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Medical malpractice lawsuits rise in Philadelphia after Pennsylvania Supreme Court rule change

Medical malpractice lawsuits rise in Philadelphia after Pennsylvania Supreme Court rule change

Late very last 12 months, the household of a 9-yr-outdated boy who fractured his jaw at a Nemours Children’s Medical center clinic in Montgomery County was ready to sue for negligent treatment.

Their attorney waited a several weeks, hoping to improve their likelihood of a productive verdict when a alter in condition regulations authorized them to attempt their circumstance in a Philadelphia courtroom, alternatively of the county where the injury transpired.

» Browse Much more: Significant shift in medical malpractice regulations in Pa. could assist victims, but opponents fear the cost

Philadelphia juries tend to make a decision healthcare malpractice circumstances in favor of plaintiffs a few periods extra frequently than Montgomery juries, in accordance to studies retained by the Administrative Business office of the Pennsylvania Courts.

That will make Philadelphia a much more promising venue for a lawsuit, stated the family’s lawyer, Julianna Burdo, who practices with the Philadelphia organization Wapner Newman. The fit claims the kid handed out and injured himself in an assessment area because clinic workers unsuccessful to convey to his family he required to continue to be off his toes in the minutes straight away right after obtaining his shot.

The rule change “provides us with location possibilities that didn’t exist ahead of,” Burdo reported.

Nemours did not respond to a request for comment on the incident, which the lawsuit claims took place at an outpatient clinic in Collegeville.

The variety of health care malpractice circumstances filed in Philadelphia’s Court docket of Typical Pleas virtually tripled in January and February, just after the rule modify took effect, compared to the exact same period past year, in accordance to information from that court docket.

These 117 situations stand for the most submitted for these two months because 2017, the court documented.

About one in 4 involve only defendants with addresses outside of the metropolis, in accordance to an Inquirer overview of the scenarios. Many very likely wouldn’t have been submitted in Philadelphia courtroom in advance of this year’s location rule transform.

The rule transform doesn’t no cost lawyers to file a situation anywhere in Pennsylvania. A go well with can only be submitted in a various county if at minimum one particular of the defendants does organization there.

Circumstances that started out in well being systems in West Looking at, Bensalem, and Langhorne are amongst those filed so much this yr in Philadelphia’s common pleas civil courtroom.

Million-greenback verdicts in Philadelphia courtrooms

For the previous 20 several years, Pennsylvania expected all health-related malpractice instances to be submitted in the county where by the damage transpired, next a increase in the range of court docket conditions and the dimensions of the verdict awards, in particular in Philadelphia. Several blamed the court docket predicament for boosting the value of professional medical legal responsibility insurance coverage and driving medical practitioners out of the point out.

The latest example of an eye-popping malpractice verdict out of Philadelphia arrived just final thirty day period when a nearby jury awarded $43.5 million to Chris Maragos, an ex-Eagles captain who sued the doctors that treated his knee. It was the second best verdict a Philadelphia jury awarded in medical malpractice scenario in a ten years, according to an Inquirer evaluate of court docket information.

At minimum 57 other instances tried using in Philadelphia courts returned verdicts greater than $1 million involving 2009 and 2021, the information confirmed.

Philadelphia’s civil division of the courtroom of frequent pleas also tends to transfer cases together additional immediately than neighboring counties, lawyers say. That is one more incentive for attorneys to file here, even however court docket records present that Philadelphia has a backlog of about 800 lively medical malpractice conditions.

Weighing issues about ‘venue shopping’

Attorneys and the health and fitness-treatment field fear “venue searching,” a reference to the follow of submitting cases in courts favorable to the particular person suing, will again push up the costs of training drugs in this article, or spur a supplier exodus.

Mainly because only about 5{c024931d10daf6b71b41321fa9ba9cd89123fb34a4039ac9f079a256e3c1e6e8} of health care malpractice conditions go to demo, according to the Philadelphia Court of Common Pleas, submitting in a plaintiff-helpful location can be a way to search for leverage in settlement negotiations.

“Allowing personalized injury lawyers to go claims from all more than the state to venues with histories of significant payouts — notably Philadelphia — puts all Pennsylvanians’ wellness treatment at hazard,” stated Liam Migdail, a spokesperson for the Clinic and Healthsystem Affiliation of Pennsylvania.

