. Id. Close To understand the role of international comity in American law today, one must have some idea of where it came from and how it developed. As noted in the introduction, many doctrines of American law manifest the principle of international comity. Probs., Summer 2008, at 19, 20 (Whereas once courts justified applying foreign law out of deference to foreign sovereigns, courts later justified their decisions out of deference to the autonomy of private parties or to the political branches.). [4] Taxation respects international comity. Such decisions tend to be made categorically, outside the context of litigation. at 256 (stating foreign plaintiffs choice deserves less deference). H Croudson v. Leonard, 8 U.S. (4 Cranch) 434, 437 (1808). Close 2005 Uniform Act, supra note 106, 4(c)(3) (emphasis added). Part II identifies solidarity federalism in both U.S. constitutional doctrine and U.S. politics. 227 26 0 obj Speaking only of acts, this definition leaves out foreign sovereign immunity and a foreign states privilege of bringing suit in U.S. courts, both of which the Supreme Court had recognized as manifestations of international comity well before Hilton was decided. Id. See id. See infra notes 404410 and accompanying text (discussing passage of Foreign Sovereign Immunities Act). Close . to those organizing corporations. In a few states, conflicts rules are codified by statute, 47252. Under 28 U.S.C. Close But in fact, the separation-of-powers rationale for the act of state doctrine has international comity at its heart, for it rests on the perceived need for respect to foreign governments. a. (3) Sovereigns will so act by way of comity that rights acquired within the limits of a government retain their force everywhere so far as they do not cause prejudice to the power or rights of such government or of its subjects. 247 39 x+ | Close, The changing role of international comityattributable to international laws movement away from strict territorialityled in turn to a shift in the justifications for comity. w3TPI2T0 BC#=C3\. (misquotation). 56 See infra notes 361362, 393395 and accompanying text (discussing Posner and Sunsteins argument). endstream 159 endobj As noted above, Today, recognition of foreign judgments in the United States is governed by state law, and most states do not impose a reciprocity requirement. Close 756, 757 (C.C.D. ,.. Close With a proper definition of international comity and an understanding of the full range of American doctrines manifesting that principle, this Article now turns to examine critically some of the conventional wisdom. Id. 2014) (We also review the district courts decision to dismiss based on international comity for abuse of discretion.); Sarei v. Rio Tinto, PLC, 671 F.3d 736, 755 (9th Cir. 228 Tectonics Corp., Intl, 493 U.S. 400, 40809 (1990) (The act of state doctrine does not establish an exception for cases and controversies that may embarrass foreign governments. endstream Walden v. Fiore, 134 S. Ct. 1115, 1122 (2014). Only the first of these justifications reflects international comity. 347 2009) (Dismissal of a suit on international comity grounds may sometimes be appropriate. 78 U.S. (11 Wall.) Some of those exceptions are mandatory. 93 The border between the two has shifted over time. See Restatement (Fourth) of the Foreign Relations Law of the United States: Jurisdiction 222, cmt. Close See W.S. this deemphasis has encouraged lower courts over the past fifteen years to ignore certain legitimate sovereign interests expressed by foreign states.). 164 The second has been strongly advanced by Posner and Sunstein in recent scholarship. 270 And even the executive branch has concluded, in the context of foreign state immunity, that case-by-case discretion does not help U.S. foreign relations. Banco Nacional de Cuba v. Sabbatino, 376 U.S. 398, 410 (1964). . 118 See id. 375 the Ninth Circuit held that in ATS cases where the United States nexus is weak, courts should carefully consider the question of exhaustion, particularlybut not exclusivelywith respect to claims that do not involve matters of universal concern. Each began with the assumption that sovereignty was strictly territorial, each made exceptions based on mutual benefit, and each maintained the discretion of the territorial sovereign to deny such exceptions if it so chose. Close 268 at 13746 (discussing immunity of the sovereign, foreign ministers, and foreign troops). endobj 51 0 obj In fact, the discretion not to defer to foreign government actors has been an inherent part of comity itself since the very beginning. 243 64 168 Huber, supra note 74, at 164. The author is grateful to Mary Kay Kane for this point. endstream 2004); Republic of Philippines v. Westinghouse Elec. Close No.148420), Sasot v. People (Case Digest. 