L2 HOMEWORK FOR Week 6: November 10th

Study the introduction to "The Electoral System", p. 76-78.

Grammar exercise 2 p. 79.
Grammar exercise p. 86.

Read Text n°2 p. 81-82 and make a list of the arguments presented the document. Reformulate these arguments in your own words. Answer the questions to exercises 1, 2 and 3, p. 82-83.

(You may also read the n° 1, which we will also be discussing in class.)

Presentation topic: The students giving a presentation will study Text n° 1: "In Defense of the Electoral College".


We will start the class by correcting Ex. 3 p. 60 (which was supposed to be prepared for the class on 'Article II: The President', but  has not been corrected yet).


Classes on Monday Nov. 10th and on Monday Nov. 17th

NB: There will be no English class on Tuesday Nov. 4th and on Tuesday Nov. 11th.
Instead, the classes will take place respectively on Monday Nov. 10th  and on Monday Nov. 17th in room 05.

The class on Monday Nov. 10th will be dedicated to "The Electoral System".
The class on Monday Nov. 17th will be dedicated to "Art. III, The Federal Judiciary"

G 8 will have class from 2.05 pm to 3.35 pm (on Monday Nov. 10th  and on Monday Nov. 17th)
G 9 will have class from 3.40 pm to 5.10 pm (on Monday Nov. 10th  and on Monday Nov. 17th)

NOTE that you will have 2 Legal English classes the same week: On Monday Nov. 17th and on Tuesday Nov. 18th . The IN-CLASS EXAM, will take place on NOVEMBER 18th!

M1 Homework for Week 6 (Nov. 4th / Nov. 6th)

1. Study the following case: A 15 Eddings v Oklahoma. (See booklet: p. 15-16).

2. Study the notes summary on the Fifth and the Sixth Amendments that have been posted on the blog.

3. Study the part on Criminal Law and Procedure of the Yellow booklet. (We will discuss this chapter in class.)

In order to practice your written English, you may, if you wish, finish the commentary on Berghuis v. Thompkins and turn it in so that I can correct it for you.

NB: On account of the fact that Nov. 11th is a bank holiday, the English class on Week 7 will take place on Wednesday Nov. 12th, at 2.05 pm in room 202. This information concerns students attending tutorial n° 2, normally scheduled on Tuesdays.

As usual, Tutorial n° 52, will take place on Thursday Nov. 13th at 9.20 am in room 606.

Summary of United States v. Alvarez (2012), p. 31-32.

L3 First Amendment

United States v. Alvarez (2012)

In United States v. Alvarez (2012), the question to the court is whether the U.S. Government’s Stolen valor Act, which makes it a crime to falsely claim receipt of military decorations, contravenes the First amendment by representing a restriction on the Freedom of speech.

As the Stolen valor Act represents a content-based restriction on speech, the onus is on the government to prove the constitutionality of the act, and the Supreme Court applies the “most exacting” level of scrutiny to determine whether the act is constitutional or not.

The Government argued that false statements have no value and therefore have no First Amendment Protection, and that the Stolen valor Act is therefore constitutional.

However, the U.S. Government’s argument did not prevail / the court rejected the U.S. Government’s argument:

The Court considered that “false statement” is not part of the few categories of speech which are unprotected by the First amendment (such as obscenity, fraud, true threats, and speech presenting some grave and imminent threat to the government) and which the government has the power to prevent.

To justify its restriction on false statements, the government should be able to demonstrate that there is direct link between a false statement and an injury.

Besides, the U.S. government could not refer to a previous ruling where the Supreme Court had to determine the constitutionality of an act which exclusively targeted falsity.

In the earlier cases, the false statements had been refused protection not simply because they were false, but because they were part of another criminal offense or civil wrong (fraud, libel). In all the previous cases, there was a clear connection between a false statement and a legally recognizable harm, the Supreme Court argued. (“The question of false statement was not irrelevant but not determinative.”)

In contrast, the Stolen Valor Act makes certain speech illegal, no matter what the circumstances or the motivations of the speaker. Declaring the Stolen Value Act constitutional, would thus give the government the power to establish a list of subjects about which false statements are punishable. (The ‘Slippery Slope’ argument)

Finally, whenever the Government seeks to regulate protected speech, the restriction must be the “least restrictive means among available, effective alternatives”. This does not prove to be the case either in this situation.

