot of ads or virtual goods.

Dual Class Shares. Following in the footsteps of Google and LinkedIn, Facebook has also adopted a dual class structure. Under this structure, Class B common stock has ten votes per share. Class A common stock, which is being offered in the initial public offering, only has one vote per share.

Facebook Ads. In 2011, almost 85% of Facebook’s revenues came from advertising. If you never click on Facebook ads because you have not found them to be relevant, then you are sharing the wrong information on Facebook.

Download PDF

Justia’s Top 10 Lists for January 2012

2012-02-01T05:02:55Z

Here is a rundown of January’s highest scoring lawyers on Justia Legal Answers, along with a look at which Justia Dockets legal filings and Facebook posts readers viewed the most.

Justia Legal Answers’ Top 10 Legal Answerers for January 2012

Jeffrey Moore, 3050 points, 61 answers
Brian D. Lerner, 1,395 points, 33 answers
Andrew Bresalier, 1,100 points, 36 answers
David Philip Shapiro 980 points, 20 answers
Don Richardson, 360 points, 8 answers
Paula Jeanette McGill, 350 points, 7 answers
Scott Charles MacCabe 350 points, 7 answers
Terrence Rubino, 325 points, 7 answers
Jason F. Barnes, 300 points, 6 answers
Kathryn L. Hudson, 200 points, 4 answers

The Top 10 Legal Filings Viewed in Justia Dockets in January 2012

A decision denying Southwest Airlines and its pilots union from transferring a pilot’s wages and benefits lawsuit from Florida to Texas.
A January 2010 federal court opinion concluding that the FDA lacked authority to regulate e-cigarettes
A consumer class-action lawsuit against Symantec alleging that some of the company’s software products are “scareware” that “does not conduct any actual diagnostic testing” on the computer.
A court opinion in a sonar fish and underwater structure detection patent case.
The December 6, 2011 supplemental case management order in a patent lawsuit involving Kelora Systems, LLC
An opinion and order in a patent case involving a self-described “patent licensing and enforcement firm.”
The court opinion holding that Rick Perry and other GOP presidential candidates waited to long to challenge the constitutionality of the state’s 10,000 signature requirement to appear on the ballot.
A court order in the hotly contested video game licensing dispute between Too Human creator Silicon Knights, Inc. and Epic Games, Inc.
An order in a sex discrimination and retaliation case involving claims under federal and Illinois state law.
The decision by a federal judge in the District of Columbia to dismiss a pro se plaintiff’s complaint against former President George Bush, and other defendants.

Our Top 10 January 2012 Facebook Posts:

A new Florida abortion bill (HB 1151) would outlaw all abortions except if a mother’s life is at risk.
Not surprisingly, the U.S. Supreme Court’s recent decision that the police may not engage in GPS tracking of suspects without a search warrant was widely read.
Our friends pondered whether SOPA & PIPA would be completely sunk or just ‘compromised?’
Justia jurors had a lot to say about whether alimony laws should be changed.
Folks were interested to learn about a key SOPA sponsor who reportedly violated copyright law.
Yes, Big Brother was watching when the DHS paid a contractor $1.16M to monitor social networks and blogs for public dissent
Readers extended sympathy and surprise when a Carnival-owned cruise ship capsized when it ran aground off the Italian coast.
Should Internet access be a fundamental human right? Our friends had many different answers the question.
Interest over Gov. Scott Walker recall petition filed by Wisconsin residents was huge.
Justia friends shared their thoughts about the indefinite detention of military tribunal suspects.

Thanks again for visiting.

Writer’s Weekly Picks

2012-01-27T23:10:19Z

Our Daily Opinion Summaries writers chose these cases to highlight this week.

From the U.S. Court of Appeals for the 5th Circuit, we have In Re FEMA Trailers Formaldehyde Products Liability Litigation (1/23/12). This case is about the “toxic trailers” issued by FEMA in the wake of Hurricanes Katrina and Rita. Plaintiffs sued under the Federal Tort Claims Act for injuries related to their exposure to formaldehyde in the trailers, but the Court held that the voluntary, cost-free provision of the trailers to disaster victims was immunized conduct under the FTCA, and affirmed the district court’s motion to dismiss for lack of subject-matter jurisdiction.

From the U.S. Court of Appeal for the 10th Circuit comes SECSYS, LLC v. Vigil (1/23/12). This corruption case involves government officials in New Mexico. In it, the plaintiff sued for discrimination because they were denied a bid-rigged contract, since they would not pay the full “allegedly extortionate demand.” The Court in this case affirmed the district court’s dismissal of plaintiff’s case.

The Maine Supreme Court issued an interesting insurance opinion this week. In Cookson v. Liberty Mut. Fire Ins. Co. (1/24/12), plaintiff lost his tractor to fire. He held two insurance policies from Liberty Mutual, one for his primary residence and one for a property where he was constructing a house. He would drive his tractor between the two properties. Liberty Mutual denied the claim based on a personal property exclusion in both policies. The plaintiff sued, and the superior court held for Liberty Mutual. The Supreme Court affirmed, holding (1) Cookson’s tractor was not the type of vehicle that fell within the limited exception for “vehicles not subject to motor vehicle registration” to the otherwise broad personal property exclusion of all “motor vehicles or all other motorized land conveyances,” and (2) Cookson’s tractor was not the type a homeowner would commonly purchase and employ simply to service his or her residence.

