* J.D. Candidate (June 2020), Benjamin N. Cardozo School of Law. Many thanks to Prof.
Buccafusco for his support and thoughtful comments throughout the writing of this Note. I would also like to thank friends Joe Holden and Clyde Rastetter for providing much-needed encouragement, feedback, and inspiration. I am incredibly grateful to the entire Cardozo Law Review team for the work and care they put into the publication of this Note. All mistakes are my own.
