AuthorTitleCitationSummaryYearKey Terms in Title or Summary
Mary Nicol Bowman SEEKING JUSTICE: PROSECUTION STRATEGIES FOR AVOIDING RACIALLY BIASED CONVICTIONS 32 Southern California Interdisciplinary Law Journal 515 (Spring, 2023) Common rhetorical techniques used by prosecutors, even those who reject racially prejudiced beliefs, are likely to trigger jurors' implicit biases. Current case law and ethical rules set up well-intentioned prosecutors by obscuring the racial bias embedded in this rhetoric and the likely impact of coded language on jurors. In 2020, however,... 2023  
Omari Scott Simmons SELECTIVE PATRONAGE 46 Seattle University Law Review 331 (Winter, 2023) The philosophy behind the Sullivan Principles was no different from the approach I had developed in my boycott days during the height of the civil rights movement . [T]he fundamental premise behind them was that people-- individually and collectively--can and should use their economic influence to make a moral statement or to take moral action.... 2023  
Inès Zamouri SELF-DEFENSE, RESPONSIBILITY, AND PUNISHMENT: RETHINKING THE CRIMINALIZATION OF WOMEN WHO KILL THEIR ABUSIVE INTIMATE PARTNERS 30 UCLA Journal of Gender & Law 203 (Summer, 2023) C1-2Table of Contents Introduction. 204 I. Accommodation of Victims/Survivors within Available Criminal Defenses. 211 A. The Self-Defense Doctrine. 212 1. Imminence. 213 2. Reasonableness. 215 3. Proportionality. 218 4. Implicit Biases in Self-Defense. 219 B. Battered Woman Syndrome Testimony. 221 1. Contours and Relevance in the Legal Context. 221... 2023  
Barbara Ann Atwood STANDING MATTERS: BRACKEEN, ARTICLE III, AND THE LURE OF THE MERITS 23 Journal of Appellate Practice and Process 105 (Winter, 2023) The Supreme Court's grant of certiorari in Brackeen v. Haaland and consolidated petitions marks only the third time that the Court has taken up a case arising under the Indian Child Welfare Act of 1978 (ICWA). From its inception in the Northern District of Texas to the Fifth Circuit's en banc decision, the litigation has been closely watched, not... 2023  
Lyndsey K. Ebener STATE TAKEOVER IN SOUTH CAROLINA: AN INADEQUATE MEANS TO ACHIEVING "MINIMALLY ADEQUATE" EDUCATION 74 South Carolina Law Review 543 (Spring, 2023) I. Introduction. 543 II. Background. 546 A. What is State Takeover?. 546 B. Effects of State Takeover. 549 1. Student Achievement. 549 2. Poverty and Race Segregation. 550 3. Funding and Fiscal Management. 553 4. Discipline. 554 5. Availability of High-Quality Teachers. 556 C. South Carolina's State Takeover Statute. 558 III. Analysis. 561 A. South... 2023  
Sonja Starr STATISTICAL DISCRIMINATION 58 Harvard Civil Rights-Civil Liberties Law Review 579 (Summer, 2023) The Supreme Court has emphatically and repeatedly rejected efforts to justify otherwise-illegal discrimination against individuals by resort to statistical generalizations about groups. But practices that violate this principle are pervasive and largely ignored or even embraced by courts, lawyers, and law scholars. For example, many health care... 2023  
Wendy A. Bach, Mishka Terplan STOPPING CRIMINALIZATION AT THE BEDSIDE 51 Journal of Law, Medicine & Ethics 533 (Fall, 2023) Keywords: Reproductive Health, Pregnancy, Criminalization, Health Privacy, Mandatory Reporting Abstract: Low-income women and, disproportionately low-income women of color seeking reproductive and pregnancy care are increasingly subject to what this article terms carceral care-- care compromised by its' proximity to punishment systems. This article... 2023  
Yiran Zhang SUBSIDIZING THE CHILDCARE ECONOMY 34 Stanford Law and Policy Review 67 (2023) This Article studies how government childcare subsidies redistribute resources and values among children, parents, providers, and their workers engaged in diverse forms of childcare. Formal centers provide developmentally beneficial care in a regulated setting but are detached from supporting the children's families. Home-based care often occurs... 2023  