Finally, in Otay Mesa Prop. v. United States (1/25/12), the U.S. Court of Appeal for the Federal Circuit held that a government easement on the plaintiff’s private property, used for border patrol purposes, was a temporary, rather than permanent taking. The land use included creating new roads, constructing a permanent tented structure, and installing underground motion-detecting sensors. Does Jan Brewer know about this?

Retired Players Battle the NFL on Eve of Super Bowl

2012-01-26T23:21:19Z

Some football players consider concussions to be part of the game, much like sprains, strains, and other common football injuries. When the San Francisco 49ers benefitted from a collision that sent New Orleans Saints running back Pierre Thomas out with a concussion, its players characterized the hit as an effective way to send a message. However, when an opposing team reportedly targeted a 49er wide receiver with a history of concussions, the perspective of the local media changed.

While some players are willing to hide their concussions, such decisions bear long-term consequences, as seen in the numerous complaints recently filed by retired NFL players.

In the complaints, the players alleged that the NFL was aware of “the risks of permanent brain damage from repetitive concussions,” but chose to ignore and conceal them from the players. Such traumatic brain injuries can cause “severe cognitive problems such as depression and early-onset dementia” as well as Chronic Traumatic Encephalopathy (CTE), which is associated with “memory loss, confusion, impaired judgment, paranoia, impulse-control problems, aggression, depression, and eventually progressive dementia.”

Repeated concussion can not only shorten player careers, but also lives. We should keep this in mind when we are watching the Super Bowl next week and cheering after a big defensive hit.

Writer’s Weekly Picks

2012-01-20T19:43:45Z

Here’s a round-up of interesting cases from this week, as reported by our Daily Opinion Summary writers.

From the US Court of Appeals for the 10th Circuit, Ochoa v. Workman, which looked at the Atkins standard of mental retardation in a capital case. In that case, the petitioner argued that the trial court erred in applying the Atkins test to his mental condition at the time of trial instead of at the time of the crime. The Court denied his petition.

From the Supreme Court of Rhode Island, we have Higgins v. R.I. Hosp.

This case offered an interesting application of the firefighter’s rule, which bars public-safety officials from “maintaining a negligence action against a tortfeasor whose alleged malfeasance is responsible for bringing the officer to the scene of [an]…emergency where the officer is injured.” The plaintiff here brought a patient to the hospital while working as an EMT/firefighter. After he delivered his patient, he assisted a nurse with a disorderly patient, who seriously injured the plaintiff. The district court and Supreme Court found the firefighter’s rule barred the plaintiff’s recovery even though the plaintiff’s injury did not arise from the same circumstances that originally brought him to the scene.

Laura, the writer who reviewed this case, noted that “the Court didn’t mention any public policy issues surrounding this decision. If I were a dissenting judge, I sure would have.”

Paige v. DEA, from the D.C. Court of Appeals, presents an amusing fact pattern. In that case, a DEA agent shot himself in the leg while giving a gun safety presentation to children and their parents. A video depicting the incident was released on the internet and on the DEA’s email system. The agent sued, alleging violations under the Privacy Act and the Federal Tort Claims Act. The court held that his claim failed under the Privacy Act because the video was not part of a system of records – an element of the act. The FTCA claim also failed because he did not establish all of the elements under Florida law for the tort of invasion of privacy by public disclosure of a private fact.

The United States Supreme Court released an opinion in a much anticipated intellectual property case, Golan v. Holder. In it, the Court upheld section 514 of the Uruguay Round Agreements Act (URAA) which removed literary and artistic works from the public domain, now making them subject to copyright protection. The court held that section 514 did not exceed Congress’ authority under the Copyright Clause and did not violate the First Amendment rights of anyone who previously had access to such works.

The US Court of Appeals for the 7th Circuit issued an opinion that touched on religious freedom and prisoners’ rights. In Grayson v. Schuler, the Court allowed a 42 USC 1983 action against a prison official to proceed. A former inmate sued an officer who ordered forcible shearing of plaintiff’s dreadlocks, despite plaintiff’s claim that they were part of his religious observance. Illinois inmates are allowed to have any length of hair that does not create a security risk, but the officer told plaintiff that only Rastafarians were allowed to have dreadlocks, and the court found this was a case of “outright arbitrary discrimination.”

Laurel, the writer who covered this case, notes that it included a photo of the late great Bob Marley.

Dr. Martin Luther King, Jr. Plaque at the Lincoln Memorial

2012-01-17T00:55:25Z

A few years ago, I was visiting Washington, D.C. and stopping by the usual tourist attractions, when I came across this plaque dedicated to Dr. Martin Luther King, Jr.

Located on the steps of the Lincoln Memorial, this plaque commemorates the I Have a Dream speech delivered by Dr. King during the March on Washington for Jobs and Freedom.

This plaque is a fairly recent addition to the National Mall. Public Law 106-365 which provides for the placement of the plaque at the Lincoln Memorial was passed by Congress in 2000 and signed into law by President Clinton on October 27, 2000.

Public Law 106-365
106th Congress

An Act

To provide for the placement at the Lincoln Memorial of a plaque commemorating the speech of Martin Luther King, Jr., known as the “I Have A Dream” speech.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. PLACEMENT OF PLAQUE AT LINCOLN MEMORIAL.

