Wake Forest Law Review
2Apr

Judges of the Fourth Circuit – Hon. J. Michael Luttig

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By Agustin Martinez and Ashley Oldfield

Born in 1954 in Tyler, Texas,[1] former Judge J. Michael Luttig attended Washington and Lee University for his undergraduate studies.[2] After graduating with a Bachelor of Arts degree in 1976,[3] Judge Luttig worked at the U.S. Supreme Court in the Office of the Administrative Assistant to the Chief Justice from 1976 to 1978.[4] Judge Luttig then attended the University of Virginia School of Law, earning his law degree in 1981.[5]

Following law school, Judge Luttig worked in the White House during the Reagan presidency, first as special assistant to the White House Counsel and then as assistant counsel from 1981 to 1982.[6] After leaving the White House, Judge Luttig worked as a judicial law clerk for then-Judge Antonin Scalia of the U.S. Court of Appeals for the D.C. Circuit from 1982 to 1983, and then for Chief Justice Warren E. Burger of the U.S. Supreme Court from 1983 to 1984.[7] Judge Luttig continued working for Chief Justice Burger from 1984 to 1985 as his special assistant.[8]

From 1985 to 1989, Judge Luttig worked in private practice for the New York law firm Davis Polk & Wardwell.[9] He then left private practice and worked for the U.S. Department of Justice for two years,[10] serving as assistant attorney general and counselor to the attorney general.[11] During his time at the Department of Justice, Judge Luttig helped prepare Justices David Souter and Clarence Thomas for their U.S. Supreme Court nomination hearings before the Senate.[12]

In 1991, President George H.W. Bush nominated Judge Luttig to a new seat on the U.S. Court of Appeals for the Fourth Circuit.[13] The Senate confirmed him that same year.[14] At the time of his appointment to the Fourth Circuit, Judge Luttig was the youngest federal court of appeals judge in the country.[15]

Judge Luttig wrote opinions in a wide variety of areas, ranging from criminal justice to civil rights to economic and labor regulation.[16] One of his more notable opinions, which was upheld by the Supreme Court, found a section of the federal Violence Against Women Act unconstitutional,[17] holding that the necessary “nexus between violence motivated by gender animus and interstate commerce” was lacking.[18] Judge Luttig was also among the first federal appeals judges to assert that the Constitution affords inmates the right to post-conviction DNA testing.[19]

Many of Judge Luttig’s clerks went on to become clerks for justices on the Supreme Court.[20] Additionally, in 2005, Judge Luttig was considered a potential contender for a position on the Court.[21] However, John G. Roberts, Jr., was nominated for the position instead and was later confirmed as the Chief Justice of the Supreme Court.[22]

Following fifteen years on the bench, Judge Luttig resigned from the Court of Appeals in May of 2006.[23] Since then he has served as general counsel and executive vice president of The Boeing Company.[24]

  1. Luttig, J. Michael, Fed. Judicial Ctr., https://www.fjc.gov/history/judges/luttig-j-michael (last visited Apr. 2, 2019). ↑

  2. Id. ↑

  3. Id. ↑

  4. Executive Biography of J. Michael Luttig, Boeing, https://www.boeing.com/company/bios/j-michael-luttig.page (last visited Apr. 2, 2019). ↑

  5. Fed. Judicial Ctr., supra note 1. ↑

  6. Executive Biography of J. Michael Luttig, supra note 4. ↑

  7. Id. ↑

  8. Id. ↑

  9. Id. ↑

  10. Fed. Judicial Ctr., supra note 1. ↑

  11. Executive Biography of J. Michael Luttig, supra note 4. ↑

  12. Id. ↑

  13. Fed. Judicial Ctr., supra note 1. ↑

  14. Id. ↑

  15. Executive Biography of J. Michael Luttig, supra note 4. ↑

  16. Charles Lane & Jerry Markon, Similar Appeal, Wash. Post (July 17, 2005), https://www.washingtonpost.com/archive/politics/2005/07/17/similar-appeal/db16a144-03f0-443f-a5d3-291bf2718f84/?utm_term=.2e13a908e7ff. ↑

  17. Id. ↑

  18. Brzonkala v. Va. Polytechnic Inst. & State Univ., 169 F.3d 820, 838 (1999). ↑

  19. Harvey v. Horan, 285 F.3d 298, 308 (2002) (Luttig, J., concurring); Lane & Markon, supra note 16. ↑

  20. David Lat, Another Judge Leaves for Greener Pastures, Above the Law (July 26, 2006, 10:36 AM), https://abovethelaw.com/2006/07/another-judge-leaves-for-greener-pastures/. ↑