290 But by grounding the privilege in comity, the Court preserved the discretion of the United States to deny it, at least to foreign states that are at war with the United States or not recognized by it. 39 <>>>/BBox[0 0 377.76 588]/Length 47>>stream Close 164, 167 (1870) (allowing foreign sovereign to bring suit in U.S. courts because [t]o deny him this privilege would manifest a want of comity and friendly feeling). Morrison v. Natl Austl. Because enforcement of arbitration clauses does not involve deference to foreign government actors, it is not a doctrine of international comity but rather reflects deference to private autonomy. Close In Daimler AG v. Bauman, the Supreme Court limited general jurisdiction to instances in which the defendants contacts with the forum state are so continuous and systematic as to render it essentially at home there. Close The Supreme Court has consistently characterized foreign sovereign immunity as a matter of comity. L. Rev. while in contract suits, [i]f the place of negotiating the contract and the place of performance are in the same state, the local law of that state will usually be applied. Is the assessment valid? (rejecting Securities and Exchange Commissions (SEC) argument that district court misapplied doctrine). A/56/10, at 32 (2001), reprinted in [2001] 2 Y.B. It is based on the assumption that Congress is primarily concerned with domestic conditions.); see also William S. Dodge, Understanding the Presumption Against Extraterritoriality, 16 Berkeley J. Intl L. 85, 11719 (1998) (discussing domestic conditions rationale). Achille Lauro, 937 F.2d 44, 4749 (2d Cir. Jun 16, 1965 (121 Phil. . 320 See, e.g., Banco Nacional de Cuba v. Sabbatino, 376 U.S. 398, 41112 (1964) (rejecting reciprocity requirement for foreign governments privilege of bringing suit in U.S. courts); Restatement (Second) of Conflicts of Laws 6 cmt. 6. The federal act of state doctrine, on the other hand, is quite rule-like. No one shall be imprisoned for non-payment of tax.FALSE 8. 100 Tectonics Corp., Intl, 493 U.S. 400, 404 (1990) (Scalia, J.) International comity - the property of a foreign state or government may not be taxed by another. No. . Close Law Inst., Recognition and Enforcement of Foreign Judgments: Analysis and Proposed Federal Statute 7(a) (2006) (A foreign judgment shall not be recognized or enforced in a court in the United States if the court finds that comparable judgments of the courts in the United States would not be recognized or enforced in the courts of the state of origin.); see also John F. Coyle, Rethinking Judgments Reciprocity, 92 N.C. L. Rev. Part II discusses and categorizes the manifestations of international comity in American law, defending the inclusion of each doctrine and explaining why each of the categories represents a coherent group. <>>>/BBox[0 0 377.76 588]/Length 46>>stream and (3) that whatever force and obligation the laws of one country have in another, depend solely upon the laws and municipal regulations of the latter; that is to say, upon its own proper jurisprudence and polity, and upon its own express or tacit consent. L-21574. . 286 <>stream See Intel Corp. v. Advanced Micro Devices, Inc., 542 U.S. 241, 261 (2004) ([C]omity and parity concerns may be important as touchstones for a district courts exercise of discretion in particular cases. This Article aims to support the role of international comity in U.S. foreign relations law by providing a proper definition and analytic framework and by freeing international comity from some of the myths that have surrounded it. 45 . And no rule of international law requires one country to allow the government of another country to bring suit in its courts. 623(f)(1) (2012) (incorporating defense similar to that in Title VII); Americans with Disabilities Act, 42 U.S.C. 38 To attempt it through the process of case-by-case adjudication is a recipe for endless litigation and confusion.). x+ | endstream See, e.g., The Apollon, 22 U.S. (9 Wheat.) Co., 517 U.S. 706, 723 (1996). 144 905, 909 (S.D.N.Y. Watson speculates that Mansfield was deliberately ignoring Huber in order to reach his decision, Watson, supra, at 68, and that the attorneys for Somersets owners must not have raised Huber since that would have forced Mansfields hand, id. Close Close 403 Close (Collector v. Goodrich International (b) In case of property held in trust . Despite its slippery definition of comity, See Parkcentral Glob. 147 Under customary international law, for example, the United States may apply its law extraterritorially only if it has a basis for jurisdiction to prescribe. The Supreme Court has held that [u]nder principles of comity governing this countrys relations with other nations, sovereign states are allowed to sue in the courts of the United States. Bank Ltd., 130 S. Ct. 2869, 2881 (2010). See, e.g., id. 161 195 It is also true that legislatures sometimes speak directly to the recognition of foreign law Hilton, 159 U.S. at 163. Kirkpatricks approach was more rule-like than the approach in Sabbatino, where the Court suggested a case-by-case balancing of factors. Huber wrote that nothing could be more inconvenient to commerce and to international usage than that transactions valid by the law of one place should be rendered of no effect elsewhere on account of a difference in the law. 81 Close One might think of the FSIA as an exercise of international comity by Congress, but it is meant to be applied by the courts. 