(a) In General.–The Secretary of the Interior shall install in the area of the Lincoln Memorial in the District of Columbia a suitable plaque to commemorate the speech of Martin Luther King, Jr., known as the “I Have A Dream” speech.

(b) Relation to Commemorative Works Act.– The Commemorative Works Act (40 U.S.C. 1001 et seq.) shall apply to the design and placement of the plaque within the area of the Lincoln Memorial.

SEC. 2. ACCEPTANCE OF CONTRIBUTIONS.

The Secretary of the Interior is authorized to accept and expand contributions toward the cost of preparing and installing the plaque, without further appropriation. Federal funds may be used to design, procure, or install the plaque.

Approved October 27, 2000.

The plaque was unveiled during a ceremony at the Lincoln Memorial on August 22, 2003.

Writer’s Weekly Picks

2012-01-20T19:31:35Z

As you may know, Justia provides free daily opinion summaries for all state supreme courts and the federal courts of appeal. We’ve asked our talented attorney writers to send us the most interesting, funny, or important cases they come across each week, and we’ll run them as a column here on the blog.

Awad v. Ziriax, et. al., US Ct. App. 10th Cir.
This case made the news this week, when the 10th Circuit upheld an injunction against a controversial ballot initiative in Oklahoma that would amend the state constitution to prevent courts from considering or using Sharia law. Plaintiff argued that this law would violate his rights under the Free Exercise and Establishment clause of the Constitution. The 10th Circuit found that his claims were justiciable, and upheld a preliminary injunction against the law.

Carter v. Lehi City, 2012 UT 2 (Utah Supreme Court)
Carter also involved a ballot initiative. In this case, the court allowed municipal initiatives regulating salaries and residency requirements for city employees to stand. To do so, the court repudiated the framework set forth by a previous case, Citizens Awareness Now v. Marakis, 873 P.2d 1117 (Ut. Sup. Ct. 1994).

Texas Medical Providers, et. al. v. Lakey et al., US Ct. App. 5th Cir.
This case also made national news this week, as the 5th Circuit vacated an injunction barring enforcement of a controversial consent law for abortion procedures in Texas. The law compels physicians to take and display sonogram images of the fetus, and make the patient listen to its heartbeat, explain the results of both exams, and have her sign a consent form before performing an abortion. The court held that the provisions were within the state’s power to regulate the practice of medicine and did not violate the First Amendment.

Conn v. Zacharov, US Ct. App. 6th Cir.
Finally, one of our writers pointed us to this case, with a humorous pearl of wisdom from Judge Batchelder. The judge opens the opinion, about jurisdiction over a Russian-American contract dispute, with this:

An old Russian proverb states, “If you’re afraid of wolves, don’t go into the forest.” For Appellant Richard A. Conn the proverb might well read, “If you’re afraid of the Russian legal system, don’t do business in Russia.”

It’s a Super PAC World and We Just Vote in It: Super PAC Resources & Links

2012-01-13T23:17:43Z

Super PACs a/k/a “Independent-expenditure Only Committees” . . . they seem to be all over the news these days, don’t they? These organizations, which came to fame through the 2010 Supreme Court Citizen’s United decision, garnered lots of attention right out of the gate. In 2010 alone, almost 80 super PACs emerged to spend more than $60 million to elect or defeat federal candidates. (Super PACs in Federal Elections: Overview and Issues for Congress, CRS 12/2/11). Super PACs stand to be an even bigger force this year as we head into the Presidential primaries and the general election so I thought I’d share the small collection of resources I’ve come across lately which might help us all better understand what kind of ride we might be in for in the coming months.

Decisions, Decisions

Citizen’s United v. Federal Elections Commission – The 2010 Supreme Court Opinion that started the ball rolling by allowing unlimited corporate and union spending in federal elections.

SpeechNow v. Federal Elections Commission – This ruling significantly broadened the impact of Citizens United, “extending its constitutional reasoning from campaign spending to campaign donations.” (SCOTUS Blog, Widening impact of Citizens United)

Backgrounder

CRS Report: Super PACs in Federal Elections: Overview and Issues for Congress, December 2, 2011.

Who’s Sorta Who

Presidential Super PAC Who’s Who: Sunlight Foundation Cheat Sheet

Federal Election Commission – Independent Expenditure-Only Committee Reports

Ongoing Reporting & Analysis

Sunlight Foundation – Super PACs Blog Feed

C-Span Video – Campaign Finance

SSRN Working Papers on Citizen’s United

Fight the Power

National Conference of State Legislatures – This resource looks at the 24 states that currently prohibit or restrict corporate and/or union spending on candidate elections, and includes links to specific statutes and laws.

MoveToAmend.org – This group has organized to reverse the Citizens United ruling and maintains a list of resolutions and ordinances abolishing corporate person-hood.

Montana Supreme Court Upholds Election Spending Limits – LA Times, January 4, 2012.

Read the Montana Decision

The Big Apple Lashes Out About the Citizen’s United Decision – Wall Street Journal Law Blog, January 5, 2012. The New York City Council approves a resolution opposing the Citizen’s United decision.

Read the Resolution

Are Firearms Prohibited at Federal Facilities?

