* Associate Editor, Cardozo Law Review; J.D., Benjamin N. Cardozo School of Law, 2020; B.A., Union College, 2017. Thank you to all the editors of the Cardozo Law Review, for their often overlooked but important work; to Professor Sam Weinstein, for his advice, critique, and encouragement throughout the process of writing this Note; and to my family, for their love.