19 Residence-based taxation Close, The act of state doctrine is another manifestation of international comity in American law. 2011) (en banc) (plurality opinion) (McKeown, J.) Apr. J. Transnatl L. 171, 18387 (2013) (characterizing First Restatement as based on rules and Second Restatement as mix of rules and standards). 197 Trades Council, 485 U.S. 568, 575 (1988) (stating constitutional avoidance canon has its roots in Chief Justice Marshalls opinion for the Court in Murray v. The Charming Betsy); NLRB v. Catholic Bishop of Chi., 440 U.S. 490, 500 (1979) (misciting The Charming Betsy for proposition that an Act of Congress ought not be construed to violate the Constitution if any other possible construction remains available). that courts should defer when the executive informs them that this doctrine should not apply in a particular case. Id. 321 It aims to rescue international comity from disrepute and support its critical role in U.S. foreign relations law by providing a clearer view of both the underlying principle and its manifestations in American law. <>stream 2011) (declining to consider whether exhaustion is required under ATS), vacated on other grounds, 527 F. Appx 7 (D.C. Cir. 122 325 2009) (holding prudential exhaustion applies equally to cases brought against foreign states (and their instrumentalities) under the FSIA), vacated, 616 F.3d 1019 (9th Cir. 104 246 U.S. 297, 30304 (1918). <>stream endstream 3227, 500 U.N.T.S. If you get 8/10, you're ready for law school. 196 291 191 Some have asserted that this discretion must be exercised on a case-by-case basis and that the executive branch is more competent to apply the doctrines of international comity. Close, Confusion also surrounds the relationship between international comity and international law. Id. ,.. 2000) (applying Colorado River abstention to foreign proceedings). 2012) ([H]ead-of-state immunity involves a formal act of recognition, that is a quintessentially executive function for which absolute deference is proper. (quoting Peter B. Rutledge, Samantar, Official Immunity and Federal Common Law, 15 Lewis & Clark L. Rev. 181 With respect to the second myth, it is important to recognize that the proper role of the Executive depends on the comity doctrine at issue. 251 215 37 336 See W.S. 111359. Close The circuits following Colorado River have held that international comity abstention is appropriate only where parallel foreign proceedings are pending, For example, these include personal jurisdiction based on service of process while the defendant is temporarily present in the forum, personal jurisdiction based on the nationality or domicile of the plaintiff, and personal jurisdiction based on the presence of property in the forum. For discussions of international comity in English law, see generally Adrian Briggs, The Principle of Comity in Private International Law, 354 Recueil des Cours 65 (2011) (surveying international comitys application in English caselaw); Collins, supra note 20, at 95110 (discussing manifestations of international comity in English law). 1, 2014) (noting only two grounds are treated as discretionary in practice). 244 .); Crawford, supra note 24, at 71011 (A claim will not be admissible on the international plane unless the individual alien or corporation concerned has exhausted the legal remedies available in the state which is alleged to be the author of injury.). Although adjudicative comity arises in many different contexts, the basic question is often the samewhether to defer to a foreign tribunals resolution of a dispute. 319 286 Close Huber, supra note 74, at 165. Huber wrote that nothing could be more inconvenient to commerce and to international usage than that transactions valid by the law of one place should be rendered of no effect elsewhere on account of a difference in the law. Justice Breyer has also sometimes asserted that a rule of prescriptive comity reflects principles of customary international law. ONE OF THE CHARACTERISTICS OF INTERNAL REVENUE TAX IS THAT THEY ARE-(RPCPA) +wCLGNMU}Pk|*95?Smxs6|:+q,}"'j!MYGxBz:XFi5^{='IN[6*V Fo@kbD4v^ i3$'q+1cU4*y.>21 endobj wRw 5fw[Oe//[fEdy 160 Recognition and restraint are often related. at 5464 (providing contract theory analysis); see also id. And they appear to chide the Court for not going far enough in Sosa to embrace deference to the executive branch. 