2012-01-04T23:17:34Z

During the holidays, I spent a few days in the great state of Arizona visiting the Grand Canyon. I was awed by the majestic grandeur of the Grand Canyon from when the rays of sunlight first washed over the canyon walls:

to when the last embers of sunlight vanished into the night sky:

But, nothing intrigued me more than the prominent warning decal citing the US Code.

The decal reads as follows:

Warning: Firearms Prohibited
Federal law prohibits the possession of a firearm or other dangerous weapon in this Federal facility unless specifically authorized. 18 USC 930(a) possession violations are subject to fine and/or imprisonment up to one year, while 18 USC 930(b) possession violations with an intent to commit a crime are punishable by a fine and imprisonment up to five years.

While the imposing no-firearms symbol appears quite resolute, the language contained in the decal is not as firm. After all, who is “specifically authorized” to possess firearms while visiting federal facilities? Now that I’ve returned to the land of internet connectivity, let’s take a look at 18 USC 930, which is entitled Possession of firearms and dangerous weapons in Federal facilities.

18 USC 930(a) states that “Except as provided in subsection (d), whoever knowingly possesses or causes to be present a firearm or other dangerous weapon in a Federal facility (other than a Federal court facility), or attempts to do so, shall be fined under this title or imprisoned not more than 1 year, or both.”

Now, onto the all-important “except as provided” subsection. Subsection (d) lists three exceptions during which subsection (a) is inapplicable. The first one concerns federal, state and municipal law enforcement officials. The second exemption applies to federal officials and members of the Armed Forces. The last exemption applies to the rest of us: “Subsection (a) shall not apply to…the lawful carrying of firearms or other dangerous weapons in a Federal facility incident to hunting or other lawful purposes.”

Whether that exception is read narrowly or broadly by the courts is untested, and being a test case requires some constitutional fortitude.

Additional Resources:

Gun Regulations in the National Parks. From the National Park Service.
United States v. De La Cruz-Bancroft. New Mexico District Court reversed magistrate judge’s dismissal of 18 U.S.C. § 930(a) information for further fact finding to determine whether defendant’s purpose for bringing a firearm to the federal facility qualified for the 18 USC § 930(d)(3) exception. (D. N.M. 2010).

Justia’s Most Popular Onward Posts of 2011

2012-01-03T23:51:23Z

It’s that special time of year, Justia friends, when we look back and share with you the most popular Onward blog posts of 2011.

Here they are:

Super Bowl Football Pools: Are They Legal?
Who isn’t interested in football, gambling, and the law? O.K., probably a few folks out there. Elizabeth Roig’s post topped the list.
Hurricane Irene – Resources & Links
Before America’s East Coast was about to be hit by Hurricane Irene, Justia’s Cicely Wilson put together a useful list of related resources for users.
LegalZoom Faces Unauthorized Practice of Law Class Action
Our colleague Courtney Minick shared the low-down on a class action against do-it-yourself legal forms company LegalZoom in Missouri federal court, alleging that the California start-up was engaging in the unauthorized practice of law.
Illinois Adopts Public Domain Citations
We’d like to think that many of our friends were just as pleased as we were when Illinois chose to adopt a vendor-neutral citation system.
Second Chance for Ex-Offenders Act of 2011
Ken Chan shed some light on a bill introduced by Rep. Charles Rangel (Dem. – NY) that would allow certain people convicted of nonviolent sentences to petition for an expungement of their criminal records.
‘Don’t Ask, Don’t Tell’ Has Not Been Repealed
An Onward blog post last February took a look at an interesting conundrum: at the end of 2010, President Obama repealed the U.S. Military’s “Don’t Ask Don’t Tell Policy,” but in reality, the law was still in place for months later.
Little Sheba the Happy Birthday Hug Pug
It looks like Justia’s Onward friends love dogs as much as we do. That would explain why so many people helped celebrate Little Sheba the Hug Pug’s 7th birthday last year.
LexisTexas: Privatizing Access to Public Courts
Courtney Minick examined a Texas civil rights lawsuit alleging discrimination against users who didn’t want, or couldn’t afford, to use the LexisNexis File & Serve e-filing product in order to file a lawsuit, claiming that it amounted to a poll tax on litigation and denied them due process as well as equal protection under the law.
The Bluebook Online
Every law student and lawyer knows about the Bluebook, but early last year, Justia let folks know that it was accessible online.
Law Dogs – Sit, Stay, Fetch a Statute. . .
Stressed out law students could “check out” Monty, a therapy dog, from the Yale University Law Library. Maybe they’d end up being dog lawyers with canine clients in their chosen professions.

Justia – Our Most Excellent 2011

2011-12-20T21:25:52Z

It’s been a great year for us at Justia, as we hope it has been for all of our Onward readers. We thought it might be fun to re-cap (not to be confused with RECAP ) some of the various new projects, pages and products we’ve worked on in 2011.

Verdict – In mid-2011, we launched our new legal commentary and analysis web site, Verdict. Each weekday, one of our team of ten columnists provides original and informed analysis of breaking news and developments in the law. Articles from Verdict this year included John Dean’s look at The Tea Party, Neil Buchanan’s piece on tax cuts for the wealthy, Sherry Colb’s examination of whether strip searches by jail officials are constitutional, and Vik Amar and Alan Brownstein’s analysis of the recent Proposition 8 ruling by the California Supreme Court. Other great pieces covered a wide variety of topics including immigration, criminal law, civil rights, constitutional law, health care, new technologies, and U.S. politics.