But occasions have modified in the two many years given that the previously limitations were being imposed, an August report from the Pennsylvania Supreme Court’s civil guidelines committee prompt. Medical malpractice lawsuits and payments to victims have declined around the previous 15 many years, the report said.

A 2020 examination from the Legislative and Finances Finance Committee further more discovered it wasn’t distinct that the price of liability insurance policy drove medical practitioners to depart the condition 20 many years ago.

Limiting venues also raises fairness worries, the court’s August examination noted, locating that health care malpractice fits ended up the only individual damage promises in the state minimal to the location where the occasion happened.

“It was seriously disenfranchising plaintiffs who were being bringing clinical error conditions,” explained Burdo, the lawyer now suing Nemours.

Outdoors of Philadelphia, juries in suburban and rural counties have a reputation for getting far more sympathetic to area medical professionals and hospitals than plaintiffs.

“What the old location policies did was to power plaintiffs into counties exactly where the percentage of scenarios that were being unsuccessful approached 80, 90, or even 100{c024931d10daf6b71b41321fa9ba9cd89123fb34a4039ac9f079a256e3c1e6e8},” claimed Steven Wigrizer, a different Philadelphia trial lawyer. “Health centers were massive companies in these counties.”

» Read Additional: A Philly jury has awarded $43.5 million to a former Eagles captain suing his health professionals over a occupation-ending knee damage

From 2017 to 2019, individuals suing a health and fitness-care service provider won jury trials in Philadelphia about 36{c024931d10daf6b71b41321fa9ba9cd89123fb34a4039ac9f079a256e3c1e6e8} of the time, according to state courts details.

Montgomery County juries, by contrast, favored the plaintiffs 12{c024931d10daf6b71b41321fa9ba9cd89123fb34a4039ac9f079a256e3c1e6e8} of the time, and in Lancaster, the plaintiffs won only 9{c024931d10daf6b71b41321fa9ba9cd89123fb34a4039ac9f079a256e3c1e6e8} of circumstances.

Nevertheless, Philadelphia juries dominated in favor of plaintiffs considerably less generally than those in Chester, Bucks, and Delaware counties during the exact same period of time.

Michael Brophy, a Philadelphia lawyer who has represented equally plaintiffs and medical center units, cautioned against reading through too significantly into trends from the initially months of the rule modify. He observed professional medical malpractice circumstances are elaborate and can get many years to convey to demo.

“This is heading to get 1 to two yrs to see the results, to see if there’s an enhance in filings, an maximize in trials,” he stated.

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In a Rare Decision On Abandoned Property Law, The US Supreme Court Rules Against Delaware

In a Rare Decision On Abandoned Property Law, The US Supreme Court Rules Against Delaware

On February 28, 2023, the US Supreme Court docket issued its final decision in the abandoned home lawsuit, Delaware v. Pennsylvania (see https://www.supremecourt.gov/thoughts/22pdf/145orig_kjfl.pdf)

The concern dealt with by the Courtroom centered on which state was entitled to accumulate unclaimed home, which arose from  two money products marketed by banking institutions on behalf of Moneygram: Agent Checks and Teller’s Checks (collectively, the “Checks”).

Next the framework founded in the seminal scenario of Texas v. New Jersey, 379 U. S. 674 (1965), since Moneygram did not have the name and tackle of the homeowners of the Checks, Moneygram experienced been escheating (that is, having to pay in excess of to the state) the money fundamental these dormant Checks to its point out of incorporation, Delaware. 

That rule, paying unclaimed house to the point out of incorporation in occasions the place the identify and deal with of the individual residence owner is not regarded, broadly applies to most residence, apart from for dollars orders and tourists checks.   This exception occurs from a 1974 federal regulation, the Federal Disposition Act (“FDA”), 12 USC  § 2501 et seq), which involves holders of money underlying unused funds orders and vacationers checks (and other identical instruments) to remit these funds to the point out in which the instruments ended up procured, not the holder’s point out of incorporation.

For that reason, the Supreme Courtroom centered on  no matter whether the Checks should be subject to the Texas v. New Jersey framework or regardless of whether they had been similar adequate to income orders so that they, also, as soon as deserted, really should be paid out to the point out where ordered and not the point out of incorporation. 

