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Michael R. Smith*
* Winston S. Howard Distinguishe d Professor of Law and Director of Legal Writing, University of Wyoming College of Law. I would like to thank Ruth Anne Robbins of Rutgers -Camden Law School for her tremendous support on this project. I would also like to thank the faculty of Stetson Law S chool, who provide helpful comments during a presentation of this topic at a faculty colloquium. I would also like to express my appreciation to Lois Ann Smith, who provided helpful comments on earlier drafts of this article. Finally, I would like to thank Peg Howard, Joan Maclachlan, and the Winston S. Howard Distinguished Professorship endowment for providing funds in support of this article.