Christian Powell Sundquist SURVEILLANCE NORMALIZATION 58 Harvard Civil Rights-Civil Liberties Law Review 117 (Winter, 2023) Since the start of the COVID-19 pandemic, the government has expanded public surveillance measures in an attempt to combat the spread of the virus. As the pandemic wears on, racialized communities and other marginalized groups are disproportionately affected by this increased level of surveillance. This article argues that increases in public... 2023  
Claire E. Remillard TELEHEALTH IS HERE TO STAY: WHY MEDICAID SHOULD PERMANENTLY REQUIRE STATES TO OFFER MENTAL HEALTH SERVICES THROUGH TELEHEALTH 23 Journal of High Technology Law 363 (2023) A troublesome image: a global pandemic threatening the health of you and your loved ones, an over-crowded apartment with stir-crazy children, bills piling up, the peak of stressful family dynamics, job and income insecurity. For many Americans, this scenario was reality during the COVID-19 pandemic. Navigating everyday life during an ever-evolving... 2023  
Etienne C. Toussaint THE ABOLITION OF FOOD OPPRESSION 111 Georgetown Law Journal 1043 (May, 2023) Public health experts trace the heightened risk of mortality from COVID-19 among historically marginalized populations to their high rates of diabetes, asthma, and hypertension, among other diet-related comorbidities. However, food justice activists call attention to structural oppression in global food systems, perhaps best illuminated by the... 2023  
Sarah Schindler, Kellen Zale THE ANTI-TENANCY DOCTRINE 171 University of Pennsylvania Law Review 267 (January, 2023) The law has failed tenants. A range of distinct legal doctrines, coupled with structural inequities, systematically disadvantage tenants in previously unrecognized ways. This Article identifies a new way of looking at this pattern of collective impediments to tenants' rights, wealth, and power, which we call the Anti-Tenancy Doctrine. This... 2023  
Duncan Kennedy THE BITTER IRONIES OF WILLIAMS v. WALKER-THOMAS FURNITURE CO. IN THE FIRST YEAR LAW SCHOOL CURRICULUM 71 Buffalo Law Review 225 (April, 2023) This Article is about the famous contracts case of Williams v. Walker-Thomas Furniture Company, decided in 1965 in the U.S. Court of Appeals for the District of Columbia with an opinion by Judge J. Skelly Wright. Ora Lee Williams, the appellant, was Black and, according to the brief, was a person of limited education and separated from her husband... 2023  
Michael Conklin , Angelo State University, San Angelo, TX, USA, Email: michael.conklin@angelo.edu THE CASE AGAINST RACE-BASED QUOTAS IN PHARMACEUTICAL TRIALS 49 American Journal of Law & Medicine 1 (2023) This Article is the first to offer a comprehensive case against using racial quotas in pharmaceutical studies by providing a detailed examination of the arguments for and against the practice. It begins by discussing the current racial classification system, calls for racial quotas in pharmaceutical trials, and the troubling history of combining... 2023  
Madalyn K. Wasilczuk THE CLINIC AS A SITE OF GROUNDED PEDAGOGY 29 Clinical Law Review 405 (Spring, 2023) Legal education tends to focus on teaching students federal law from hefty casebooks, inculcating the ability to think like lawyers. In a sea of Socratic lectures and hypotheticals, students often take refuge in clinics as an island of practical skills-building, client centeredness, and individual fulfillment. Yet even clinics sometimes fail to... 2023  
Trevor George Gardner THE CONFLICT AMONG AFRICAN AMERICAN PENAL INTERESTS: RETHINKING RACIAL EQUITY IN CRIMINAL PROCEDURE 171 University of Pennsylvania Law Review 1699 (June, 2023) This Article argues that neither the criminal justice reform platform nor the penal abolition platform shows the ambition necessary to advance each of the primary African American interests in penal administration. It contends, first, that abolitionists have rightly called for a more robust conceptualization of racial equity in criminal procedure.... 2023  
Aziz Z. Huq THE COUNTERDEMOCRATIC DIFFICULTY 117 Northwestern University Law Review 1099 (2023) Abstract--Since the 2020 elections, debate about the Supreme Court's relationship with the mechanisms of national democracy has intensified. One important thread of that debate focuses critically on the possibility of a judicial decision flipping a presidential election or thwarting the will of national majorities respecting progressive... 2023  