Free Daily & Weekly Opinion Summaries – In 2011, we also launched Justia’s opinion summaries. The summaries are written by licensed attorneys and cover published opinions from the United State Supreme Court, the Federal Circuit Courts of Appeal and all 50 state supreme (or highest appellate) courts. You can sign up to receive daily summary newsletters by jurisdiction or, if you prefer, receive weekly summary newsletters grouped by practice area. We also created a variety of feeds which allow you to track new summaries via individual blogs, Facebook and Twitter. And announced just today, the summaries are now also available to all users of the Fastcase online caselaw database.

Facebook – This year we continued to launch more law practice and state law Facebook pages which combine links to breaking legal news, opinion summaries, legal commentary and more. To see a full list of all our Facebook pages, click here.

Google + – Justia set-up its very own Google+ page this year! You can check it out here.

Tech Law News – We recently launched our Tech Law News blog. In it, we highlight tech law stories of interest, as well as give readers a heads up on interesting new tech lawsuits and filings coming through Justia Dockets.

Universal Citation – In the Summer of 2011, we met up in Philadelphia with some of our Free Law heroes (including Peter Martin, Tom Bruce, John Joergenson, Ed Walters, John Mayer and Sarah Glassmeyer) for the first meeting of UniversalCitation.org. The group aims “to provide the organizational infrastructure needed to facilitate the adoption and use of a uniform set of media and vendor neutral citations that can be used for all American court decisions.” Courtney and I were so inspired, we began working with Justia’s engineers to insert media-neutral citation into Justia’s state codes. Courtney also wrote a post for VoxPopuLII describing our efforts.

Other 2011 Justia Highlights. . .

Our Justia Mexico teammates moved into new offices which of course means one thing: more room for bean bag chairs. . .
Justia’s Pugs, Sheba and Rio, continued to make new friends all over the world (over 150,000 and going strong!) connecting up via their Facebook page.

And now, it’s on to 2012 during which we’ll continue to work on cool new projects. Stay tuned and Happy New Year!

Congress Recruiting Founding Fathers to Save the Republic

2011-12-14T00:08:08Z

Last month, Representative Don Young of Alaska introduced the DebtPatriots.Gov Act of 2011, which calls for the creation of a website dedicated to collecting donations to reduce the public debt of the United States. The website, which will be hosted at www.DebtPatriots.gov, will collect donations and publicly recognize the patriotism of those who “are willing to contribute additional funds, above and beyond their tax obligations.”

The bill proposes several levels of donor recognition:

Corporation Award Levels

Corporate Founder ($50B).
Corporate Son of Liberty ($10B).
Corporate Constitutional Delegate ($1B).
Corporate Minuteman ($500M).
Corporate Patriot ($1M).

Individual Award Levels (Premium)

Premium Founding Father/Mother ($1B).
Premium Son/Daughter of Liberty ($500M).
Premium Constitutional Delegate ($100M).
Premium Minuteman/woman ($10M).
Premium Patriot ($1M).

Individual Award Levels

Founding Father/Mother ($100K).
Son/Daughter of Liberty ($10K).
Constitutional Delegate ($1K).
Minuteman/woman ($100).
Patriot ($10).

In lieu of real political reform, I guess this is the best that Washington, D.C. can come up with these days. However, I do wonder whether Representative Young missed the GOP memo that corporations are people. Otherwise, why create separate recognition levels for corporations and individuals?

Besides being publicly recognized on the website, donors will also receive a “signed certification of appreciation” from the President! So, for less than the cost of a private law school education, you can become a Founding Father or a Founding Mother of the republic. How will that look on your résumé?

The Re-Styled Federal Rules of Evidence

2011-12-13T00:07:17Z

I’m a little behind on this, but in September of this year, the AOC announced revisions to the Federal Rules of Evidence in the form of “re-styling.” The Judicial Conference Advisory Committee on Evidence Rules explains:

“The revision is intended to make the Evidence Rules easier to read, and to clarify, simplify, and modernize them without altering their substantive meaning,” said Judge Robert L. Hinkle (N. D. Fla). “There will be no change at all in the meaning or application of any rule. A judge or lawyer would get the right result using either a restyled rule or the old version. However, we think the chance of misunderstanding the rule is much smaller using the restyled version.”

The process began in 2007, and was released for the 2012 version of the FRE. As part of the effort, “Term usage was standardized, and the use of ambiguous words, such as “shall,” minimized along with outdated or archaic terms, intensifiers, and redundant terms and cross references. Rule numbers and citations were preserved to minimize the effects on research, but subdivisions were rearranged in some rules for greater clarity and simplicity. But terms were retained that have acquired special status from years of case law interpretation.”

Basically, the Committee tried to improve the language, make it more modern and easy to read, while retaining the substance of the enacted Rules. I think this is great — I’m all for plain English wherever possible. I downloaded CALI’s free version for the iPad and took a look. CALI’s version contains the Committee Notes, so it was pretty easy to see where changes were made in 2011. The changes are bigger than I expected, I was actually pretty impressed. Here’s what I found: If a rule was restyled, it contains the following note:

Committee Notes on Rules—2011 Amendment

The language of Rule 201 has been amended as part of the restyling of the Evidence Rules to make them more easily understood and to make style and terminology consistent throughout the rules. These changes are intended to be stylistic only. There is no intent to change any result in any ruling on evidence admissibility.