L3 Homework for Week 6

Study the introduction to the 2nd Amendment, p. 51-53.
Study the glossary, p. 66.
Exercises 1 & 2, p. 65. ('Fill in the blanks' and 'Choose the Right Word')

+ for Groups 8 and 9: Ex E : Key Gun Control Legislation, p. 58, 59, 60.

G 42, 43, 44, 51: READ the TEXT p. 55-57 District of Columbia v. Heller (2008) and make a list of the new vocabulary. Find a definition for each new term.

Presentation topics for Week 6:
G 42, 43, 44, 51: District of Columbia v. Heller (2008)

Summary on Judge Moore and the Godless 14th Amendment (Text 4. p. 11-12)

Text 4. p. 11-12 

Judge Moore and the Godless 14th Amendment

By placing a monument inscribed with the Decalogue in the Alabama judicial building, Judge Moore is accused of having infringed the Establishment clause of the First Amendment, according to which Congress shall make no law that would establish an official religion or would interfere with the free exercise of religion.

A federal district court ordered that the Decalogue should be removed.

When she says that the Decalogue represents a civilizing moral code to which nobody could object, the journalist seems to be siding with Judge Moore.

The Bill of Rights, she argues, was originally intended to put limits on the power of federal government. She claims that “by vesting its enforcement in the national rather than in the state governments”, (i. e. by enabling the federal government to force state governments to abide by its provisions) not only does the 14^th Amendment distort the original intention (/changes the scope) of the Bill of Rights but it also affects the principle of Federalism, which is guaranteed by (depends on / is based on) the balance of authority between federal power and state power and by the limits placed on the power of the federal government. 

The Federal and State Judicial Systems

The Federal and State Judicial Systems

The systems of courts exist at two levels: at federal level and at state level.

                 I.     State courts

More than 99% of all court cases are heard in state courts. The majority of criminal cases involve violations of state laws like murder, fraud, theft and assault. If such case is brought to trial, it will be heard in a state trial court.

Usually there are 2 or 3 levels of jurisdiction: the State Trial Court, the Appellate Court, and the State’s Supreme Court.

Likewise in civil cases, most cases are brought in the courts established by the state in which the activity in question took place.

For example, a patient bringing suit against a physician for malpractice would file the suit in the appropriate court in the state where the alleged malpractice occurred

The judge hearing the case would apply state law and state precedent to the matter at hand.

Although each state has its set of laws, these laws have much in common. In the case of contract law, most states have adopted the Uniform Commercial Code in order to reduce interstate differences. In areas such as family law, however, which covers such matters as divorce and child custody arrangements, state laws vary greatly.

In criminal law, possible punishments vary from one state to another (like the death penalty). And some acts which are legal in one state can be illegal in another one. For example, prostitution is legal in some Nevada counties and it outlawed in all other states.

But in both civil and criminal matters most cases are settled before trial through negotiated agreements between the parties.

In criminal cases these agreements are called plea bargains. A defendant agrees to plead guilty in return for state’s agreement to reduce the severity of the criminal charge the defendant is facing.

1.    Courts of Limited Jurisdiction and Courts of general jurisdiction

We usually distinguish between 2 sets of trial courts: Courts of Limited Jurisdiction and Courts of General Jurisdiction

Courts of Limited Jurisdiction deal with specific types of cases. They are located near the County courthouse and are presided over by a single judge:

·      Probate court

·      Family court

·      Traffic court

·      Juvenile court

·      Small claims court

·      Municipal court

Courts of general jurisdiction hear both civil and criminal cases outside the jurisdiction of the trial Courts of limited jurisdiction.

There is usually a single judge to decide issues of law, and often a jury to decide issues of fact. (These courts have a variety of names: circuit courts, superior courts, courts of common pleas, supreme court (ex. New York).)

These courts may also hear appeals from trial courts of limited jurisdiction

2.    Appeals

If the defendant is convicted, he or she may appeal the conviction to a higher court such as a state appellate court and from there to a state’s supreme court.

Such appeals are usually a matter of right, which means that the court must hear them. Courts address only alleged procedural mistakes and errors of law. They do not review facts. They do not examine additional evidence. Usually, these courts sit in a panel of 3 judges.