The Supreme Courtroom held, in the first the vast majority impression penned by new Supreme Courtroom Justice Ketanji Brown Jackson, that the Checks were being in fact similar to revenue orders, and should be escheated to the point out of acquire below the Food and drug administration, and not the condition of incorporation:

When a money solution operates like a dollars order— i.e., when it is a prepaid prepared instrument employed to transmit cash to a named payee—and when it would also escheat inequitably entirely to the Condition of incorporation of the business keeping the funds below our popular-law policies because of to recordkeeping gaps, then it is sufficiently “similar” to a dollars buy to slide presumptively inside the Food and drug administration.  (598 U.S. __ slip op. at 22)

This is viewed as a much more equitable rule, allowing for the assets to be dispersed among a number of states where the industrial exercise happened.

There was a large total of revenue at stake: some estimate Delaware will owe far more than $400 million to the other states based mostly on the outcome in this lawsuit.

The bigger concern is regardless of whether, now that the definition of “money orders” (and related instruments) below the Fda has been widened to include the Checks, will other financial solutions and devices also be topic to a identical resolve?  We foresee that lots of states will be using a closer appear at “prepaid created devices used to transmit money” in order to maximize their deserted assets collections.

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Supreme Court on Abandoned Property Lawsuit

Supreme Court on Abandoned Property Lawsuit

On February 28, 2023, the US Supreme Court docket issued its choice in the abandoned property lawsuit, Delaware v. Pennsylvania (see https://www.supremecourt.gov/opinions/22pdf/145orig_kjfl.pdf)

The issue tackled by the Court docket centered on which state was entitled to accumulate unclaimed assets, which arose from  two fiscal products offered by banking institutions on behalf of Moneygram: Agent Checks and Teller’s Checks (collectively, the “Checks”).

Subsequent the framework proven in the seminal circumstance of Texas v. New Jersey, 379 U. S. 674 (1965), simply because Moneygram did not have the title and deal with of the owners of the Checks, Moneygram had been escheating (that is, paying out over to the state) the resources fundamental these dormant Checks to its condition of incorporation, Delaware. 

That rule, paying unclaimed residence to the state of incorporation in cases the place the title and handle of the particular person property proprietor is not recognized, broadly applies to most assets, besides for money orders and vacationers checks.   This exception arises from a 1974 federal law, the Federal Disposition Act (“FDA”), 12 USC  § 2501 et seq), which involves holders of money fundamental unused dollars orders and tourists checks (and other identical instruments) to remit those people money to the state in which the instruments ended up ordered, not the holder’s point out of incorporation.

Hence, the Supreme Court centered on  whether the Checks must be matter to the Texas v. New Jersey framework or regardless of whether they were being very similar ample to revenue orders so that they, also, at the time deserted, should really be paid out to the point out the place ordered and not the point out of incorporation. 

The Supreme Courtroom held, in the 1st greater part impression penned by new Supreme Courtroom Justice Ketanji Brown Jackson, that the Checks have been in fact very similar to cash orders, and must be escheated to the state of purchase less than the Food and drug administration, and not the point out of incorporation:

When a financial product operates like a revenue order— i.e., when it is a pay as you go published instrument utilised to transmit cash to a named payee—and when it would also escheat inequitably solely to the State of incorporation of the business holding the funds under our widespread-legislation regulations because of to recordkeeping gaps, then it is sufficiently “similar” to a income purchase to slide presumptively inside the Food and drug administration.  (598 U.S. __ slip op. at 22)

This is thought of a extra equitable rule, enabling the residence to be distributed among many states in which the professional activity transpired.

There was a incredible amount of money at stake: some estimate Delaware will owe additional than $400 million to the other states based on the end result in this lawsuit.

The more substantial question is regardless of whether, now that the definition of “money orders” (and identical instruments) under the Fda has been widened to consist of the Checks, will other monetary products and devices also be topic to a equivalent determination?  We foresee that lots of states will be using a nearer glimpse at “prepaid published devices utilised to transmit money” in order to maximize their deserted home collections.  

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States prevail over Delaware in unclaimed property case at the Supreme Court

States prevail over Delaware in unclaimed property case at the Supreme Court

All nine Supreme Court Justices sided with a group of 30 states in a dispute with Delaware over hundreds of millions of dollars of unclaimed checks issued by MoneyGram, a money transfer company. The Court held that the unclaimed checks must be sent to the states where they were purchased, and not to Delaware, the company’s state of incorporation. The case turned on the interpretation of the Federal Disposition Act,1 a federal statute enacted by Congress in 1974, which governs escheatment of money orders “or other similar written instruments.”2 The Court held that the MoneyGram checks were similar to money orders, and therefore the federal statute determines which state can escheat the unclaimed funds.