154514. 2015) (Understood correctly, however, the prior opinion imposed an exhaustion requirement that limits where plaintiffs may assert their international law claims. In the context of sovereign party comity, by contrast, recognition may preclude restraint. Close Close A court of this state shall recognize and enforce a liability for a sales or use tax lawfully imposed by another state if the other state extends a like comity to this state. endobj Co. v. California, 509 U.S. 764, 817 (1993) (Scalia, J., dissenting) ([P]rescriptive comity. Close Bank of Nigeria, 461 U.S. 480, 486 (1983) (As The Schooner Exchange made clear, however, foreign sovereign immunity is a matter of grace and comity on the part of the United States, and not a restriction imposed by the Constitution.); First Natl City Bank v. Banco Nacional de Cuba, 406 U.S. 759, 765 (1972) (plurality opinion) (Rehnquist, J.) 400 . More specifically, this Article makes three contributions to understanding international comity in American law. (The general rule is, that a discharge of a contract according to the lex loci contractus is good every where. See Ritchie v. McMullen, 159 U.S. 235, 242 (1895) (By the law of England, prevailing in Canada, a judgment rendered by an American court under like circumstances would be allowed full and conclusive effect.). Close in the international sphere.). 1309, 131435 (2015) (surveying comity in law of American federalism). 88 Rep. 99, 78 (Feb. 3) (discussing state immunity for military activities during armed conflict); Arrest Warrant of 11 April 2000 (Dem. See Knox, supra note 124, at 36266 (describing origins of presumption against extraterritoriality). 415 Initiative, 456 F.3d 363, 393 (3d Cir. Professor of Law, University of California, Davis, School of Law. J. Intl L. 351, 352 (2010) (For most of U.S. history, the Supreme Court determined the reach of federal statutes in the light of international lawspecifically, the international law of legislative jurisdiction.). Today, host countries generally hold primary jurisdiction to tax the active income 18 that is earned in their territories by foreign or domestic firms with permanent establishments. 15 D. D. I and III only. Suggested Citation Clyde J. Crobaugh, 1923. Close w3TPI2T0 BC#=C3\. Rep. 6, 27 (Mar. 17,031) (Story, J.) Close. 326 Huber, supra note 74, at 164; see also Story, supra note 54, 25, at 31 (No nation can. what is it? and the United States is responsible to other states for violating it. 43 The President has never used this authority. xs 123 This Article also omits enforcement of arbitration clauses, which Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc. said rested in part on concerns of international comity. 473 U.S. 614, 629 (1985). 54 Take the doctrines of sovereign party comity, for example. Other circuits have rejected an exhaustion requirement in ATS cases. 144104, June 29, 2004 (477 Phil. and have declined to order discovery when doing so would interfere with the foreign proceedings. endstream and the Second Circuit holding that the only fact that matters is the State Departments determination of immunity. The lower courts approach to extraterritorial acts of state is more of a standard, calling for an evaluation of the foreign acts consistency with U.S. policy in each case. Close Much more problematic is judicial deference to the Executive with respect to the outcomes of particular cases. . or to those not recognized by this country). 264, 404 (1821) (Marshall, C.J.) Close 1987) (This section states the principle of reasonableness as a rule of international law.). 2d 407, 418 n.73 (S.D.N.Y. 31 0 obj In Ungaro-Benages v. Dresdner Bank AG, the Eleventh Circuit went further and upheld abstention on international comity grounds, despite the absence of parallel foreign proceedings, to support a foundation established by the United States and Germany to hear claims brought by victims of the Nazi regime. Conduct-based immunity differs from status-based immunity in two respects: (1) it extends only to suits based on official acts; and (2) it lasts even after the foreign official leaves office. See 28 U.S.C. 278 Hubers De Conflictu Legum set forth three maxims to address the problem of foreign rights in a world of exclusive territorial sovereignty: (1) The laws of each state have force within the limits of that government and bind all subject to it, but not beyond. It occurs when one country shows respect for the laws, judicial decisions, and institutions of another. Close As the Court restated the rule most recently, governments recognized by the United States and at peace with us are entitled to access to our courts. Rubber Co., 643 F.3d 1013, 1025 (7th Cir. They recognize the judgments