3.    Highest State Courts

They are not necessarily called a supreme court. As in Maryland, they may be called Court of Appeal. They sit in panels of 3, 5, 7 or 9 justices.

In states with intermediate appellate courts, the highest state courts usually have discretionary review as to whether to accept a case.

In states without an intermediate state court, cases may usually be taken to the highest state court as a matter of right.

4.    Original jurisdiction of State’s Supreme Courts

Many State Supreme Courts have original jurisdiction in certain matters. Ex: They have original jurisdiction over Controversies regarding Elections and the Reapportionment of Legislative Districts.

NB vocabulary: An appeal lies from a court to higher court / to lodge and appeal / to have jurisdiction

               II.     Structure of the federal judicial system

At the top of this structure, there is the Supreme Court, created by the Constitution. It is the only federal court mentioned by the Constitution. (See Article III). But Article I (section 8) and Article III (section 1) of the Constitution also gives Congress the power to create other federal courts, (which Congress did in 1789 by creating District Courts).

Just below we can find 13 Appellate Courts of the USA, (and the Military Appellate Court). At the bottom of the pyramid, we can find 94 District Courts as well as specialized courts like the Financial Court, the Veteran Appellate Court or the International Trade Court.

Each State has at least one District Court. Then the number of federal judges depends on the population. The USA is divided in 94 districts. Each district has at least one Federal Judge. In California, they are over 500 in all the 4 districts of the State.

District courts deal with 90% of all Federal Cases. The number of cases has been increasing throughout the years but Congress can decide to increase the number of courts.

Whenever one side disagrees with the judgment, it goes to appeal to federal Appellate Courts also named Circuit Courts, created in 1891 to help the Supreme Court. The US territory is divided into 13 sectors called circuits. There is one Federal Appellate Court per circuit.

At the top of the pyramid, is the Supreme Court of the USA.

              III.     Competence of Federal courts

The federal judiciary was given jurisdiction in controversies that might not, or could not, be handled appropriately by the courts of just one state (Article III, Section 2, §1):

The judicial Power shall extend to all Cases, in Law and Equity, arising under this Constitution, the Laws of the United States, and Treaties made, or which shall be made, under their Authority; — to all Cases affecting Ambassadors, other public Ministers and Consuls; — to all Cases of admiralty and maritime Jurisdiction; — to Controversies to which the United States shall be a Party; — to Controversies between two or more States; — between a State and Citizens of another State (Modified by Amendment XI (1795) which reads : “The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.”) — between Citizens of different States; — between Citizens of the same State claiming Lands under Grants of different States, and between a State, or the Citizens thereof, and foreign States, Citizens or Subjects.

In all Cases affecting Ambassadors, other public Ministers and Consuls, and those in which a State shall be Party, the Supreme Court shall have original Jurisdiction.

In all the other Cases before mentioned, the Supreme Court shall have appellate Jurisdiction, both as to Law and Fact, with such Exceptions, and under such Regulations as the Congress shall make.

History has shown that the vast majority of cases in federal courts have belonged to one of two broad categories of subject-matter jurisdiction:

1.    Federal question cases:

These are lawsuits in which plaintiffs base their claims on federal law. For example:

·      A retired woman brings an action against the government to obtain federal Social Security (pension) benefits that were denied her.

·      A man sues the company that fired him in violation of federal anti-discrimination law.

·      One smartphone manufacturer files a money claim against a competitor for copying its product features (called "patent infringement"). See Article I, Section 8.

A considerable amount of federal question litigation involves judicial review: in the context of an individual case, a court examines a government act (legislative or executive, federal or state) to determine whether or not it is constitutional (conforms to the US Constitution).

2.    Diversity of citizenship cases:

"Controversies [...] between citizens of different states." Federal court jurisdiction may apply if the opposing parties (persons or companies) in litigation are geographically "diverse".

Congress has legislated so that today a federal court may take a diversity case only if the amount in controversy exceeds $75,000.

Examples:

·      A patient from New Jersey sues a New York doctor for malpractice after a disastrous operation.

·      A company with headquarters in Nevada brings an action against its supplier based in California for providing defective merchandise.