  21. Lane & Markon, supra note 16. ↑

  22. John G. Roberts, Jr., Oyez, https://www.oyez.org/justices/john_g_roberts_jr (last visited Apr. 2, 2019). ↑

  23. David Lat, Lawyerly Lairs: Luttig in Lap of Luxury, Above the Law (July 27, 2010, 1:37 PM), https://abovethelaw.com/2010/07/lawyerly-lairs-luttigs-lap-of-luxuryplus-info-about-his-current-compensation/. ↑

  24. Id. ↑

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19Mar

Judges of the Fourth Circuit – Hon. Judge Clyde Hamilton

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By Elliott Beale and Cassidy Webb

Senior Judge Clyde H. Hamilton was born in 1934 in the town of Edgefield, South Carolina.[1] After obtaining his B.S. from Wofford College in 1956, Judge Hamilton served as a U.S. Army Reserve Captain from 1956-1958.[2]  Judge Hamilton then attended George Washington University Law School, graduating with his J.D. with honors in 1961.[3] For the next two decades, Judge Hamilton worked in private practice in Edgefield and Spartanburg.[4]

On November 13, 1981, President Ronald Reagan nominated Judge Hamilton to a vacant seat in the U.S. District Court for the District of South Carolina.[5]  The Senate confirmed Judge Hamilton on November 24, 1981; Judge Hamilton served in this role until 1991.[6]  On June 12, 1991, President George H.W. Bush nominated Judge Hamilton to fill a newly created seat on the U.S. Court of Appeals for the Fourth Circuit.[7]  He was confirmed by the Senate on July 18, 1991 and assumed senior status on November 30, 1999.[8]  Senior status allows a retirement-eligible judge to continue serving on the bench while taking a reduced caseload.[9]  He is still currently serving as a senior judge.[10]

The majority of the cases Judge Hamilton hears are civil procedure cases, followed by labor and employment law and business and corporate compliance cases.[11]  He has presided over numerous interesting cases.  For example, in 2015 Judge Hamilton sat on the Fourth Circuit panel that found “consumers accusing manufacturers of making false advertising statements must show that no reasonable expert would agree with the statements.”[12]  This ruling was the “first-of-its-kind” by a federal appellate court.[13]  Judge Hamilton was also on the panel that “upheld the constitutionality of a federal law prohibiting citizens from engaging in non-commercial, illicit sexual conduct after traveling to a foreign country.”[14]

One of the most notable cases Judge Hamilton heard was decided in 2003.[15]  In 2002, 13-year-old middle schooler Alan Newsom was told by Virginia school officials that he could not wear a “NRA T-shirt depicting images of three people with guns and the words ‘Sports Shooting Camp.’”[16]  Newsom sued the school district and the Fourth Circuit eventually ruled that the school’s ban on clothing portraying weapons is unconstitutionally vague and overbroad.[17]  Judge Hamilton wrote the opinion of the court.[18]  He stated that the school’s dress code “exclude[d] a broad range and scope of symbols, images, and political messages that are entirely legitimate and even laudatory.”[19]       

As Judge Hamilton remains serving as a senior judge, he continues to hear cases.[20]  Recently, he was on the panel that although “testimony may have conflicted with disputed evidence, the conflict can affect only the weight and credibility of the opinion, not its admissibility.”[21]  Last year, he sat on the panel that affirmed a lower court’s decision to cap at $100,000 an insurer’s duty to defend a gym in a suit claiming two of its staff sexually assaulted a teenager.[22]  Judge Hamilton will likely be involved in many future fascinating cases as he continues his impressive career.

[1]Senior Judge Clyde H. Hamilton, U.S. Court of Appeals for the Fourth Circuit, http://www.ca4.uscourts.gov/judges/judges-of-the-court/senior-judge-clyde-h-hamilton (last visited Mar. 18, 2019). 

[2]Id.