Michelle Y. Ewert THE DANGERS OF FACIAL RECOGNITION TECHNOLOGY IN SUBSIDIZED HOUSING 25 NYU Journal of Legislation and Public Policy 665 (2022-2023) The use of facial recognition technology (FRT) in subsidized housing makes life more difficult for subsidized tenants, who are disproportionately women, seniors, and people of color. Conditioning building access on facial recognition is problematic because flaws in the technology make it hard for systems to recognize people with darker skin, women,... 2023  
Anna Arons THE EMPTY PROMISE OF THE FOURTH AMENDMENT IN THE FAMILY REGULATION SYSTEM 100 Washington University Law Review 1057 (2023) Each year, state agents search the homes of hundreds of thousands of families across the United States under the auspices of the family regulation system. Through these searches--required elements of investigations into allegations of child maltreatment in virtually every jurisdiction--state agents invade the home, the most protected space in... 2023  
Tooba Naveed THE END OF SINGLE-FAMILY ZONING IN CALIFORNIA: HOW CHAPTER 162'S IMPACT IS MORE SYMBOLIC THAN TRANSFORMATIVE 54 University of the Pacific Law Review 168 (May, 2023) Code Sections Affected Government Code §§ 66452.6 (amended), 65852.21, 66411.7 (new) SB 9 (Atkins); 2021 Stat. Ch. 162 C1-2Table of Contents I. Introduction. 169 II. Legal Background. 170 A. Not in My Neighborhood: How Restrictive Covenants and Zoning Laws Shaped California's Neighborhoods. 171 B. The Supreme Court Ensures Parasites Stay Out of... 2023  
Paul J. Larkin , GianCarlo Canaparo THE FALLACY OF SYSTEMIC RACISM IN THE AMERICAN CRIMINAL JUSTICE SYSTEM 18 Liberty University Law Review 1 (Fall, 2023) Critics of the criminal justice system have repeatedly charged it with systemic racism. It is a tenet of the war on the War on Drugs, it is a justification used by the so-called progressive prosecutors to reject the Broken Windows theory of law enforcement, and it is an article of faith of the Defund the Police! movement. Even President... 2023  
Kathryn A. Sabbeth, Jessica K. Steinberg THE GENDER OF GIDEON 69 UCLA Law Review 1130 (January, 2023) This Article makes a simple claim that has been overlooked for decades and yet has enormous theoretical and practical significance: the constitutional guarantee of counsel adopted by the U.S. Supreme Court in Gideon v. Wainwright accrues largely to the benefit of men. In this Article, we present original data analysis demonstrating that millions of... 2023  
Amelia Tidwell THE HEART OF THE MATTER: ICWA AND THE FUTURE OF NATIVE AMERICAN CHILD WELFARE 43 Journal of the National Association of Administrative Law Judiciary 126 (Spring, 2023) The United States has a long and tragic history of removing Native American children from their homes and culture at shocking rates. Congress passed the Indian Child Welfare Act (ICWA) in 1978 in response to that crisis and many states have bolstered the Act with state legislation and tribal-state agreements, but racial disparities are still... 2023 Yes
Berta Esperanza Hernández-Truyol THE HUMAN ENVIRONMENT: AWAKENING TO THE INDOMITABLE CUBAN SPIRIT-- GOVERNMENT, CULTURE, AND PEOPLE 17 FIU Law Review 563 (Spring, 2023) I. Introduction. 563 II. Government. 566 III. Culture. 580 A. Race. 583 B. Sex/Gender. 589 C. LGBTQ. 591 IV. The Cuban People/La Gente Cubana. 594 V. Conclusion. 606 2023  
Akil Roper , Shivi Prasad THE IMPACT AND CONSEQUENCES OF TRUE POVERTY ON ACCESS TO JUSTICE 340-FEB New Jersey Lawyer, the Magazine 54 (February, 2023) Legal representation by a licensed attorney, and ultimately justice, are denied to the poor in far too many critical civil legal cases. Social science studies reveal that those in poverty will have lawyers for just 8% (or less) of the civil legal problems they face. And, the problems they face go the very heart of their existence, often with grave... 2023 Yes