(The other types of cases listed in Art. III, Section 2 involve, similarly, either federal rather than individual state interests or other forms of diversity; jurisdiction in the latter was partly modified by the 11^th Amendment (1795))

3.    Concurrent jurisdiction and “forum shopping”:

It is important to note here that in Article III, federal jurisdiction was not described as being exclusive. State courts might also be competent for many cases. Over the years, Congress has established a number of rules to clarify the issue of concurrent jurisdiction. (The jurisdiction of state courts extends in theory to all cases which do not fall within the exclusive jurisdiction of federal courts. This obviously includes areas in which states have legislated more extensively than the federal government.)

State and federal courts have concurrent jurisdiction on some diversity of citizenship cases (when less than $75,000 is claimed in damages) and in nearly all federal question cases. Plaintiffs will then decide which court is best for them. This process is called “forum shopping”. The plaintiff will consider such things as the proximity of the court, and differences in the judges or jury panel.  

Example of dual jurisdiction: Iris Simpson, a Michigan citizen sues Police officer Jack Orwell (from Michigan) for wrongly arresting her. She bases her case on a federal statute and asks for $9,000 in damages. Despite the fact that Irish seeks less than $75,000 and that Jack and Iris are both citizens of the same state, a federal district court in Michigan has jurisdiction to hear the case, as it is based on a federal statute. Irish could also decide to go before a state court, as she was arrested in the state where the 2 parties live. (See The Belin Book, p. 163.)

In describing the federal judicial power, Article III included the distinction between original jurisdiction (for cases heard at first instance, at trials) and appellate jurisdiction (for parties contesting the trial decisions). 

As inferior federal trial courts were soon to be created, the Supreme Court was given original jurisdiction for only a few types of cases:

In all Cases affecting Ambassadors, other public Ministers and Consuls, and those in which a State shall be Party, the Supreme Court shall have original Jurisdiction. (“The U.S. Constitution, Article 3, Section 2, § 2”)

  Congress has since empowered lower federal courts to try most of those cases, leaving exclusive SC first instance jurisdiction only for conflicts between states (e.g., border disputes).

   It was thus understood that federal trial courts would handle most cases brought under federal jurisdiction, although it was also understood that the state courts, with their own categories of jurisdiction as well, would always hear the vast majority of judicial cases across the United States.

4.    Appeals from state-level courts heard in Federal Courts:

a-    Federal courts as appellate courts:

Federal courts also act as appellate courts. They hear appeals from state-level courts.

Individuals found guilty of breaking state criminal law can appeal their conviction by raising a constitutional issue and asking a federal court to determine whether the state’s actions were consistent with the requirements of the U.S. Constitution. An appellant may assert that the state court denied him or her the right to counsel (6^th Amendment), imposed excessive bail (8^th Amendment), or denied the appellant due process (5^th and 14^th Amendments). Under such circumstances, an appellant can ask the federal court to reverse his or her conviction.

But it’s not systematic since federal courts only look at cases they consider valuable on the basis of issues at stake and if the appellant has exhausted all other possibilities within state courts.

b-   The Supreme Court:

The decision of state supreme courts may also be appealed to the US Supreme Court if the state court’s decision goes against a previous US Supreme Court decision or raises some important question of federal law. Such appeals are accepted by the US Supreme Court at its discretion.

The decisions of the Federal courts are important because it is in the federal courts that the Constitution and federal laws that govern all Americans are interpreted and their meaning established. It is also in the federal courts that the powers and limitation of the national government are tested. They ultimately govern the American judicial system.

            IV.     The US Supreme Court

The US Constitution has created a Supreme Court but does not say much about its powers. (The Constitution does not say anything about the organisation of the other federal courts, which can in theory be created and suppressed.) Congress clarified this point through the 1789 Judiciary Law.

1.    The structure of the Supreme Court

The Supreme Court is located in a building next to the US Congress, Washington DC. It is composed of 9 judges (Justices to the Supreme Court). They are appointed by the President and confirmed by the Senate. Their mandate has no time limit. So they’re independent and free from any pressure.

The Supreme Court does not specify the number of justices that should sit on the supreme court. Congress has the authority to change the court’s size.  Congress set the number of justices at 9 in 1869 and the court has remained that size ever since.

“The Switch in time that saved nine”:

In 1937, Franklin Delano Roosevelt was infuriated by the Supreme Court, which had struck down several New Deal Programs. Roosevelt asked Congress to enlarge the Court so he could add a few sympathetic justices to the bench. The Congress balked at Roosevelt’s “court packing”, but the Supreme Court gave in to the pressure started to take a more favourable view of his policy initiatives. The President, in turn, dropped his efforts to enlarge the court.