[3]Clyde H. Hamilton, Lexis Context, https://advance.lexis.com/contextprofile/?pdmfid=1518492&crid=b85c5a5b-b786-4b15-a3c8-97537db1eb96&pdsearchterms=Hamilton%2C+Clyde+(US+Appeals+Ct.%2C+4th+Circuit%7C+US+Appeals+Ct.%2C+4th+Circuit%7C+US+District+Ct.%2C+South+Carolina)&pdprofiletype=judge&pdprofileid=urn%3Aentity%3Ajud100047518&pdtypeofsearch=searchboxclick&ecomp=t7cg9kk&prid=f240e184-9906-447e-9b1b-29b4bf9a7fa2 (last visited Mar. 18, 2019).

[4]Senior Judge Clyde H. Hamilton, supra note 1. 

[5]Id.

[6]Id.

[7]Id.

[8]Id.

[9]Kevin Elliker, How Senior Status Vacancies Will Shape the 4th Circ., Law 360 (Feb. 7, 2018),https://www.law360.com/articles/1009286.

[10]Senior Judge Clyde H. Hamilton,supra note 1. 

[11]Clyde H. Hamilton, supra note 3. 

[12]Sindhu Sundar, 4th Circ. Raises Bar for False Ad Plaintiffs in GNC Ruling, Law 360 (July 9, 2015), https://www.law360.com/articles/677609/4th-circ-raises-bar-for-false-ad-plaintiffs-in-gnc-ruling.

[13]Id.

[14]Marcia Coyle, Gov’t Can Prosecute Citizens for Illicit Sex in Foreign Countries, The Legal Intelligencer (Aug. 25, 2015), https://advance.lexis.com/document/?pdmfid=1518492&crid=861f3959-3fb2-4c6f-81d6-b4687f2d0b67&ecomp=ggLk&earg=17&prid=b83b70fa-15e4-4602-9537-56b14abe13e5.

[15]Michelle Galley, Court Blocks School Ban on Weapons Images, Education Week (Jan. 7, 2004), https://www.edweek.org/ew/articles/2004/01/07/16tshirt.h23.html. 

[16]Id. 

[17]Id.

[18]Eugene Volokh, High School Student Suspended for Refusing to Remove NRA T-shirt, Wash. Post (Mar. 13, 2014), https://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/03/13/high-school-student-suspended-for-refusing-to-remove-nra-t-shirt/?utm_term=.95f3c78b5f5e.

[19]Id. 

[20]See 4th Circuit: Testimony that Conflicted with Disputed Evidence was Allowed, Mealey’s Daubert Report (July 20, 2018), https://advance.lexis.com/document/?pdmfid=1518492&crid=04e478cb-1651-4a2b-ab35-7de4d2908d14&ecomp=ggLk&earg=3&prid=03672a4e-44c1-49e8-8a87-f8e4a26685f9.

[21]Id. 

[22]Adam Rhodes, Gym’s Sex Abuse Coverage Capped at $100K by 4th Circ., Law 360 (Mar. 27, 2018), https://www.law360.com/articles/1026784. 

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12Feb

Judges of the Fourth Circuit – Hon. William W. Wilkins

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Photo by Airman 1st Class Aspen Reid.

By Henry O. Hilston

The Honorable William W. Wilkins, who goes by Billy in legal circles, was born in 1942 in Anderson, South Carolina.[1]  He grew up in Greenville, South Carolina, where his father worked as an attorney.[2]  He enjoyed watching his father try cases in the county courthouse, which led to his childhood resolve to become an attorney in the future.[3]  He went on to get a B.A. from Davidson college in 1964, and then he immediately went to law school at the University of South Carolina, graduating with a J.D. in 1967.[4]  That same year, Wilkins entered the military.  He served two years on active duty in the Army, attaining the rank of captain.[5]  In 1969, he rotated to the U.S. Army Reserves, serving from 1969­­-83 and rising to the rank of Lieutenant Colonel.[6]

Upon leaving active service in the Army, Wilkins’ legal career began in full.  From 1969-70, he clerked for Clement Haynsworth, who was then the Chief Judge for the Fourth Circuit Court of Appeals.[7]  After that term, he served as a legal assistant to Strom Thurmond, United States Senator, from 1970-71.[8]  Wilkins then entered private practice in Greenville, South Carolina.[9]  From 1974-81, concurrent with his private practice, he also served as the Solicitor (District Attorney) of the 13th Judicial Circuit of South Carolina.[10]