The case has the potential to put a significant dent in Delaware’s unclaimed property revenue. In 2022, after accounting for amounts returned to property owners, the State’s unclaimed property revenue was $349 million, or approximately 6{c024931d10daf6b71b41321fa9ba9cd89123fb34a4039ac9f079a256e3c1e6e8} of total state revenue.3 Although this number is down from recent years, some reports indicate that Delaware could owe as much as $400 million back to other states solely from this case.

Justice Ketanji Brown Jackson delivered the opinion on February 28, 2023 for a Court that ruled unanimously against Delaware. The MoneyGram case represents the first time the Supreme Court has grappled with escheatment and unclaimed property issues since the early 1990s, when the Court decided Delaware v. New York, 507 U.S. 490, 510 (1993).

Before this case, the State of Delaware had been taking custody of these MoneyGram checks based on the common law priority rule that allows a company’s state of incorporation to take custody of abandoned property when the address of the owner is unknown. Other states, led by Pennsylvania and Arkansas, filed suit against Delaware and argued that, for these MoneyGram checks, the Federal Disposition Act overrides the common law rule. The Federal Disposition Act provides that unclaimed funds from money orders or “other similar written instruments” are to be escheated to the state where the checks were purchased. The parties disagreed on which rule should apply: the federal statute or the common law.4

The Supreme Court decided the case on narrow grounds, finding that the MoneyGram instruments are “similar” to money orders and therefore subject to the federal statute, regardless of whether they are actually money orders. The Court adopted a practical approach and reasoned that the MoneyGram checks are similar to money orders in two key respects. First, they are similar in function and operation to money orders. And second, they have similar characteristics to the types of instruments Congress was attempting to address in the statute. Specifically, like money orders, MoneyGram had generally not collected the addresses of the creditors, and so if the common law priority rules were to apply, “then the abandoned proceeds would escheat inequitably solely to the State of incorporation, just like the money orders expressly referenced in the statute.”5

The Court’s decision was based, in part, on the practical consideration of avoiding the “inequitable” result of having all of the money go to the state of incorporation. The Court reasoned that the purpose of the statute—establishing a place-of-purchase standard for these payment instruments—was to prevent a “windfall” for one state over all others. Justice Jackson wrote for the Court that “the [Federal Disposition Act’s] text provides a solution for the problem of the inequitable distribution of escheats, and that solution expressly eschews requiring entities like Western Union to keep adequate records. Inadequate recordkeeping is thus highly relevant to the interpretive question of when the [Federal Disposition Act], rather than the common law, should apply to the escheatment of the intangible property at issue.”6

The Supreme Court found Delaware’s arguments to be unpersuasive because:


The remaining issue in the case involves the determination of the amounts owed by Delaware back to the other states, and the impact on state unclaimed property regimes, particularly in Delaware. For the liability determination, the case will go back to the Special Master to determine the amounts owed and any other remaining issues.

Key Takeaways:


  1. The Court seemed guided by the practical consideration of avoiding a “windfall” for one state over all others.

  2. By deciding the case on narrow grounds, the Court avoided wading into other potentially disputed unclaimed property issues, such as reconsideration of the common law priority rules. Other unclaimed property cases could find their way to the Supreme Court in future terms.

  3. The potential impact on Delaware and its unclaimed property program remain to be seen. The State could be required to distribute hundreds of millions of funds to other states based on the ruling in this case.


_______________


1 The Federal Disposition of Abandoned Money Orders and Traveler’s Checks Act, 12 U.S.C. § § 2501–03.

2 Delaware v. Pennsylvania, No. 145, 146, slip op. at 2, 9 (2023).

3 https://financefiles.delaware.gov/DEFAC/12-22/Revenue.pdf

4 A Special Master appointed by the Supreme Court initially agreed with Pennsylvania and the other states in his First Interim Report, finding that the federal statute and not the common law priority rules should apply to these disputed instruments. The Special Master later changed his recommendation after oral argument and issued a Second Interim Report, where he found that (1) some of the disputed instruments fell within the category of “other similar written instrument,” but would not be included in the category of “money order,” and (2) to the extent the disputed instruments are drawn by a bank as drawer, the disputed instruments would fall within the statute’s “third party bank checks” exception.