The Constitution does not explain what qualification a judge must have. But before appointing a judge, the President always has a look at:

Career and personality: Most of the Justices to the Supreme Court are law specialists or top ranking officials (former member of the government). Most of them have traditionally been a judge of a State Court (or a federal District court). Recommendations from the American Bar Association (le barreau américain) are often followed by an appointment, which shows the importance of the professional aspect.

Political tendencies: That habit has always existed even if Justices and Presidents deny it. In recent years, Justices appointed have often been from the same party as the President.

Judicial philosophies: The President often takes into account the point of view of a candidate on important judicial issues.

Senatorial courtesy: Before suggesting their choice to the Senate, Presidents traditionally ask the point of view of the Senators of the State from which the candidate is originated. If at least one of the Senators refused, the President almost always changed his mind. But if the President stood on his position, the Senators would probably support their colleague and reject the appointment.

2.    The Supreme Court as an Original court

As an original court, the Supreme Court hears cases:

-       Between the USA and a State

-       Between two or more states

-       Involving foreign ambassadors or ministers

-       Brought by one state against citizens of another state or against a foreign country

But these first proceeding hearings represent a small minority of the Supreme Court’s activities.

3.    Highest Appellate court and first proceedings: Judicial Review

The US Supreme Court is the head of the Judicial Branch. It’s also the highest Appellate Court in the USA. 

The US Supreme Court has the power of Judicial Review, that is to say the authority and the obligation to review any lower court decision whenever there is an important issue of public law.  This is the most important part of its job. Anyone involved in a trial has the right to appeal.

4.    Judicial review of acts of Congress and State Actions

The Supreme Court has the power to review acts of Congress as well as State actions and determine if there’re constitutional or not. That’s why the Supreme Court is more than a judicial agency, it’s also a lawmaking body.

5.    Judicial review and Lawmaking

When courts of original jurisdiction apply existing statutes or past cases directly to citizens, the effect is the same as legislation. It’s called common law. Similar cases are often judged the same way.

Appellate courts work in another way. When an Appellate court gives its decision, it does two things. First it decides who wins. But at the same time it expresses its understanding of the case to the lower courts for future similar cases. It sets precedents and in effect establishes laws (common law). But they are laws governing only the behaviour of the judiciary because the US Supreme Court always tries to make it clear how it ruled a case. And these explanations give guidance to lower courts but also affect citizens who can decide whether to take a case to court or not.

6.    How Cases reach the Supreme Court

a-    Rules of Access

Over the years, the courts have developed specific rules that govern which cases within their jurisdiction they will and will not hear. In order to have access to the courts, cases must meet certain criteria. These rules of access can be broken into three major categories:

·      Cases or controversy

·      Standing

·      Mootness

Article III of the Constitution and Supreme Court decisions define judicial power as extending only to “cases and controversies”. This means that the case before a court must be an actual controversy with two truly adversary parties and not a hypothetical one.

The Courts have interpreted this language to mean that they do not have the power to render advisory opinions to legislatures or agencies about the constitutionality of proposed law or regulations. Furthermore, even after a law is enacted, the courts will generally refuse to consider its constitutionality until it is actually applied.

Parties to a case must also have standing, that is, they must show that they have a substantial stake in the outcome of the case. The traditional one was to show injury to oneself: personal, economic or even aesthetic. For example if a group wants to come up with a case of injury, each member of the group must show injury. So if a group comes up with a case of general interest like environment, it does not provide the group with sufficient basis for standing.

The third criterion is mootness. In theory, cases brought too late are disqualified (too late means the problem may have been solved by other means or not relevant anymore). So the case must be brought before the dispute has become moot, irrelevant.

Mootness is subject tot the discretion of the courts, which have begun to relax the rules of mootness, particularly in cases where a situation that has been resolved is likely to come up again. In the abortion case Roe v. Wade (1973), for example, the Supreme Court rejected the lower court’s argument that because the pregnancy had already come to term, the case was moot. The court agreed to hear the case because no pregnancy was likely to outlast the lengthy appeals process.