On July 9, 1981, President Ronald Reagan nominated Wilkins to a seat on the United States District Court for the District of South Carolina that Robert W. Hemphill had vacated; the Senate confirmed his appointment on July 20, 1981.[11]  Judge Wilkins was President Reagan’s first federal judicial appointment.[12]  Wilkins did not spend long at the District Court level.  On June 2, 1986, President Reagan elevated Judge Wilkins to the Fourth Circuit where he would fill a seat vacated by Emory M. Sneeden, and the Senate confirmed his elevation on June 13, 1986.[13]  From 2003-2007, he served as Chief Justice of the Fourth Circuit and was a member of the Judicial Conference of the United States.[14]  He kept that position until July 1, 2007, when he chose to assume senior status.  His service was officially terminated in 2008 because of his retirement.[15]

Those accomplishments by themselves cut an impressive figure.  Concurrent with his district and appellate court service, however, Wilkins also served as the first chairman of the United States Sentencing Commission from 1985-94.[16]  Under Wilkins’ guidance, the Commission developed and promulgated sentencing guidelines for the federal judicial system.  Before that reform, there was little uniformity in federal sentencing, arguably because there was too much discretion available to judges.[17]  Speaking to the House Judiciary after the first release of the structured sentencing guidelines, he stated that the goal was not to make something “perfect” but rather something that would “bring greater certainty and fairness” to sentencing in federal court.[18]  Wilkins left his mark on the federal judicial system in more ways than serving as a judge.

Wilkins’ concurrent service on the Commission helps elucidate some of the opinions that he authored during his tenure on the Fourth Circuit.  In United States v. Hughes, for instance, Wilkins penned the majority opinion that held, among other things, that it was plain error for a district court judge to impose a sentence based on judge-found facts in excess of the maximum allowed based on the facts found by the jury.[19]  Likewise, in United States v. White, Wilkins wrote the majority opinion, holding that a district court committed plain error in treating the sentencing guidelines as mandatory, but that such treatment did not affect the defendant’s substantial rights.[20]  These two opinions show how Wilkins continued to rein in judicial discretion in sentencing, while simultaneously permitting some latitude to judges in how they handle that critical phase of adjudication.

Of course, Judge Wilkins is not the type of person to remain still for long.  After retiring from the Fourth Circuit, he has returned to private practice and is currently employed by Nexsen Pruet at the Greenville office.[21]  He leads the firm’s White-Collar Criminal Defense, Shareholder Litigation/Corporate Compliance, and Appellate Advocacy practices.[22]  This work keeps Wilkins in the courtroom, though he is now back on the side opposite the bench where he first began his legal career.

[1] Wilkins, William Walter, Fed. Jud. Ctr., https://www.fjc.gov/history/judges/wilkins-william-walter (last visited Feb. 11, 2019).

[2] Greenville Journal Staff, The Life and Trials of William Walter Wilkins, Greenville J. (May 27, 2011), https://greenvillejournal.com/2011/05/27/the-life-and-trials-of-william-walter-wilkins/.

[3] Id.

[4] Wilkins, William Walter, supra note 1.

[5] Id.

[6] Id.

[7] Id.

[8] Id.

[9] Id.

[10] Id.

[11] Id.

[12] William W. Wilkins, Nexsen Pruet, https://www.m.nexsenpruet.com/professionals/william-wilkins (last visited Feb. 11, 2019).

[13]Wilkins, William Walter, supra note 1.

[14] Id.

[15] Id.

[16] Brent E. Newton & Dawinder S. Sidhu, The History of the Original United States Sentencing Commission, 1985—1987, 45 Hofstra L. Rev. 1167, 1188 (2017).

[17] Id. at 1169-70.

[18] Id. at 1302.

[19] 401 F.3d 540 (4th Cir. 2005).

[20] 405 F.3d 208 (4th Cir. 2005).

[21] William W. Wilkins, supra note 12.

[22] Id.

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17Oct

Judges of the Fourth Circuit – Hon. Francis D. Murnaghan, Jr.

