Judge Janice Brown on cy pres, cont’d

In the D.C. Circuit case of Keepseagle v. Perdue, mentioned in this space last month, Judge Janice Rogers Brown had some choice words regarding the constitutional status of class-action slush funds arising from the settlement of a suit against the federal government on behalf of Native Americans claiming discrimination against them by the Department of Agriculture:

$380,000,000 is, to use the late Senator Dirksen’s wry phrase, “real money.” That is what has been left on the table for private disbursement in this case. Perhaps one day, I will possess my colleagues’ schadenfreude toward the Executive Branch raiding hundreds-of-millions of taxpayer dollars out of the Treasury, putting them into a slush fund disguised as a settlement, and then doling the money out to whatever constituency the Executive wants bankrolled. But, that day is not today….

The Executive Branch may wish to favor certain interests on the taxpayer’s dime. It may wish to use the Judicial Branch’s enforcement of settlement agreements to avoid asking Congress for an appropriation. But the Constitution’s design gives the People’s elected representatives a means to thwart these “overgrown prerogatives.” . . . By limiting the “judicial Power” to resolving “Cases” and “Controversies,” . . . the Constitution ensures the Judicial Branch has “no influence over . . . the purse.” . . . Expenditures toward the fulfilment of public policy are integral to policymaking itself, and policymaking is left to the legislature. . . . In short, congressional control over the People’s purse is a structural limit on both the Executive and Judicial Branches.

Alas, the analysis came in a dissent. Mark Pulliam writes up the case at Liberty and Law.

Libel, slander, and defamation roundup

  • After nearly four years federal judge grants summary judgment to blogger/prosecutor Patrick Frey, one of many defendants sued by Brett Kimberlin [Patterico] That took a lot of thankless pro bono work by attorney/Likelihood of Confusion blogger Ron Coleman (who writes about it here) and Maryland employment lawyer Bruce Godfrey [Eric Turkewitz, more reactions]
  • India: “editor explains how threat of legal action is used to silence journalists” [Aayush Soni, Committee To Protect Journalists]
  • Liberty Counsel v. GuideStar, Maajid Nawaz v. SPLC: “How the Southern Poverty Law Center Enraged Nominal Conservatives Into Betraying Free Speech Values” [Popehat]
  • “Former University Official Files Libel Lawsuit Against His Replacement For Things A Journalist Said” [Tim Cushing, TechDirt, Tennessee]
  • “Ted Rall Is Incensed That Anti-SLAPP Laws Protect Everyone” [Popehat]
  • Conjuring up notional John Doe defendants can help get injunctions forcing websites to take down stories [Paul Alan Levy, Arizona]

Vicarious criminal liability for managers: how we got there

In Dotterweich v. U.S., a 1943 case that established a persistent and troublesome doctrine in criminal law, the U.S. Supreme Court agreed that a pharmaceutical company manager could appropriately be convicted over the misdeeds of an underling without having to show that he knew of the violation, participated in it, intended it, or was negligent in failing to prevent it. My new Cato post summarizes new research by Craig Lerner on Dotterweich’s trial, in which the court seemed to struggle with the idea of imposing vicarious guilt without mens rea (a guilty state of mind). I also link to the chapter I wrote on white-collar prosecution in this year’s new edition of the Cato Handbook for Policymakers.

Privacy a casualty in war on opioids

Law enforcement officials in some states are seeking warrantless access to prescription databases. A New Jersey bill “would require officials to ‘certify’ that they are engaged in a specific investigation,” seeking to calm fears that enforcers will begin trawling data for people to investigate. Rhode Island Gov. Gina Raimondo has already signed a similar bill. “In California, the Supreme Court ruled recently that the state Medical Board can dig through prescription drug records without a warrant or subpoena.” [Associated Press via Scott Shackford, Reason]

CFPB anti-arbitration rule

Why it should go [Rafael Mangual and Jarrett Dieterle, Investors Business Daily] And Thaya Brook Knight, Cato:

If customers were really upset about arbitration, it seems they would have presented a terrific market for a company that would offer them contracts free of arbitration clauses. The trade-off would likely have been slightly higher fees for their products to off-set the costs. That is, effectively the trade-off the new rule presents: no arbitration clause, but higher costs. To my knowledge, no one offered this trade-off. Given the competitiveness of the market, it seems that if there were customers willing to pay for a product, banks and credit card companies would have offered it. The fact that no one did suggests to me that arbitration clauses are not that important to consumers. Not important enough, at least, to justify higher costs. This makes the rule a bit strange. It forces on consumers an option they never chose, all in the name of protecting their best interests.

“After N.F.L. Concussion Settlement, Feeding Frenzy of Lawyers and Lenders”

Following the biggest settlement in sports history, on behalf of National Football League players who were not given enough warning of the dangers of concussions and brain injury, a small army of legal, financial, claims-filing, and medical advisers are working hard to pitch retired players on their services. But “the fact that many players are cognitively impaired and may struggle to understand the terms of the services offered to them has raised alarm among player advocates, legal ethicists and the lawyers for the players who sued the N.F.L.” [Ken Belson, New York Times]

Most of the claim-service providers require players to agree to share 15 percent or more of anything they receive in return for helping them with a process that the providers portray, in stark terms, as unduly complicated. They also do not always tell players that they can call court-appointed experts to receive free advice on how to file a claim, or that they can visit doctors who will provide a free neurological exam.

Some lawyers have hosted dinners for former players at steakhouses to get them to sign up. Others have promised to get players appointments with doctors who will write diagnoses that make their medical conditions look worse than they are, according to players who have received pitches from some of the companies.

Side note: Ira Stoll has a comment about the Times’s use of the phrase “largely unregulated.”

July 26 roundup

  • “It’s time for our justice system to embrace artificial intelligence” [Caleb Watney, Brookings]
  • Ontario woman named vexatious litigant and barred from filing lawsuits without leave tells newspaper “to hold off on publishing her story until all of her matters before the court were concluded, or else” [Jesse McLean and Emily Mathieu, Toronto Star]
  • Psittacine hearsay? Parrot said to have repeated “don’t (expletive) shoot” in murder victim’s voice; wife convicted [AP/Detroit News] “The parrot was not involved in any court proceedings.” [Evening Standard (U.K.)]
  • Pennsylvania’s abuse-of-process law, not particularly strong in the first place, survives a challenge [Hillary Hunter, WLF]
  • No, that’s not how the law works. Sanctions next? “Baton Rouge police officer injured in deadly ambush sues Black Lives Matter” and five leaders of it [CBS]
  • “When the first section heading of an opinion is ‘Design Basics and the Art of the Intellectual Property Shakedown,’ you can probably guess how things are going to turn out for Plaintiff Design Basics, LLC.” [John Ross, Short Circuit on this Seventh Circuit case]

After a copyright verdict, creators keep mum

Two years after the Blurred Lines copyright verdict, lawyerly caution is making itself felt: “According to a BBC report last week, recording artists are now being instructed not to talk publicly about their musical influences for fear of exposure to copyright infringement claims.” [Brink Lindsey, Cato] From the BBC report:

According to forensic musicologist Peter Oxendale “everyone’s concerned that inspiration can [now be interpreted as] a catalyst for infringement.

“All of these companies are worried that if a track is referenced on another at all, there may be a claim being brought,” he explains.