Mariya Denisenko THE IMPACT OF GOVERNMENT SPONSORED SEGREGATION ON HEALTH INEQUITIES: ADDRESSING DEATH GAPS THROUGH REPARATIONS 80 Washington and Lee Law Review 1687 (Fall, 2023) Government sponsored segregation of urban neighborhoods has detrimentally impacted the health of Black Americans. Over the last century, federal, state, and local governments have promulgated racist laws and policies that shaped the racial divide of communities in major metropolitan cities. This divide has contributed to poor health outcomes and... 2023  
Rebecca Horwitz-Willis , Leanna Katz THE INTERDEPENDENCE OF FAMILY, STATE, AND MARKET: CHILDCARE IN THE SHIFTING LANDSCAPE OF THE COVID-19 PANDEMIC 30 Georgetown Journal on Poverty Law and Policy 405 (Spring, 2023) In response to the first wave of the COVID-19 pandemic, the U.S. federal and state governments enacted various supports for childcare, including expanded funding and flexibility for the childcare market, expanded paid leave, more generous and inclusive unemployment insurance, loans available to childcare providers, and tax rebates. In this Article,... 2023  
Adam J. Mikell THE INVISIBLE DANGER IN PLAIN SITE: ENDING THE PRACTICE OF BUILDING HOUSING IN EXPOSURE ZONES 41 Minnesota Journal of Law & Inequality 191 (Summer, 2023) Safe, affordable housing is a basic necessity for every family. Without a decent place to live, people cannot be productive members of society, children cannot learn, and families cannot thrive. Adequate housing, or the lack thereof, affects every person every day. At its core, housing is a fundamental human need with inelastic demand, yet for... 2023  
Rose Holden Vacanti Gilroy THE LAW OF ASSISTED REPRODUCTIVE TECHNOLOGIES FOR LGBTQ+ PARENTS: A RECOGNITION REGIME OF FAMILY LAW BUILT IN OPPOSITION TO THE REGULATORY REGIME 38 Berkeley Journal of Gender, Law & Justice 109 (2023) Introduction. 109 I. Parentage in Opposition. 115 A. Race, Racism, and Parentage. 115 B. Wealthy Parents vs. Impoverished Parents. 119 C. Children as Success vs. Children as Failure. 122 D. Married Parents vs. Unmarried Parents. 124 II. Intended Parents and the Weaponization of Parentage. 126 A. Intent-Based Parentage Through Voluntary... 2023  
Tonja Jacobi , Riley Clafton THE LAW OF DISPOSABLE CHILDREN: DISCIPLINE IN SCHOOLS 2023 University of Illinois Law Review 1123 (2023) With almost no jurisprudence from the Supreme Court constraining schools' discretion in disciplining schoolchildren, it has been left to the states to define the constitutional boundaries of school practices that include exclusion, isolation, and physical restraint. But overwhelmingly, states defer to schools to set their own rules on disciplinary... 2023  
India M. Whaley THE LONG VOYAGE HOME 19 South Carolina Journal of International Law & Business 211 (Spring, 2023) This research paper (Paper) examines the international, constitutional, legal history, and current rights to housing in the United States (U.S.), Jamaica, and South Africa. This Paper addresses the federal and sub-national systems regarding affordable housing initiatives that drive policies associated with poverty and homelessness. Moreover, the... 2023  
Vincent M. Southerland THE MASTER'S TOOLS AND A MISSION: USING COMMUNITY CONTROL AND OVERSIGHT LAWS TO RESIST AND ABOLISH POLICE SURVEILLANCE TECHNOLOGIES 70 UCLA Law Review 2 (June, 2023) The proliferation and use of technology by law enforcement is rooted in the hope that technological tools can improve policing. Improvement, however, is relative. Quantitative data and qualitative experience have proven the criminal legal system a site of racial injustice and rank brutality. Police are one of the principal instruments of those... 2023  
Josh Gupta-Kagan , Christopher Church , Melissa Carter , Vivek Sankaran , Andrew Barclay THE NEW ORLEANS TRANSFORMATION: FOSTER CARE AS A RARE, TIME-LIMITED INTERVENTION 27 Lewis & Clark Law Review 417 (2023) This Article offers an initial evaluation of one reformed child protection system--New Orleans, Louisiana--and describes how a system that dramatically reduces the number of children in foster care might look. This system shows how a major metropolitan area can shrink its daily population of children in foster care to the low double digits, which... 2023  