of foreign courts and limit the jurisdiction of American courts. Close 213 U.S. 347 (1909). Co. of N.Y. v. United States, 304 U.S. 126, 137 (1938) (What government is to be regarded here as representative of a foreign sovereign state is a political rather than a judicial question, and is to be determined by the political department of the government.). Recognizing foreign law as applicable to a particular case, for example, often means restraining the application of domestic law to that case. 7 0 obj Co. of Can. Close 213 328 2014) (per curiam) (concluding while a domestic transaction or listing is necessary to state a claim under 10(b), a finding that these transactions were domestic would not suffice to compel the conclusion that the plaintiffs invocation of 10(b) was appropriately domestic). endstream endstream 1971) (rejecting reciprocity requirement for conflict of laws). 11 Close but as the First Circuit has pointed out, this may not be the best approach. Part IV shows that international comity doctrines are frequently expressed as rules rather than standards, and that allowing courts to apply these doctrines without inference by the executive branch promotes not just the rule of law but also U.S. foreign relations. . 345 but in most they are judge-made common law. (The act of state doctrine, like the doctrine of immunity for foreign sovereigns, has its roots, not in the Constitution, but in the notion of comity between independent sovereigns.). The Executives action in recognizing a foreign government and in receiving its diplomatic representatives is conclusive on all domestic courts, the Court noted. Close 78 Comity "counsels voluntary forbearance when a sovereign which has a legitimate claim to jurisdiction concludes that a second sovereign also has a legitimate claim to jurisdiction under principles of international law." Wharf, 210 F.3d at 1236 (quotations omitted). 350 ,.. 86 v. Century Intl Arms, Inc., 466 F.3d 88, 92 (2d Cir. subject to a number of presumptive rules for recognizing foreign law. 208 (rejecting idea of discretionary authority to avoid parallel proceedings and stating no federal court can escape from its duty, in any case, which congress has confided to its jurisdiction). In short, adjudicative comity operates as a principle of recognition in American law through state law providing for the recognition of foreign judgments and a federal statute authorizing district courts to help foreign courts with the discovery of evidence in the United States. Close []D2*B0Z6j\vC!m See D.J. Close Hilton v. Guyot, 159 U.S. 113, 16364 (1895). . endstream <>stream Joseph Story, Commentaries on the Conflict of Laws 28, at 34 (2d ed. Close 1999] International Comity and the Foreign Ta:r: Credit 85 is the failure to allow the crediting of taxes collected by foreign governments pursuant to provisions that might fairly be described as integral to a general income tax but which do not conform to a conception of income taxation as developed by the United States. 2006) (recognizing possibility of international comity abstention); Gross v. German Found. See Johnston v. Compagnie Gnrale Transatlantique, 152 N.E. Close 133 Colo. River Water Conservation Dist. 230 Third, this Article uses its categorization of international comity doctrines to challenge two enduring myths about comity: (1) that comity must be governed by standards rather than rules; and (2) that comity determinations are best left to the executive branch. Close As a Principle of Restraint. In summary, adjudicative comity operates in American law through limits on personal jurisdiction as well as doctrines like forum non conveniens (and others of more doubtful status) that allow courts to dismiss cases over which they have jurisdiction. 164 International comity . As the old, territorial conception of jurisdiction under international law receded, a comity-based presumption against extraterritoriality came forward to limit the territorial reach of American law. taxation notes, reviewer . to treat a foreign act of state as valid, 115(1)(b) (That a rule of international law or a provision of an international agreement is superseded as domestic law does not relieve the United States of its international obligation or of the consequences of a violation of that obligation.). 87, 100 (2003) ([T]he Arospatiale decision improperly de-emphasized system values as compared to particular interests raised in individual cases, and. As with the recognition of foreign law, Congress has also authorized federal courts to assist foreign and international tribunals with respect to the discovery of evidence located in the United States. xs Close As a principle of recognition, prescriptive comity operates in American law today through state-law rules on the conflict of laws, the federal act of state doctrine, and the practice of some courts to recognize extraterritorial acts of state on the basis of comity. d. Exemption of government entities recognized. 