To the extent that Graham remains the law of the land, the Ninth and Tenth Circuits’ proper—and more capacious—reading of the Supreme Court’s opinion should be adopted by all lower federal courts as well as by the Supreme Court itself.
[The United States] must recognize the global epidemic of domestic violence and enact guidelines and a statutory amendment that will explicitly offer safe harbor to those seeking protection. The current system must be reformed to ensure that the thousands of
Venture liability allows for a holistic examination of the power and incentive dynamics within supply chains.
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