* Notes Editor, Cardozo Law Review, Volume 41. J.D. Candidate, Benjamin N. Cardozo School of Law, May 2020; B.A., St. John’s University, 2015. I would like to thank Professor Felix Wu, my faculty advisor, for his generous feedback and guidance; my Notes Editor, Ava Schein, for her sincerity, advice, and encouragement; and all the editors of Volumes 40 and 41 of Cardozo Law Review for their diligence in preparing this Note for publication.