5 Delaware v. Pennsylvania, No. 145, 146, slip op. at 13–14 (2023).

7 Id. at 19 n.13.


If you have any questions about this Legal Alert, please feel free to contact any of the attorneys listed or the Eversheds Sutherland attorney with whom you regularly work.

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As U.S. Supreme Court weighs YouTube’s algorithms, ‘litigation minefield’ looms

As U.S. Supreme Court weighs YouTube’s algorithms, ‘litigation minefield’ looms
  • Court to listen to arguments on Tuesday in Portion 230 case
  • Web firms protected from liability for person written content
  • Slain woman’s household appeals ruling in YouTube dispute

WASHINGTON, Feb 17 (Reuters) – In 2021, a California point out courtroom threw out a feminist blogger’s lawsuit accusing Twitter Inc (TWTR.MX) of unlawfully barring as “hateful carry out” posts criticizing transgender persons. In 2022, a federal court in California tossed a lawsuit by LGBT plaintiffs accusing YouTube, element of Alphabet Inc (GOOGL.O), of limiting material posted by gay and transgender people today.

These lawsuits were being amid many scuttled by a powerful sort of immunity enshrined in U.S. legislation that addresses web firms. Portion 230 of the Communications Decency Act of 1996 frees platforms from legal accountability for information posted on the web by their people.

In a significant situation to be argued at the U.S. Supreme Court on Tuesday, the 9 justices will tackle the scope of Portion 230 for the initial time. A ruling weakening it could expose web businesses to litigation from each individual route, lawful specialists explained.

“You can find going to be a lot more lawsuits than there are atoms in the universe,” regulation professor Eric Goldman of the College of Santa Clara Legislation School’s Higher Tech Law Institute said.

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The justices will listen to arguments in an charm by the spouse and children of Nohemi Gonzalez, a 23-year-outdated lady from California shot dead throughout a 2015 rampage by Islamist militants in Paris, of a lower court’s ruling dismissing a lawsuit in opposition to YouTube’s proprietor Google LLC trying to find monetary damages, citing Segment 230. Google and YouTube are section of Alphabet.

The spouse and children claimed that YouTube, by its personal computer algorithms, unlawfully suggested movies by the Islamic State militant group, which claimed duty for the attacks, to specific buyers.

A ruling in opposition to the company could produce a “litigation minefield,” Google explained to the justices in a brief. These a choice could alter how the world-wide-web is effective, earning it less practical, undermining cost-free speech and hurting the economy, according to the corporation and its supporters.

It could threaten providers as diversified as look for engines, job listings, products assessments and shows of related news, tunes or leisure, they included.

Portion 230 protects “interactive laptop companies” by guaranteeing they cannot be taken care of as the “publisher or speaker” of details delivered by end users. Authorized authorities note that providers could make use of other authorized defenses if Part 230 protections are curbed.

Phone calls have appear from throughout the ideological and political spectrum – including Democratic President Joe Biden and his Republican predecessor Donald Trump – for a rethink of Section 230 to guarantee that firms can be held accountable. Biden’s administration urged the justices to revive the Gonzalez family’s lawsuit.

‘GET OUT OF JAIL FREE’

Civil rights, gun management and other groups have explained to the justices that platforms are amplifying extremism and despise speech. Republican lawmakers have stated platforms stifle conservative viewpoints. A coalition of 26 states mentioned that social media companies “do not just publish” consumer material anymore, they “actively exploit it.”

“It’s a huge ‘get out of jail free’ card,” Michigan State College legislation professor Adam Candeub stated of Portion 230.

Grievances versus companies range. Some have qualified the way platforms monetize written content, put adverts or reasonable information by eliminating or not eradicating specified substance.

Authorized statements typically allege breach of deal, fraudulent small business practices or violations of state anti-discrimination laws, such as centered on political sights.

“You could have a situation the place two sides of a very controversial concern could be suing a platform,” mentioned Scott Wilkens, an attorney at Columbia University’s Knight To start with Amendment Institute.

Candeub represented Meghan Murphy, the blogger and writer on feminist difficulties who sued right after Twitter banned her for posts criticizing transgender women of all ages. A California appeals court dismissed the lawsuit, citing Area 230, due to the fact it sought to keep Twitter liable for content material Murphy developed.