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By: Jason Wiener

Francis Dominic Murnaghan, Jr. was born in Baltimore, Maryland on June 20, 1920.[1]  After he received an undergraduate degree from Johns Hopkins University in 1941, he served his country during World War II as a U.S. Naval Reserve Lieutenant from 1942 to 1946.[2]  Upon graduating from Harvard Law School in 1948, he went into private practice in Pennsylvania until 1950 and then served as a staff attorney for the U.S. Department of State’s High Commission on Germany from 1950 to 1952.[3]  Before taking the bench, Judge Murnaghan was a partner at Venable, Baetjer and Howard and served as the Assistant Attorney General for the State of Maryland.[4]

From 1967 to 1970, Judge Murnaghan was president of the Baltimore City School Board.[5]  He served as president and then chairman of the Walters Art Gallery from 1963 until being named chairman emeritus in 1985.[6]  Known for his participation in the public and political spheres in Baltimore, he assisted in the successful campaigns of Senator Paul Sarbanes in 1976 and Governor Harry Hughes in 1978.[7]

On May 8, 1979, he was nominated to the U.S. Court of Appeals for the Fourth Circuit by Jimmy Carter.[8]  While on the bench, Judge Murnaghan wrote over 500 opinions and more than half as many concurrences and dissents.[9]  Known for his compassion and professionalism, his opinions had great impacts in the areas of civil rights, labor, First Amendment law.[10]

Although it is rare for a circuit to reverse a district court finding on a clearly erroneous standard of review, in United States v. Gregory, Judge Murnaghan reversed the lower court’s finding that the Sheriff of Patrick County, Virginia, was not discriminating against women in the hiring of deputies.[11]  Judge Murnaghan stated that the district court erred in its factual findings and found that the record indicated that Sheriff Gregory routinely engaged in discriminatory practices against women in violation of Title VII.[12]

In a notable dissent, Judge Murnaghan alone argued against the constitutionality of a Virginia statute that allowed the Commonwealth to collect the DNA of all convicted felons for a law enforcement data bank.[13]  Judge Murnaghan believed that the Commonwealth did not justify the statute with an important state interest that outweighed non-violent felons’ reasonable expectations of privacy.[14]  He went on to warn of his “deep, disturbing, and overriding concern that, without a proper and compelling justification, the Commonwealth may be successful in taking significant strides towards the establishment of a future police state, in which broad and vague concerns for administrative efficiency will serve to support substantial intrusions into the privacy of citizens.”[15]

Judge Murnaghan’s contributions helped strengthen the foundations of democracy and equality, and he will be remembered for his devotion to civil rights.[16]  On August 31, 2000, the Honorable Francis Dominic Murnaghan, Jr. died at the age of 80.[17]  Upon his death, the Baltimore Sun avowed, “Judge Murnaghan was one of the most admired figures in the legal establishment for his urbane scholarship, legal knowledge, and public spirit.”[18]

 

[1] Francis Dominic Murnaghan, Jr., Fed. Jud. Ctr., https://www.fjc.gov/node/1385506 (last visited Oct. 14, 2018).

[2] Id.

[3] Id.

[4] Biography of Judge Murnaghan, Francis D. Murnaghan Appellate Advocacy Fellowship, http://www.murnaghanfellowship.org/judge_murnaghan (last visited Oct. 14, 2018).

[5] Longtime Federal Appellate Judge Francis D. Murnaghan Dies at 80, Wash. Post (Sept. 1, 2000),  https://www.washingtonpost.com/archive/local/2000/09/01/longtime-federal-appellate-judge-francis-d-murnaghan-dies-at-80/d1be1771-8f0b-4d10-b094-77d7ac3820ba/?noredirect=on&utm_term=.1823226946fb.

[6] Id.

[7] Id.

[8] Fed. Jud. Ctr., supra note 1.

[9] Biography of Judge Murnaghan, supra note 4.

[10] Id.

[11] United States v. Gregory, 871 F.2d 1239, 1241 (4th Cir. 1989).

[12] Id. at 1247.

[13] Jones v. Murray, 962 F.2d 302, 311 (4th Cir. 1992).

[14] Id. at 312.

[15] Id. at 315.

[16] Biography of Judge Murnaghan, supra note 4.

[17] Fed. Jud. Ctr., supra note 1.

[18] Confirmation Hearing on the Nomination of Claude A. Allen, of Virginia, to be Circuit Judge for the Fourth Circuit; and Mark R. Filip, of Illinois, to be District Judge for the Northern District of Illinois Before the S. Comm. on the Judiciary, 108th Cong. 5 (2003) (statement of Sen. Paul S. Sarbanes).

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4Sep

Judges of the Fourth Circuit – Hon. John D. Butzner, Jr.

