* Benjamin N. Cardozo School of Law, J.D. 2020. The author is grateful to Professor Peter
Goodrich for his thoughtful comments throughout this project; to the editors of the Cardozo Law
Review for their efforts in developing and editing this Note; and to his family and friends for their
support. Most of all, the author would like to thank his dear wife, Feigie, for her encouragement
and support, and particularly for her constant review of and advice on this project.
