Second Circuit, Eastern District of Michigan, and Utah Court of Appeals Cite the ULJ

The Second Circuit recently cited to Mary Pennisi’s article, A Herculean Leap for the Hard Case of Post-Acquisition Claims: Interpreting Fair Housing Act Section 3604(B) After Modesto, in its opinion for Francis v. King Park Manor, Inc., No. 15-1823-cv, 2019 U.S. App. LEXIS 6486, at *15 n.6 (2d Cir. Mar. 4, 2019).  This article from Book 37.4 was cited as scholarship confirming that §§ 3604(b) and 3617 of the Fair Housing Act encompass post-acquisition claims.

The Eastern District of Michigan cited to a student note by Rebecca Laitman from Book 45.3Fourth Amendment Flagrancy: What It Is, and What It Is Not, in its opinion for United States v. Gordon, 346 F. Supp. 3d 999, 1007 n.7 (E.D. Mich. 2018).

The Utah Court of Appeals recently cited to Michal Gilad, Abraham Gutman, and Stephen P. Chawaga’s article from Book 46.1The Snowball Effect of Crime and Violence: Measuring the Triple-C Impact, in its opinion for Interest of C.C.W., 2019 UT App 34, ¶ 20 & n.6.