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Like most judicial clerks (and, for that matter, judges) we found writing dissents more fun than writing majority opinions. Dissents free one from the need to articulate a consensus.  Moreover, since a dissent does not establish a precedent that others must at least pretend to follow, the dissent’s author can be less precise and can let the rhetorical fireworks fly.  To reverse the Spider Man rubric, with lack of responsibility comes great power to write colorfully.

We clerked on the Ninth Circuit.  The Ninth Circuit is often unjustly maligned. And yet the fact is that the Ninth Circuit more often than not gets things right.  Put another way, not every Ninth Circuit dissent hits the mark.  We certainly do not agree with the dissent to the denial of rehearing en banc in California Chamber of Commerce v. Council for Education and Research on Toxics, 2022 WL 14725243 (9th Cir. Oct. 26, 2022).  But it is a fun read. 

The underlying Ninth Circuit decision enjoined certain Proposition 65 litigation on first amendment grounds, and we discussed that decision last May.  Here is a brief refresher: Proposition 65 requires postings of warnings about substances “known to the state [of California] to cause cancer.” You see those warnings pretty much everywhere in California.  In truth, the warnings are so ubiquitous as to be useless.  

Continue Reading Ninth Circuit Dissent from Denial of En Banc re Injunction against Prop 65 Lawsuit: Sturm und Drang und Wrong

More plaintiffs, more money. And we don’t mean a mere linear increase. If, as Hegel said, quantitative differences ultimately become qualitative differences, in litigation that happens when going from one plaintiff to two, and certainly to several or many.  When a jury sees multiple people bringing claims against a defendant, they think something’s up, where

We listen to the This American Life show on National Public Radio most weeks, and it often reveals interesting things about, uh, this American life.   On Saturday, as we drove around the Main Line doing chores, we listened to a This American Life program that illustrated the Tolstoyan ditty about how unhappy families are each

Fraud via omission of facts is a popular plaintiff lawsuit theory, but many of those lawsuits themselves suffer from the omission of plausibility and specificity.  In Womack v. Evol Nutrition Assocs., 2022 U.S. Dist. LEXIS 145754 (N.D.N.Y. Aug. 16, 2022), the plaintiff filed a purported class action alleging that a manufacturer of energy drinks failed


From the defense perspective, the worst thing about a mass tort is that it is so … massive.  The more the merrier?  No way. The presence of multiple plaintiffs signals to the jury that something must be wrong with the product.  Don’t believe us?  We think there is research to support our dislike of consolidation

We are headed to Guitar Town.  That’s Nashville to you.  Guitars are played and guitars (including the magnificent Gibson ES-335) are made there. We aim to sample plenty of live music and hot chicken. But the reason for our trip is the Defense Research Institute (DRI) Drug and Medical Device Conference.  Tomorrow we will be