Gillian R. Chadwick THE NONCITIZEN PARENT TRAP: HOW ABUSE VICTIMS BECOME STUCK BETWEEN FAMILY COURT AND IMMIGRATION LAW 71 University of Kansas Law Review 621 (May, 2023) Sonia was a 23-year-old artist who was born and raised in Santo Domingo. She met a 27-year-old American named Brett while he was making a documentary in the Dominican Republic. Brett and Sonia began dating. Brett was immediately infatuated with Sonia and began going to great lengths to court her. Brett's parents were wealthy, and he was able to... 2023  
Aziz Z. Huq THE PRIVATE SUPPRESSION OF CONSTITUTIONAL RIGHTS 101 Texas Law Review 1259 (May, 2023) On September 1, 2021, Texas's abortion ban, S.B. 8, went into effect even as the constitutional right to an abortion was under siege at the Supreme Court. It not only prohibited almost all abortions after six weeks but also allowed any private party to sue those who, knowingly or unwittingly, aid or abet such procedures. Texas's law has been... 2023  
Nicole K. McConlogue THE ROAD TO AUTONOMY 75 Oklahoma Law Review 815 (Summer, 2023) Scholars, activists, and advocates have long identified the transportation gap as a significant factor contributing to race- and class-based economic and other disparities. Carlessness correlates closely with race and poverty; meanwhile, widespread disinvestment in public transit results in low-income Black and Brown people suffering a... 2023  
Fredrick E. Vars THE SLAYER RULE: AN EMPIRICAL EXAMINATION 48 ACTEC Law Journal 201 (Spring, 2023) Elmer Palmer murdered his grandfather. The undisputed motive was money. The grandfather's will included a large gift to Elmer, which the grandfather was poised to eliminate. Elmer acted first. Under the law at the time, Elmer would inherit despite having intentionally killed his grandfather: the existing will controlled. Unfortunately for Elmer,... 2023  
Heather Swadley THE STRUCTURAL HARMS OF PROVIDING MENTAL HEALTH SERVICES THROUGH THE BIPARTISAN SAFER COMMUNITIES ACT 102 Nebraska Law Review 52 (2023) Many have proclaimed that the Bipartisan Safer Communities Act is the most sweeping gun control legislation to be passed in decades. However, the bill is not primarily a gun control bill--instead, much of the Act seeks to improve mental health services in hopes of preventing gun violence. Such a move is not rooted in established evidence, which... 2023  
Emily Suski THE TWO TITLE IXS 101 North Carolina Law Review 403 (January, 2023) Title IX, a law that mandates equality, operates unequally. Title IX prohibits sex discrimination of all forms, including sexual harassment, in public schools. When students assert Title IX sexual harassment claims, one standard exists for determining Title IX's violation. The Supreme Court held that schools violate Title IX when they respond with... 2023  
Mariela Olivares THE UNPRAGMATIC FAMILY LAW OF MARGINALIZED FAMILIES 136 Harvard Law Review Forum 363 (April, 2023) In her excellent article Pragmatic Family Law, Professor Clare Huntington argues that divisive issues roiling U.S. politics, law, and society--such as abortion rights, gender-affirming health care for children, and parental involvement in and control over public school curricula regarding race and identity--have put a spotlight on family law. She... 2023  
Sarah J. Adams-Schoen THE WHITE SUPREMACIST STRUCTURE OF AMERICAN ZONING LAW 88 Brooklyn Law Review 1225 (Summer, 2023) When I began this research project in the summer of 2021, those who lived in the predominantly Black neighborhood where I grew up -- Portland, Oregon's Cully neighborhood--experienced a catastrophic and unprecedented heat wave at temperatures as much as 25°F higher than those who lived in Portland's restrictive, amenity rich single-family... 2023  
Darren Lenard Hutchinson THINLY ROOTED: DOBBS, TRADITION, AND REPRODUCTIVE JUSTICE 65 Arizona Law Review 385 (Summer, 2023) In Dobbs v. Jackson Women's Health Organization, the Supreme Court overruled Roe v. Wade and Planned Parenthood of Southeastern Pennsylvania v. Casey. These two cases held that the Due Process Clause of the Fourteenth Amendment encompassed a right of women to terminate a pregnancy. Roe reflected over 60 years of substantive due process precedent... 2023  