A independent lawsuit by transgender YouTube channel creator Chase Ross and other plaintiffs accused the video clip-sharing platform of unlawfully proscribing their written content mainly because of their identities even though permitting anti-LGBT slurs to keep on being. A choose blocked them, citing Area 230.

ANTI-TERRORISM ACT

Gonzalez, who had been learning in Paris, died when militants fired on a group at a bistro for the duration of the rampage that killed 130 people.

The 2016 lawsuit by her mother Beatriz Gonzalez, stepfather Jose Hernandez and other family accused YouTube of delivering “material assist” to Islamic Point out in element by recommending the group’s films to selected consumers based on algorithmic predictions about their passions. The suggestions helped distribute Islamic State’s concept and recruit jihadist fighters, the lawsuit mentioned.

The lawsuit was brought underneath the U.S. Anti-Terrorism Act, which lets Americans get well damages associated to “an act of global terrorism.” The San Francisco-based mostly 9th U.S. Circuit Court of Appeals dismissed it in 2021.

The enterprise has captivated assistance from a variety of technological know-how businesses, scholars, legislators, libertarians and rights groups apprehensive that exposing platforms to legal responsibility would drive them to clear away content at even the trace of controversy, harming free of charge speech.

The company has defended its tactics. With no algorithmic sorting, it explained, “YouTube would play each individual online video at any time posted in just one infinite sequence – the world’s worst Tv channel.”

Reporting by Andrew Chung Enhancing by Will Dunham

Our Benchmarks: The Thomson Reuters Believe in Ideas.

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U.S. Supreme Court spurns attorney-client privilege fight in crypto tax probe

U.S. Supreme Court spurns attorney-client privilege fight in crypto tax probe

Jan 23 (Reuters) – The U.S. Supreme Court docket on Monday threw out a circumstance about the scope of lawyer-client privilege involving a law firm’s bid to withhold documents from prosecutors relevant to a cryptocurrency-endorsing consumer in a tax investigation.

The unsigned one-sentence ruling “dismissed as improvidently granted” an enchantment by an unnamed legislation company of court docket orders keeping it in contempt for not turning over information relevant to a person of its clientele in reaction to a federal grand jury subpoena.

The justices did so only two weeks immediately after hearing arguments in the scenario. A lot of of the aspects of the case are unclear, as the names of the regulation organization and consumer have been stored from the general public history throughout the typically secretive grand jury probe.

According to court docket papers, the legislation organization specializes in international tax difficulties and recommended a consumer the U.S. Office of Justice says was an early promoter of bitcoin who expatriated himself from the United States in 2014.

The regulation organization suggests it ready the client’s tax returns and also offered legal advice on how to determine ownership of cryptocurrency property and value them.

In reaction to a grand jury subpoena looking for documents similar to the preparing of the client’s tax returns, the agency created over 20,000 webpages of records but withheld many others, citing lawyer-customer privilege.

When a court requested it to change more than about 54 some others, it resisted. All those information, the business said, have been “dual-reason” communications that contained lawful assistance as perfectly as non-authorized, advice regarding the preparation of its tax returns.

But the San Francisco-based 9th U.S. Circuit Courtroom of Appeals upheld the decrease-court docket decide in expressing legal tips experienced to be the “principal” goal of the communication to qualify for lawyer-client privilege.

That ruling was at odds with what some other federal appeals courts have ruled in similar situations, and numerous lawyers’ groups like the American Bar Affiliation filed briefs urging the justices to undertake a much more expansive typical for privilege.

In the course of arguments on Jan. 9, some justices questioned why the 9th Circuit’s normal was wrong, with liberal Justice Sonia Sotomayor noting that “the huge greater part of states use the primary function test.”

Liberal Justice Elena Kagan observed that no federal appeals court docket till 2014 experienced instructed a diverse conventional must utilize. She jokingly questioned a lawyer for the legislation agency to remark on “the historic authorized principle of ‘if it ain’t broke, you should not deal with it.’

Reporting by Nate Raymond in Boston enhancing by Jonathan Oatis

Our Specifications: The Thomson Reuters Have faith in Rules.

Nate Raymond

Thomson Reuters

Nate Raymond experiences on the federal judiciary and litigation. He can be reached at [email protected].