Aesthetic changes

Visually, the new rules look different (and more modern). The Committee replaced long paragraphs and run-on sentences with a cleaner outline format, offset subsections, and bullet points. The result is a rule that is quicker to digest and understand. For example, here’s Rule 201. Judicial Notice of Adjudicative Facts in 2011:

and here is the 2012 version:

Similarly, see Rule 402. General Admissibility of Relevant Evidence

2011

2012

Standardized Terms

The 2012 version standardizes some of the language in the rules, as well. This makes the rules, as a whole, more consistent and easy to understand. For example, the 2012 version replaces “Act of Congress” with “federal statutes” and “Supreme Court pursuant to statutory authority” with “ “rules prescribed by the Supreme Court.” In many places, “accused” becomes “defendant.” In Rules 413-415, the 2012 version uses the terminology in all three rules: “Permitted uses” and “disclosure to the defendant” for introducing a victim’s sexual behavior in a sex offense case.

Elimination of Redundant Terms

The restyling changed the language to make them easier to read. The 2012 version employs a more active voice, economy of words, and simpler language. Some examples:

Rule 106 changes “contemporaneously” to “at the same time.” Rule 410 changes “in the course of” to “during,” and Rule 411 changes “does not require exclusion” to “court may admit.”

Rule 301 is edited from 73 words down to 50 in 2012:

2011

2012

Even small changes can make the rules seem simpler and more current. For example, 2012’s 201(e) changes “upon timely request” to “on timely request. ”All in all, nice work by the Committee. Check out the free versions on CALI to compare for yourself.

“Paging the Pot and the Kettle” – CRS Issues Report on Secrecy and Transparency in Congressional Lawmaking

2011-12-08T20:17:22Z

From the Free Government Information Blog (by way of beSpacific) comes word that the Congressional Research Service issued a report on November 30, 2011, titled “Congressional Lawmaking: A Perspective on Secrecy and Transparency.” The 19-page report briefly outlines the history of the tension between secrecy and transparency in Congress, reviews the issues that emerged on this front during the formation of the 2011 Joint Select Deficit Reduction Committee, looks at various parts of lawmaking that are typically imbued with closed door activities, and closes with some summary observations.

All well and good, but . . . is it just me, or does anyone else find it the topic slightly ironic given that the CRS itself seems reluctant to release unclassified and non-confidential (public domain) copies of their reports in any systematic way, and no comprehensive list of these reports is even publicly available? As the first sentence of the Report notes, “Openness is fundamental to representative government.” That openness should include access these valuable public policy documents paid for with our tax dollars.

CRS Resources

CRS Reports “Uber” Archive from Archive-It

opencrs – Access and upload CRS reports here.

University of North Texas Digital Library – CRS Reports Collection

National Council for Science and the Environment – Access to CRS Reports related to the environment and other related topics.

U.S. Department of State – CRS Reports and issues briefs.

Thurgood Marshall Law Library (University of Maryland College of Law) – CRS Reports on homeland security/terrorism and health law & policy.

Federation of American Scientists – CRS Reports on national security, foreign policy and related topics.

Pearl Harbor Remembrance Day

2011-12-07T22:39:32Z

Each year, on this fateful date, we remember the sacrifices of those we lost on December 7, 1941. In observance of National Pearl Harbor Remembrance Day, President Barack Obama has issued a proclamation honoring those patriots who gave their lives in defense of our nation during the attack on Pearl Harbor. Today, we join our fellow Americans in saluting and honoring our veterans for their sacrifices. Thank you.

Here are some photos from my visit to the USS Arizona Memorial.

Don’t Send a Fruitcake to the White House

2011-12-02T18:53:52Z

Now that November is in the rear-view mirror, it is time to start planning for the upcoming holiday season. If you are having problems coming up with the perfect gift for your family members or friends, consider the plight of those who have to buy gifts for the man who has everything.

For gifts that are worthy of the Most Powerful Man on Earth, you can browse the lists of gifts received by the President (as well as other federal employees) from foreign government sources for yuletide inspiration: 1993, 1994, 1995, 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, and 2009.

However, the U.S. Constitution prohibits the President and other persons in office from accepting presents from any King, Prince or foreign State without the consent of Congress. Article I, Section 9, Clause 8. Accordingly, these gifts are disposed of pursuant to the regulations concerning the utilization, donation and disposal of foreign gifts and decorations. 41 C.F.R. § 105-42.5. Most gifts are sent to the Archives, transfered to the General Servies Administration or retained for display or official use.

Chestnuts Roasting on an Open Fire

The disposition of some gifts is discreetly described as being “handled pursuant to Secret Service policy.”

Date of Acceptance	Gift	Identity of Foreign Donor and Government
4/2/2008	Bottle of 1977 Chardonnay.	His Excellency Calin Popescu-Tariceanu, Prime Minister of Romania.
5/6/2008	Ten Fuente OpusX cigars.	His Excellency Martin Torrijos Espino President of the Republic of Panama.
7/8/2008	Bouquet of flowers and thirty-eight boxes of assorted Godiva chocolates.	His Majesty Mohammed VI, King of Morocco.
4/16/2008	Box of Rococco chocolates.	The Right Honorable James Gordon Brown, M.P., Prime Minister.
5/15/2008	Ahava Bath + Beauty set in blue AHAVA travel case.	Her Excellency Dali Itzik, Speaker of the Knesset of Israel.
3/5/2009	Four boxes of dates and twelve bottles of wine.	His Excellency Abdelaziz Bouteflika, President of the People’s Democratic Republic of Algeria.
5/28/2009	Bottle of olive oil.	His Excellency Dr. Mahmoud Abbas, President of the Palestinian Authority.