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By Ryan Meier

Judge John D. Butzner, Jr. was born on October 2, 1917 in Scranton, PA.[1] His interest in law and justice began at an early age, as he frequently visited his attorney uncle Billy Butzner who practiced at Butzner & Hicks in Fredericksburg, VA. After graduating magna cum laude from the University of Scranton in 1939, Judge Butzner attended the University of Virginia School of Law where he served on the board of editors for the school’s Law Review publication.[2]

Shortly after graduating with an LL.B. degree in 1941, Judge Butzner returned to Fredericksburg to practice with his uncle at Butzner & Hicks.[3] Despite his budding legal career in Virginia, Judge Butzner practiced for only a year before enlisting in the United States Air Force to aid the effort in World War II. He served as a staff sergeant for the Weather Service in Alaska until 1945 before returning to private practice in Fredericksburg.[4] While practicing, Butzner litigated in a variety of areas including contract law, criminal law, and civil rights cases in addition to serving as a city attorney for six years.[5]

In 1958, Butzner began his judicial career when he was sworn in as an associate judge of the new 15th Judicial Circuit of Virginia where he would serve for two years.[6] Judge Butzner officially became a Virginia Circuit Court judge for the 39th judicial Circuit in 1960. Two years after his appointment as a state court judge, on May 15, 1962, President John F. Kennedy nominated Judge Butzner for a vacant seat as a federal judge in the Eastern District of Virginia.[7] His appointment was confirmed by the Senate a month later on June 15, 1962.[8]

On June 27, 1967 President Lyndon B. Johnson nominated Judge Butzner to fill a seat vacated by J. Spencer Bell in the Fourth Circuit.[9] Judge Butzner was confirmed and received commission by the Senate nearly a month later on July 31, 1967.[10] Over his 33-year tenure on the Fourth Circuit, Judge Butzner would rule on a number of cases involving civil rights and racial justice—including class actions against some of the largest corporations such as Phillip Morris.[11] In 1976, the Virginia Trial Lawyers Association would honor him with the Distinguished Service Award.[12]

However, despite his judicial record as a civil rights advocate, his most notable contributions came after Chief Justice William H. Rehnquist appointed him to a special panel to appoint independent counsels to investigate alleged wrongdoing by members of the executive branch. Judge Butzner would cast a dissenting vote on a three-person panel in two high-profile decisions—the reversal of fraud and racketeering convictions against Maryland Governor Marvin Mandel and the appointment of Ken Starr as the independent prosecutor investigating President Clinton’s involvement with the Whitewater controversy.[13] Though no official record exists regarding Judge Butzner’s selection to investigate the Clintons, he is quoted as saying, “I was against Starr, start to finish.”[14]

Judge Butzner would assume senior status on November 1, 1982 and work in that capacity until his retirement in 2000. He died six years later due to illness.[15] Judge J. Harvie Wilkinson III, a colleague on the 4th Circuit bench, recalls Butzner as “A perfect example of what a judge ought to be. He combined integrity, courtesy, fairness and intelligence.”[16] After nearly 40 years of judicial service, Judge Butzner’s dedication to justice lives on in his work.

[1] Federal Judicial Center, John Decker Butzner, Jr., https://www.fjc.gov/node/1378651 (last visited Sept. 4, 2018).

[2] Wil Bowler, John Decker Butzner, Jr., Find a Grave (Sept. 12, 2006), https://www.findagrave.com/memorial/15714709/john-decker-butzner.

[3] Federal Judicial Center, supra note 1.

[4] Bowler, supra note 2.

[5] Id.

[6] Federal Judicial Center, supra note 1.

[7] Id.

[8] Id.

[9] Id.

[10] Id.

[11] Quarles v. Phillip Morris, Inc., 279 F. Supp. 505 (4th Cir. 1968).

[12] Bowler, supra note 2.

[13] See United States v. Mandel, 591 F.2d 1347 (4th Cir. 1979); Toni Locy, Judges’ Politics Examined in Appointment of Starr to Direct Probe, Wash. Post (Aug. 7, 1994), https://www.washingtonpost.com/archive/politics/1994/08/07/judges-politics-examined-in-appointment-of-starr-to-direct-probe/89aa6333-f4f1-4564-861e-907a1ecd9040/?utm_term=.7a1dd76c1a9b.

[14] Janet Maslin, Damages: Bill Clinton’s Legal Mess, N.Y. Times (Feb. 14, 2010), https://www.nytimes.com/2010/02/15/books/15book.html.

[15] Bowler, supra note 2.

[16] Id.

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