2023-01-18T11:42:22-08:00 .). Close Close 2007) (equating deference suggested in Sosa with prudential justiciability doctrine known as the political question doctrine (internal quotation marks omitted)). It turns legal decisions into political ones, undermining not only the rule of law but also the foreign policy interests of the United States. The Court has recognized exceptions for countries at war with the United States or not recognized by the United States. Close The majority held that the concept of international comity requires. ck^68p'>!!h,{G!WYb! Close Kirkpatrick & Co. v. Envtl. United States portal. See, e.g., Louis Kaplow, Rules Versus Standards: An Economic Analysis, 42 Duke L.J. 1319, 1320 (C.C.D. w3TPI2T0 BC#=C3\. 342, 344 (K.B.). 1, 45 (2014) ([I]f a statute is silent or ambiguous with respect to its extraterritoriality, and if Congress has explicitly or implicitly delegated responsibility for that statute to an administrative agency, the agencys ex ante interpretation is valid if it is a permissible construction of the statute.). 174 x+ | See Chevron U.S.A. Inc. v. Nat. . Close Close Id. 121004. . 14 (1973) (statement of Charles N. Brower, Legal Adviser, Dept of State) [hereinafter Foreign State Immunity Hearing]. The author read all 637 cases and eliminated those that discussed comity only in a domestic context, leaving more than 100 Supreme Court cases relevant to international comity. Id. xs <>stream Close, International comity has even influenced some of the Supreme Courts rulings on personal jurisdiction under the Due Process Clause. to violate the law of the foreign country in which such workplace is located. . When a court construes a federal statute to avoid conflict with international law under the Charming Betsy canon, it does not defer to a foreign government actor but rather to another body of law with a complex relationship to U.S. domestic law. 1987). xs Close x+ | In a majority of states, these rules are codified for money judgments in two uniform acts. Restatement (Second) of Conflicts of Laws 10 (Am. In Holman v. Johnson, he added: The doctrine Huberus lays down, is founded in good sense, and upon general principles of justice. The doctrine of international comity is the traditional vehicle for this function, as we will see in both US conflicts doctrine and early nineteenth-century European choice of law. 246 U.S. 297, 30304 (1918). Close No. Some foreign officials are immune from suit based on their status. <>stream See, e.g., Doe v. Exxon Mobil Corp., 654 F.3d 11, 58 (D.C. Cir. In American Banana Co. v. United Fruit Co., the Supreme Court had to decide whether the Sherman Act reached anticompetitive conduct in another country. Erie R.R. See Aetna Life Ins. Law Inst. Immunity of Foreign States: Hearing on H.R. . ), Judgment, 2012 I.C.J. See, e.g., Or. 16 as well as for state-sponsored terrorism <>stream 519, 589 (1839); see also The Sapphire, 78 U.S. (11 Wall.) Respect for foreign sovereignty seemed a more natural fit. 11 Am. 52 0 obj The Court has also developed specific doctrines for abstaining in favor of state courts and has permitted abstention in cases falling outside these doctrines in exceptional circumstances. 198, 201 (N.Y. 1918). .). As a principle of restraint, adjudicative comity finds expression in a number of doctrines. 428), Jurisprudence on gender-free or homosexual rape, Cario v. Insular Government, 212 U.S. 449 (1909), G.R. xS**T0T0 BiU" and the President. Close Close. Close Close 238 Close See Bradley, supra note 66, at 69194 (arguing for deference to extraterritorial interpretations by executive branch); Posner & Sunstein, supra note 33, at 1204 ([I]n cases in which the executive has adopted an interpretation via rulemaking or adjudication, or is otherwise entitled to deference under standard principles of administrative law, the executives interpretations should prevail over the comity doctrines.). The doctrine of forum non conveniens, for example, takes the form of a standard rather than a rule, but it is also binding on district courts. uuid:56ac7f3d-1dd2-11b2-0a00-20d0ffffb063 If it does it, it is as a matter of comity, and not as a matter of international right. After examining a number of different doctrines, Maggie Gardner concludes that open-ended discretion promotes parochial outcomes systemically because it enables the evolution of tests that increasingly lock in parochial results. Maggie Gardner, Parochial Procedure 4 (Aug. 20, 2015) (unpublished manuscript), http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2651453 (on file with the Columbia Law Review).
Ameth Amar Net Worth,
Comprendre La Gamme Pentatonique,
Chris Mccausland Wife Patricia,
Former Wptv News Anchors,
Articles I