The Ronald Reagan Presidential Library explains in Presidential Gifts: Their Handling and Legal Status that “the Secret Service requires destruction of food and drink gifts, combustible items which may release fumes, and colognes and other substances that are applied to the skin.” So, while Santa may appreciate cookies and a glass of milk, don’t send a fruitcake to the White House.

12 Gifts for Less Than a Benjamin

If you are looking for gifts that will not bust the budget, how about these stocking stuffers for under $100 each.

Estimated value	Gift	Foreign donor and government
$15.00	CD: ‘‘Jazz for Quiet Moments,’’ by Greg Howard.	His Majesty Sultan Haji Hassanal Bolkiah Mu’izzaddin Waddaulah, Sultan and Yang Di-Pertuan of Brunei Darussalam.
$23.00	Household Item: small green dish.	His Excellency Sheikh Hamad bin Jassim bin Jabir Al Thani, Prime Minister of the State of Qatar.
$25.00	Book, hardcover: ‘‘Churchill: The Unexpected Hero,’’ by Paul Addison, inscribed by donor.	The Right Honorable James Gordon Brown, M.P., Prime Minister of the United Kingdom.
$30.00	Holiday Item: gold-tone beaded snowflake Christmas ornament.	His Excellency Saqr Ghobash Saeed Ghobash and Mrs. Fatima Salem, Ambassador Extraordinary and Plenipotentiary, United Arab Emirates.
$35.00	Clothing: black and gold traditional Afghan vest with white ties.	His Excellency Hamid Karzai, President of the Islamic Republic of Afghanistan.
$42.00	Athletic Equipment (2): Possum Leather True Grip Golf Gloves.	The Right Honorable Helen Clark, Prime Minister of New Zealand.
$50.00	Local vegetable floral arrangement.	Mrs. Pilar Nores de Garcia, The First Lady of the Republic of Peru, Palacio de Gobierno, Plaza de Arnas, Lima.
$50.00	Bottle of Kutjevo wine.	His Excellency Stjepan Mesic, President of the Republic of Croatia.
$55.00	Books, hardcover (2): ‘‘Stayed Tuned,’’ by Joe Garner and ‘‘1,001 Reasons to Love America,’’ by Hubert Pedroli and Mary Tiegreen.	His Majesty Sultan Haji Hassanal Bolkiah Mu’izzaddin Waddaulah, Sultan and Yang Di-Pertuan of Brunei Darussalam.
$60.00	Various chocolates, cookies, corn relish and spirited cherries.	His Majesty Sultan Haji Hassanal Bolkiah Mu’izzaddin Waddaulah, Sultan and Yang Di Pertuan of Brunei Darussalam
$89.00	Book, hardcover (in Mongolian): ‘‘Great Mongolian State.’’	His Excellency N. Enkhbayar, President of Mongolia.
$95.00	Household Item: green, beige, and red plaid lambswool blanket.	The Right Honorable James Gordon Brown, M.P., Prime Minister of the United Kingdom.

Ninth Circuit Questions for Certification – There’s A Chart for That

2011-12-01T06:10:22Z

Writ columnists Vik Amar and Alan Brownstein recently wrote an interesting article on the latest ruling in the litigation regarding Proposition 8, California’s anti-gay-marriage initiative. Using the process known as certification, the Ninth Circuit, in trying to figure out if the the proponents of Prop. 8 had standing to defend the case in federal court, asked the California Supreme Court for their input on “whether, at least as a matter of California law, initiative proponents enjoy some special capacity to represent the state’s electorate when public officials decline to defend a law adopted through direct democracy.”

This wasn’t the only case where the Ninth Circuit requested certification from the California Supreme Court. In fact, the Stanford Law School SCOCAL site has a whole chart about certification issues. This chart was created by attorneys at Hughes Hubbard and Reed (the family firm) and it tracks the questions of certification from the 9th Circuit to the California Supreme Court, with coverage from 1998 to the present, providing the text of the actual question or questions along with the associated 9th Circuit and California Supreme Court decisions. (Links to the full text of the decisions are also provided.) To learn more about the resource, check out Erika Wayne’s post from Legal Research Plus and also check out the chart, here.

Free Federal Rules E-Books from CALI and LII

2011-11-18T18:56:35Z

Our friends at CALI [Computer Assisted Legal Instruction] and Cornell LII have issued a series of helpful e-books for lawyers, law students, and anyone else who wants quick and free access to the Federal Rules. The Federal Rules of Evidence, Civil Procedure, and Criminal Procedure are available for free download on CALI’s site. The book’s are based on Cornell LII’s federal rules collection, and are current to December 2010. They include the Advisory Committee’s notes, a functioning Table of Contents, internal links and external links to the LII site. They are “DRM-free” which means you can read them on any device you choose.

This is a great free reference tool–download now!