Of course, putting these criteria aside, the Supreme Court is most likely to accept cases that involve conflicting decisions by the federal circuit courts; cases that present important questions of civil rights or civil liberties and cases in which the federal government is the appellant. Ultimately justices decide which case they’re going to examine.

b-   The Writs

Decisions handed down by lower courts can today reach the Supreme Court in one of three ways:

-       Through a writ of certiorari

-       Through a writ of habeas corpus

-       On a writ of appeal

Distinction between a writ and an appeal: A writ is an order from a higher court to a lower court aimed at reviewing a specific detail of a case which cannot be raised on appeal.

The great majority of cases reach the Supreme Court through the writ of certiorari (from the Latin “to make more certain”), which is granted whenever 4 out of 9 justices agree to review a case. This is called to “grant cert”.  

The Supreme Court was once so inundated with appeals that in 1925 Congress enacted laws giving it some control over its caseload with the power to issue writs of certiorari. Rule 10 of the Supreme Court’s own rules defines certiorari as “not a matter of right, but of sound judicial discretion… granted when there are special and important reasons therefore”. The reasons provided for in Rule 10 are:

-       Where a state court has made a decision that conflicts with previous Court decisions

-       Where a state court has come up with an entirely new federal question

-       Where one court of appeals has rendered a decision in conflict with another

-       Where there are other inconsistent rulings between two or more courts or states

-       Where a single court of appeals has sanctioned too great a departure by a lower court from normal judicial proceedings (a reason rarely given)

The writ of habeas corpus is a fundamental safeguard of individual rights. Its historical purpose is to enable an accused person to challenge arbitrary detention and to force an open trial before a judge.

In 1867, however, Congress’s distrust of Southern courts led it to confer on federal courts the authority to issue writs of habeas corpus to prisoners already tried or being tried in state courts, where the constitutional rights of the prisoner were possibly being violated. This writ gives state prisoners a channel towards the Supreme Court review in case their direct appeal from the highest state court fails.

The writ of habeas corpus is discretionary: the Court can decide which cases it will review. Most cases accepted by a writ of habeas corpus involve prisoners on death row. Since 1996, the Court has limited prisoners’ filing of writs of habeas corpus.

Writs of appeal are available to all litigants. They concern cases where a state law directly conflicts with the Constitution or a federal law, or where the United States is party to a civil suit. These situations rarely occur. The Court often remand the cases to a lower court rather than fully reviewing them.

c-    The role of the Solicitor General

The Solicitor General is the third most important person in the Justice Department (after the Attorney General and the Vice Attorney General). But he is the top government defence lawyer in almost all cases involving the government as a party.

The role of the Solicitor General is to regulate the flow of cases. Other attorneys can do it but he has greatest control with no review of his or her actions by any authority.

7.    The Supreme Court’s procedures

a-    The preparation

When a case is accepted, both sides must prepare briefs – written documents in which attorneys explain why the court should rule in favour of their client. Briefs are filled with references to precedents to show that other courts have often ruled the same way as the Supreme Court should do.

At the same time, there are often sympathetic interest groups coming to support one side. They write amicus curiae (friend of the court) briefs to claim support.

b-   Oral Argument

The next stage consists in both attorneys (both sides) to appear before the Court to present their position and answer questions. Each attorney has only half an hour, including interruptions and questions.

c-    The Conference

The Court discusses the case in its Wednesday or Friday conference presided by the Chief Justice who speaks first. It’s a secret conference. They reach a decision on the basis of a majority vote.

d-    Opinion Writing

Then one of the members of the majority who voted for the decision writes an opinion. The Chief Justice decides who will write. This decision is important because it can change the signification of the decision. Every opinion of the Supreme Court is considered as a precedent for future cases. Differences in wording or emphasis can have important implications. But the Supreme Court always expresses its decisions in terms of law and precedent.

e-    Dissent

Justices who disagree with the decision of the majority may choose to express their disagreement in the form of a dissenting opinion. Dissent can also be used to signal that people defeated are still supported by some Justices. Dissent plays an important role because it gives lawyers a reason to bring such cases to appeal. And it shows that even if the Court speaks with a single opinion, it’s still the opinion of a majority.

Bibliography:

Lowi Theodore J. and Benjamin Ginsberg, American Government, New York, Norton, 2002. 

The English of Law: U.S. Law & Politics, Paris, Belin Sup, 2007.