Shiv Narayan Persaud TOWARDS AN UNDERSTANDING OF CRITICAL RACE THEORY: DISPELLING FALSE CLAIMS AND MISREPRESENTATIONS 18 University of Massachusetts Law Review 79 (Winter, 2023) The Article discusses critical race theory as a paradigm shift, and further dispels the notion that it promotes a form of Marxism. With the rise of political attitudes toward seeking legislation to denounce CRT, it is incumbent upon those in legal studies to investigate and bring the value of CRT into the forefront. The purpose of this Article is... 2023  
Keith N. Hylton TWO APPROACHES TO EQUALITY, WITH IMPLICATIONS FOR GRUTTER 56 Suffolk University Law Review 47 (2023) The question what is equality?, applied to the distribution of resources across races, suggests the following answer: when there appears to be no need for a policy that focuses on improving the welfare of one race relative to another. There is another way to approach the same question: Equality is when traditionally recognized paths to... 2023  
Allison Dentinger TWO SIDES TO THE SAME COIN: HOW TENANTS AND ATTORNEYS CAN COMBINE TO WIN HOUSING JUSTICE FOR ALL 32 Journal of Affordable Housing & Community Development Law 281 (2023) One of the most destabilizing events in a person's life is coming home to find a Warrant of Eviction posted on the door. That notice indicates that the tenant's family has only days to be out of their home if they want to avoid being forced out by the eviction marshal. This is an increasing reality for low-income tenants, particularly tenants of... 2023  
Danielle Pelfrey Duryea , Peggy Maisel , Kelley Saia, MD UN-ERASING RACE IN A MEDICAL-LEGAL PARTNERSHIP: ANTIRACIST HEALTH JUSTICE ADVOCACY BY DESIGN 70 Washington University Journal of Law & Policy 97 (2023) [I]t is only by naming racism, asking the question How is racism operating here? and then mobilizing with others to actually confront the system and dismantle it that we can have any significant or lasting impacts on the pervasive racial health disparities that have plagued this country for centuries. --Camara Phyllis Jones, MD, MPH, PhD This... 2023  
Lindsay Sain Jones , Goldburn P. Maynard, Jr. UNFULFILLED PROMISES OF THE FINTECH REVOLUTION 111 California Law Review 801 (June, 2023) While financial technology (fintech) has the potential to make financial services more accessible and affordable, hope that technology alone can solve the complex issue of wealth inequality is misplaced. After all, fintech companies are still subject to the same market forces as traditional financial institutions, with little incentive to address... 2023  
Lindsay F. Wiley UNIVERSALISM, VULNERABILITY, AND HEALTH JUSTICE 70 UCLA Law Review Discourse 204 (5/27/2023) This Essay responds to two recent articles which, on the surface, appear to pull the health justice movement in different directions: Angela Harris and Aysha Pamukcu's The Civil Rights of Health and Martha Albertson Fineman's Vulnerability and Social Justice. As a framework for health law scholarship and advocacy, health justice emphasizes... 2023  
Katherine Wilkin USE WITH NO REVIEW: HOW SPECIAL USE PERMITS IN MUNICIPAL ZONING PERPETUATE ENVIRONMENTAL INJUSTICE IN FOSSIL FUEL INFRASTRUCTURE SITING 54 Columbia Human Rights Law Review 952 (Spring, 2023) C1-2Table of Contents Introduction. 954 I. The Limited Assessment of Special Use Permits and Their Role in Environmental Justice. 956 A. A Brief Overview of Environmental Justice in the United States. 957 B. Role of Land Use Planning in Environmental Justice. 959 C. Special Use Permits as a Mechanism of Municipal Zoning. 962 D. Lack of Scholarship... 2023  
Andrew Darcy USING STATE LAW TO ENFORCE "AFFIRMATIVELY FURTHER" FAIR HOUSING OBLIGATIONS: NO LONGER FITTING A SQUARE PEG IN A ROUND HOLE 29 Cardozo Journal of Equal Rights & Social Justice 593 (Summer, 2023) C1-2Table of Contents Part I: Introduction. 594 Part II: Housing Discrimination in the United States and the AFFH. 596 A. High-Level Overview of Housing Discrimination in the United States. 596 B. The Fair Housing Act and the Obligation to Affirmatively Further Fair Housing. 600 Part III: AFFH Enforcement--and Lack Thereof. 604 Part IV: New York's... 2023  
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