Back to the Basics: Why Quality Blog Content Matters

2011-11-17T15:41:44Z

As cliché as it sounds, “content is king.” It goes without saying that content is one of the key elements in creating an effective and well-optimized legal blog. However, with the internet being an open forum that allows all forms of content—some quality, some not—the search engines have attempted to become smarter. When users search the web, the search engines seek to present results that are relevant and contain high quality information. Google’s “Panda” update to its complex search algorithm aimed to ensure that sites with quality content would outrank similar sites with shallow, repetitive, and unoriginal content. Thus, the core purpose of this post is to help legal bloggers understand the concept of quality content. This post will also discuss specific factors that influence the search engines in identifying content as “quality” as well as some tips to consider if you’re concerned about the quality of your blog.

So, what exactly is “quality” content? Aren’t search engines just looking for text and general information on legal matters? Why can’t I just rewrite an interesting article that someone else has published on a particular matter? After the dust began to settle on Google’s “Panda” update, many bloggers became concerned about whether their established method of blogging would cut the mustard. Google went ahead and set forth some guidelines in a post on their own Webmaster Tools blog: More guidance on building high-quality sites.

In essence, when it comes to creating quality content on your blog, it’s best to go back to the basics and tap back into the reason why you have a legal blog in the first place: to freely discuss legal matters and share your insights with the greater legal blogging community and others looking for legal information and insight. You do not have to write a full-fledged law review articles. However, you should be attempting to write substantive legal articles, which may discuss premises liability, comment on a landmark legal ruling or analyze a recent copyright decision.

More specifically, it is important for all bloggers to step outside of their own shoes and into the shoes of someone who could potentially find your blog when searching on the internet. It could be someone looking to find a lawyer knowledgeable in estate planning or it could be a fellow attorney doing legal research. No matter how they found your blog, when they get to it, and actually read it, what kind of impression will they get of you or your law firm? If the answer to this question is positive then you most likely have taken the time to develop well thought out and original articles. If not, there is always room to improve your content starting now. Here are some additional tips to focus on:

Write for people not search engines. Search engines will still find you and people won’t turn away once they get to your blog.
You should feel comfortable submitting any one of your blog posts to a print publication.
Your posts should be thoroughly proofread and free of any blatant spelling or grammatical errors.
The post is based on original research and not simply a rewrite of an existing published elsewhere.
The article goes beyond mere factual details and contains insightful analysis.

At the end of the day, if you’re spending time drafting content for blog posts it’s worth taking a few more minutes to ensure that it meets the big picture criteria for quality as outlined above. Search engine optimization is still a very important concept but the key is to not look at it in a vacuum and take it too literally. Otherwise you risk losing both the attention of the search engines as well as your actual readers. Happy blogging!

Additional Reading:

Content & Search Engine Ranking Factors

Public Domain Citation News: Colorado (re)-Joins the Band

2011-11-16T22:44:45Z

A hat tip to our friend Ed Walters over at FastCase who alerted us to the news that Colorado has proposed adopting a public domain citation format for its Supreme Court and Court of Appeals published opinions. (Yay!) By our count, this means there will now be seventeen states using some form of universal / vendor neutral citation for their court opinions.

A link to the proposal (in PDF) is here. Public comments are welcome on the proposed changes but must be in by December 12, 2011.

Some items to note:

1. The proposed format goes into effect on January 1, 2012.

2. As mentioned, the citation format covers only published opinions for the Colorado Supreme Court and the Colorado Court of Appeals.

3. Like several other vendor-neutral jurisdictions, the citation format includes three core elements: the calendar year, the state postal code abbreviation and the opinion number, e.g. “2012 CO 1” (Supreme Court), “2012 CO App 1″ (Court of Appeals).

4. Pinpoint citation will be achieved through the use of paragraph numbering. The proposal includes a description of what constitutes a “paragraph” for these purposes and provides examples of how to cite to a specific paragraph or series of paragraphs.

4. Modified, revised, or substantively amended opinions will keep the vendor-neutral citation of their original opinion, but will be marked with an “M” to indicate changes, e.g., “2012 CO 1M”. If an opinion is modified more than once, the “M” shall be followed by an appropriate Arabic number, e.g. “2012 CO 1M-2″, “2012 CO 1M-3″, etc.

5. Withdrawn opinions shall keep the vendor-neutral citation of their original opinion, but will be followed by a “W”, e.g., 2012 CO 1 W”.

It looks like Colorado did attempt to adopt a form of media-neutral citation in 1995, but to little effect. (See, “Neutral Citation, Court Web Sites, and Access to Case Law”, by Professor Peter Martin, fn. 27, (2006) ) Let’s hope this time around, especially given that the state is the official publisher of its case law, that their request that all publishers of Colorado Supreme Court and Court of Appeals materials include the vendor-neutral citation within the heading of each opinion they publish sticks. We at Justia will certainly include these citations in our online Colorado case law after the new year.

Additional Links & Resources

UniversalCitation.org – current movement to provide the organizational infrastructure needed to facilitate the adoption and use of a uniform set of media and vendor-neutral citations that can be used for all American court decisions. This site also links to lots of great resources on the history and work that’s been done in the field so far.

Universal Citation for State Codes - Courtney’s recent piece in VoxPopuLII describes Justia’s efforts to apply a system of vendor-neutral citation to all primary legal source material, starting with the state codes.

From the Onward Blog: