arg_comp/held_out.json

[
  {
    "file": "Docket23-1275_Brief001.pdf",
    "text": "I. The any-qualified-provider provision does not create individual rights enforceable under 42 U.S.C.  1983\nA. Spending Clause statutes must unambiguously confer individual rights to be privately enforceable under Section 1983\nB. The any-qualified-provider provision does not unambiguously confer individual federal rights\nC. [MISSING]\nD. Other enforcement mechanisms protect beneficiaries\nII. The court of appeals erred in finding an individual federal right\n",
    "reference": "C. Finding a privately enforceable individual right in this case would create line-drawing problems"
  },
  {
    "file": "Docket23-1275_Brief001.pdf",
    "text": "I. The any-qualified-provider provision does not create individual rights enforceable under 42 U.S.C.  1983\nA. Spending Clause statutes must unambiguously confer individual rights to be privately enforceable under Section 1983\nB. The any-qualified-provider provision does not unambiguously confer individual federal rights\nC. Finding a privately enforceable individual right in this case would create line-drawing problems\nD. [MISSING]\nII. The court of appeals erred in finding an individual federal right\n",
    "reference": "D. Other enforcement mechanisms protect beneficiaries"
  },
  {
    "file": "Docket23-1275_Brief001.pdf",
    "text": "I. The any-qualified-provider provision does not create individual rights enforceable under 42 U.S.C.  1983\nA. Spending Clause statutes must unambiguously confer individual rights to be privately enforceable under Section 1983\nB. The any-qualified-provider provision does not unambiguously confer individual federal rights\nC. Finding a privately enforceable individual right in this case would create line-drawing problems\nD. Other enforcement mechanisms protect beneficiaries\nII. [MISSING]\n",
    "reference": "II. The court of appeals erred in finding an individual federal right"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. [MISSING]\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "I. The any-qualified-provider provision does not create a private right"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. [MISSING]\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "A. Only clear rights-creating terms create a private right in spending laws"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. [MISSING]\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "B. The any-qualified-provider provision lacks clear rights-creating language"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. [MISSING]\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "C. The Court should retain its bright lines about what qualifies as clear rights-creating language"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. [MISSING]\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. [MISSING]\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. [MISSING]\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. [MISSING]\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "D. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. [MISSING]\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "E. Common sense confirms what text and structure prove"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. [MISSING]\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. [MISSING]\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "2. Finding a private right in the any- qualified-provider provision creates contradictions and problems"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. [MISSING]\nIII.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources\n",
    "reference": "II. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright"
  },
  {
    "file": "Docket23-1275_Brief002.pdf",
    "text": "I. The any-qualified-provider provision does not create a private right\nA. Only clear rights-creating terms create a private right in spending laws\nB. The any-qualified-provider provision lacks clear rights-creating language\nC. The Court should retain its bright lines about what qualifies as clear rights-creating language\n1. Talevski  proves Congress can clearly confer a private right by explicitly labeling a benefit a \u201cright.\u201d\n2. Titles VI and IX prove Congress can clearly confer a private right by using text from the rights-creating provisions of the U.S. Constitution\n3. Absent such explicit rights-creating language, spending statutes do not create private rights, as this Court\u2019s precedents prove\nD. The Medicaid Act\u2019s broader statutory regime reinforces that the any-qualified-provider provision does not create private rights\nE. Common sense confirms what text and structure prove\n1. Respondents\u2019 approach would drop Talevski \u2019s high bar to the floor\n2. Finding a private right in the any- qualified-provider provision creates contradictions and problems\nII. The Court need not overrule any cases, but it should clarify that it has abandoned Blessing \u2019s factors and cabined Wilder  and Wright\n [MISSING]\n",
    "reference": "III.Reversal would respect separation of powers and enable states to better steward scarce Medicaid resources"
  },
  {
    "file": "Docket23-1275_Brief003.pdf",
    "text": "I. [MISSING]\nA.  PPSAT Plays a Crucial Role Counteracting  South Carolina\u2019s Medical Care Deserts\nB.  PPSAT Provides Comprehensive Reproductive  and Primary Care Health Services\nII.  SOUTH CAROLINA\u2019S CPCS ARE NOT A REPLACEMENT FOR CRHCS, LIKE PPSAT\nIII.  ELIMINATING CRHCS, LIKE PPSAT, FROM  MEDICAID HARMS SOUTH CAROLINIAN  BENEFICIARIES\n",
    "reference": "I.  PPSAT IS AN EXEMPLARY PROVIDER OFFERING VITAL SERVICES  TO SOUTH CAROLINIAN MEDICAID BENEFICIARIES"
  },
  {
    "file": "Docket23-1275_Brief003.pdf",
    "text": "I.  PPSAT IS AN EXEMPLARY PROVIDER OFFERING VITAL SERVICES  TO SOUTH CAROLINIAN MEDICAID BENEFICIARIES\nA. [MISSING]\nB.  PPSAT Provides Comprehensive Reproductive  and Primary Care Health Services\nII.  SOUTH CAROLINA\u2019S CPCS ARE NOT A REPLACEMENT FOR CRHCS, LIKE PPSAT\nIII.  ELIMINATING CRHCS, LIKE PPSAT, FROM  MEDICAID HARMS SOUTH CAROLINIAN  BENEFICIARIES\n",
    "reference": "A.  PPSAT Plays a Crucial Role Counteracting  South Carolina\u2019s Medical Care Deserts"
  },
  {
    "file": "Docket23-1275_Brief003.pdf",
    "text": "I.  PPSAT IS AN EXEMPLARY PROVIDER OFFERING VITAL SERVICES  TO SOUTH CAROLINIAN MEDICAID BENEFICIARIES\nA.  PPSAT Plays a Crucial Role Counteracting  South Carolina\u2019s Medical Care Deserts\nB. [MISSING]\nII.  SOUTH CAROLINA\u2019S CPCS ARE NOT A REPLACEMENT FOR CRHCS, LIKE PPSAT\nIII.  ELIMINATING CRHCS, LIKE PPSAT, FROM  MEDICAID HARMS SOUTH CAROLINIAN  BENEFICIARIES\n",
    "reference": "B.  PPSAT Provides Comprehensive Reproductive  and Primary Care Health Services"
  },
  {
    "file": "Docket23-1275_Brief003.pdf",
    "text": "I.  PPSAT IS AN EXEMPLARY PROVIDER OFFERING VITAL SERVICES  TO SOUTH CAROLINIAN MEDICAID BENEFICIARIES\nA.  PPSAT Plays a Crucial Role Counteracting  South Carolina\u2019s Medical Care Deserts\nB.  PPSAT Provides Comprehensive Reproductive  and Primary Care Health Services\nII. [MISSING]\nIII.  ELIMINATING CRHCS, LIKE PPSAT, FROM  MEDICAID HARMS SOUTH CAROLINIAN  BENEFICIARIES\n",
    "reference": "II.  SOUTH CAROLINA\u2019S CPCS ARE NOT A REPLACEMENT FOR CRHCS, LIKE PPSAT"
  },
  {
    "file": "Docket23-1275_Brief003.pdf",
    "text": "I.  PPSAT IS AN EXEMPLARY PROVIDER OFFERING VITAL SERVICES  TO SOUTH CAROLINIAN MEDICAID BENEFICIARIES\nA.  PPSAT Plays a Crucial Role Counteracting  South Carolina\u2019s Medical Care Deserts\nB.  PPSAT Provides Comprehensive Reproductive  and Primary Care Health Services\nII.  SOUTH CAROLINA\u2019S CPCS ARE NOT A REPLACEMENT FOR CRHCS, LIKE PPSAT\nIII. [MISSING]\n",
    "reference": "III.  ELIMINATING CRHCS, LIKE PPSAT, FROM  MEDICAID HARMS SOUTH CAROLINIAN  BENEFICIARIES"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": " [MISSING]\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA. [MISSING]\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "A.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB. [MISSING]\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "B.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. [MISSING]\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "D. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. [MISSING]\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "1. This is an important individual right that Congress specifically intended to protect"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2. [MISSING]\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3. [MISSING]\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. [MISSING]\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. [MISSING]\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "E. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1. [MISSING]\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "1.  Petitioner does not attempt to satisfy Talevski  step 2"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. [MISSING]\nF.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right\n",
    "reference": "2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement"
  },
  {
    "file": "Docket23-1275_Brief004.pdf",
    "text": "The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right Enforceable Under Section 1983\nA.  A Provision Is Enforceable Under Section 1983 When Congress Unambiguously Confers An Individual Right And Does Not Otherwise Preclude Individual Enforcement\nB.  The Text Of The Free-Choice-Of-Provider Provision Unambiguously Confers An Individual Right On Medicaid Beneficiaries.C. Petitioner\u2019s And The Federal Government\u2019s Textual Arguments Lack Merit\nD. The Free-Choice-Of-Provider Provision\u2019s Context And History Confirm That It Is Privately Enforceable\n1. This is an important individual right that Congress specifically intended to protect\n2.  Inclusion as a state plan requirement does not undercut Section 1983 enforceability\n3.  Permitting funding in cases of substantial compliance does not negate an intent to confer an individual right\n4. Private enforcement of the free-choice-of-provider provision has not opened any floodgates\nE. There Is No Alternative, Incompatible Federal Enforcement Scheme Showing An Intent To Preclude Section 1983 Enforcement\n1.  Petitioner does not attempt to satisfy Talevski  step 2\n2. There is no comprehensive alternative scheme that shows an intent to preclude Section 1983 enforcement\nF. [MISSING]\n",
    "reference": "F.  There Is No Question That PPSAT Is A Qualified Provider And That Petitioner Violated Ms. Edwards\u2019 Free-Choice-Of-Provider Right"
  },
  {
    "file": "Docket24-249_Brief002.pdf",
    "text": "A. [MISSING]\n1. To establish a violation of Title II or Section 504, a plaintiff need not prove that the defendant intended to engage in disability discrimination\n2. To obtain compensatory damages for Title II and Section 504 violations, a plaintiff must prove intentional discrimination, which may be shown by proving deliberate indifference\nB. Title II and Section 504 claims are subject to the same intent standards inside and outside the educational context\n1. The texts of Title II and Section 504 indicate that the same intent standards apply inside and outside the educational context\n2. The statutory context supports reading Title II and Section 504 to impose the same intent  standards inside and outside the educational  context\n3. The Eighth Circuit and respondents have identified no sound basis for applying a heightened intent requirement to disability-discrimination claims in the context of elementary and secondary education\n",
    "reference": "A. Proof of discriminatory intent is not required to demonstrate a violation of Title II or Section 504, but such proof is required to recover damages under those provisions"
  },
  {
    "file": "Docket24-249_Brief002.pdf",
    "text": "A. Proof of discriminatory intent is not required to demonstrate a violation of Title II or Section 504, but such proof is required to recover damages under those provisions\n1. [MISSING]\n2. To obtain compensatory damages for Title II and Section 504 violations, a plaintiff must prove intentional discrimination, which may be shown by proving deliberate indifference\nB. Title II and Section 504 claims are subject to the same intent standards inside and outside the educational context\n1. The texts of Title II and Section 504 indicate that the same intent standards apply inside and outside the educational context\n2. The statutory context supports reading Title II and Section 504 to impose the same intent  standards inside and outside the educational  context\n3. The Eighth Circuit and respondents have identified no sound basis for applying a heightened intent requirement to disability-discrimination claims in the context of elementary and secondary education\n",
    "reference": "1. To establish a violation of Title II or Section 504, a plaintiff need not prove that the defendant intended to engage in disability discrimination"
  },
  {
    "file": "Docket24-249_Brief002.pdf",
    "text": "A. Proof of discriminatory intent is not required to demonstrate a violation of Title II or Section 504, but such proof is required to recover damages under those provisions\n1. To establish a violation of Title II or Section 504, a plaintiff need not prove that the defendant intended to engage in disability discrimination\n2. [MISSING]\nB. Title II and Section 504 claims are subject to the same intent standards inside and outside the educational context\n1. The texts of Title II and Section 504 indicate that the same intent standards apply inside and outside the educational context\n2. The statutory context supports reading Title II and Section 504 to impose the same intent  standards inside and outside the educational  context\n3. The Eighth Circuit and respondents have identified no sound basis for applying a heightened intent requirement to disability-discrimination claims in the context of elementary and secondary education\n",
    "reference": "2. To obtain compensatory damages for Title II and Section 504 violations, a plaintiff must prove intentional discrimination, which may be shown by proving deliberate indifference"
  },
  {
    "file": "Docket24-249_Brief002.pdf",
    "text": "A. Proof of discriminatory intent is not required to demonstrate a violation of Title II or Section 504, but such proof is required to recover damages under those provisions\n1. To establish a violation of Title II or Section 504, a plaintiff need not prove that the defendant intended to engage in disability discrimination\n2. To obtain compensatory damages for Title II and Section 504 violations, a plaintiff must prove intentional discrimination, which may be shown by proving deliberate indifference\nB. [MISSING]\n1. The texts of Title II and Section 504 indicate that the same intent standards apply inside and outside the educational context\n2. The statutory context supports reading Title II and Section 504 to impose the same intent  standards inside and outside the educational  context\n3. The Eighth Circuit and respondents have identified no sound basis for applying a heightened intent requirement to disability-discrimination claims in the context of elementary and secondary education\n",
    "reference": "B. Title II and Section 504 claims are subject to the same intent standards inside and outside the educational context"
  },
  {
    "file": "Docket24-249_Brief002.pdf",
    "text": "A. Proof of discriminatory intent is not required to demonstrate a violation of Title II or Section 504, but such proof is required to recover damages under those provisions\n1. To establish a violation of Title II or Section 504, a plaintiff need not prove that the defendant intended to engage in disability discrimination\n2. To obtain compensatory damages for Title II and Section 504 violations, a plaintiff must prove intentional discrimination, which may be shown by proving deliberate indifference\nB. Title II and Section 504 claims are subject to the same intent standards inside and outside the educational context\n1. [MISSING]\n2. The statutory context supports reading Title II and Section 504 to impose the same intent  standards inside and outside the educational  context\n3. The Eighth Circuit and respondents have identified no sound basis for applying a heightened intent requirement to disability-discrimination claims in the context of elementary and secondary education\n",
    "reference": "1. The texts of Title II and Section 504 indicate that the same intent standards apply inside and outside the educational context"
  },
  {
    "file": "Docket24-249_Brief002.pdf",
    "text": "A. Proof of discriminatory intent is not required to demonstrate a violation of Title II or Section 504, but such proof is required to recover damages under those provisions\n1. To establish a violation of Title II or Section 504, a plaintiff need not prove that the defendant intended to engage in disability discrimination\n2. To obtain compensatory damages for Title II and Section 504 violations, a plaintiff must prove intentional discrimination, which may be shown by proving deliberate indifference\nB. Title II and Section 504 claims are subject to the same intent standards inside and outside the educational context\n1. The texts of Title II and Section 504 indicate that the same intent standards apply inside and outside the educational context\n2. [MISSING]\n3. The Eighth Circuit and respondents have identified no sound basis for applying a heightened intent requirement to disability-discrimination claims in the context of elementary and secondary education\n",
    "reference": "2. The statutory context supports reading Title II and Section 504 to impose the same intent  standards inside and outside the educational  context"
  },
  {
    "file": "Docket24-249_Brief002.pdf",
    "text": "A. Proof of discriminatory intent is not required to demonstrate a violation of Title II or Section 504, but such proof is required to recover damages under those provisions\n1. To establish a violation of Title II or Section 504, a plaintiff need not prove that the defendant intended to engage in disability discrimination\n2. To obtain compensatory damages for Title II and Section 504 violations, a plaintiff must prove intentional discrimination, which may be shown by proving deliberate indifference\nB. Title II and Section 504 claims are subject to the same intent standards inside and outside the educational context\n1. The texts of Title II and Section 504 indicate that the same intent standards apply inside and outside the educational context\n2. The statutory context supports reading Title II and Section 504 to impose the same intent  standards inside and outside the educational  context\n3. [MISSING]\n",
    "reference": "3. The Eighth Circuit and respondents have identified no sound basis for applying a heightened intent requirement to disability-discrimination claims in the context of elementary and secondary education"
  },
  {
    "file": "Docket24-275_Brief001.pdf",
    "text": "I. [MISSING]\nA.  Premature notices of appeal generally take effect when an appeal period opens\nB.  Section 2107(c) incorporates that ripening principle\nC.  Ripening upon reopening is a simple jurisdictional rule that preserves \u00a7 2107(c) \u2019s purpose\nII. THE FOURTH CIRCUIT \u2019S SECOND-NOTICE REQUIREMENT LACKS ANY SOUND JUSTIFICATION\nA.  \u201cReopen \u201d is consistent with ripening\nB.  A filing can be both a notice of appeal and a motion to reopen\n",
    "reference": "I. NOTICES OF APPEAL FILED AFTER THE ORDINARY APPEAL PERIOD EXPIRES RIPEN WHEN THE APPEAL PERIOD IS REOPENED"
  },
  {
    "file": "Docket24-275_Brief001.pdf",
    "text": "I. NOTICES OF APPEAL FILED AFTER THE ORDINARY APPEAL PERIOD EXPIRES RIPEN WHEN THE APPEAL PERIOD IS REOPENED\nA. [MISSING]\nB.  Section 2107(c) incorporates that ripening principle\nC.  Ripening upon reopening is a simple jurisdictional rule that preserves \u00a7 2107(c) \u2019s purpose\nII. THE FOURTH CIRCUIT \u2019S SECOND-NOTICE REQUIREMENT LACKS ANY SOUND JUSTIFICATION\nA.  \u201cReopen \u201d is consistent with ripening\nB.  A filing can be both a notice of appeal and a motion to reopen\n",
    "reference": "A.  Premature notices of appeal generally take effect when an appeal period opens"
  },
  {
    "file": "Docket24-275_Brief001.pdf",
    "text": "I. NOTICES OF APPEAL FILED AFTER THE ORDINARY APPEAL PERIOD EXPIRES RIPEN WHEN THE APPEAL PERIOD IS REOPENED\nA.  Premature notices of appeal generally take effect when an appeal period opens\nB. [MISSING]\nC.  Ripening upon reopening is a simple jurisdictional rule that preserves \u00a7 2107(c) \u2019s purpose\nII. THE FOURTH CIRCUIT \u2019S SECOND-NOTICE REQUIREMENT LACKS ANY SOUND JUSTIFICATION\nA.  \u201cReopen \u201d is consistent with ripening\nB.  A filing can be both a notice of appeal and a motion to reopen\n",
    "reference": "B.  Section 2107(c) incorporates that ripening principle"
  },
  {
    "file": "Docket24-275_Brief001.pdf",
    "text": "I. NOTICES OF APPEAL FILED AFTER THE ORDINARY APPEAL PERIOD EXPIRES RIPEN WHEN THE APPEAL PERIOD IS REOPENED\nA.  Premature notices of appeal generally take effect when an appeal period opens\nB.  Section 2107(c) incorporates that ripening principle\nC. [MISSING]\nII. THE FOURTH CIRCUIT \u2019S SECOND-NOTICE REQUIREMENT LACKS ANY SOUND JUSTIFICATION\nA.  \u201cReopen \u201d is consistent with ripening\nB.  A filing can be both a notice of appeal and a motion to reopen\n",
    "reference": "C.  Ripening upon reopening is a simple jurisdictional rule that preserves \u00a7 2107(c) \u2019s purpose"
  },
  {
    "file": "Docket24-275_Brief001.pdf",
    "text": "I. NOTICES OF APPEAL FILED AFTER THE ORDINARY APPEAL PERIOD EXPIRES RIPEN WHEN THE APPEAL PERIOD IS REOPENED\nA.  Premature notices of appeal generally take effect when an appeal period opens\nB.  Section 2107(c) incorporates that ripening principle\nC.  Ripening upon reopening is a simple jurisdictional rule that preserves \u00a7 2107(c) \u2019s purpose\nII. [MISSING]\nA.  \u201cReopen \u201d is consistent with ripening\nB.  A filing can be both a notice of appeal and a motion to reopen\n",
    "reference": "II. THE FOURTH CIRCUIT \u2019S SECOND-NOTICE REQUIREMENT LACKS ANY SOUND JUSTIFICATION"
  },
  {
    "file": "Docket24-275_Brief001.pdf",
    "text": "I. NOTICES OF APPEAL FILED AFTER THE ORDINARY APPEAL PERIOD EXPIRES RIPEN WHEN THE APPEAL PERIOD IS REOPENED\nA.  Premature notices of appeal generally take effect when an appeal period opens\nB.  Section 2107(c) incorporates that ripening principle\nC.  Ripening upon reopening is a simple jurisdictional rule that preserves \u00a7 2107(c) \u2019s purpose\nII. THE FOURTH CIRCUIT \u2019S SECOND-NOTICE REQUIREMENT LACKS ANY SOUND JUSTIFICATION\nA. [MISSING]\nB.  A filing can be both a notice of appeal and a motion to reopen\n",
    "reference": "A.  \u201cReopen \u201d is consistent with ripening"
  },
  {
    "file": "Docket24-275_Brief001.pdf",
    "text": "I. NOTICES OF APPEAL FILED AFTER THE ORDINARY APPEAL PERIOD EXPIRES RIPEN WHEN THE APPEAL PERIOD IS REOPENED\nA.  Premature notices of appeal generally take effect when an appeal period opens\nB.  Section 2107(c) incorporates that ripening principle\nC.  Ripening upon reopening is a simple jurisdictional rule that preserves \u00a7 2107(c) \u2019s purpose\nII. THE FOURTH CIRCUIT \u2019S SECOND-NOTICE REQUIREMENT LACKS ANY SOUND JUSTIFICATION\nA.  \u201cReopen \u201d is consistent with ripening\nB. [MISSING]\n",
    "reference": "B.  A filing can be both a notice of appeal and a motion to reopen"
  },
  {
    "file": "Docket24-304_Brief001.pdf",
    "text": "I. [MISSING]\nA. Rule 23(b)(3) requires rigorous analysis before certifying a damages class\nB. A court\u2019s Rule 23(b)(3) analysis must recognize the defendant\u2019s right to identify and exclude uninjured absent class members\nC. The Rule 23(b)(3) determination must take account of the defendant\u2019s right to resolution by the district court of challenges to absent class members\u2019 injury claims\nD. Proper application of the predominance and superiority requirements will make it difficult to certify classes that include uninjured individuals\nE. Courts of appeals have recognized that Rule 23(b)(3) precludes certification of proposed damages classes containing uninjured members who cannot easily be identified and excluded\nII. The Damages Class In This Case Should Never Have Been Certified Because It Contains Uninjured Members And There Is No Easy Way For A Court To Identify And Exclude Them\nIII. An Impermissibly Lax Approach To The Issue Of Uninjured Class Members At Class Certification Harms Businesses And The Judicial System\n",
    "reference": "I. Rule 23(b)(3) Prohibits Certification If A Putative Damages Class Contains Uninjured Members Who Cannot Easily Be Identified And Excluded From The Class"
  },
  {
    "file": "Docket24-304_Brief001.pdf",
    "text": "I. Rule 23(b)(3) Prohibits Certification If A Putative Damages Class Contains Uninjured Members Who Cannot Easily Be Identified And Excluded From The Class\nA. [MISSING]\nB. A court\u2019s Rule 23(b)(3) analysis must recognize the defendant\u2019s right to identify and exclude uninjured absent class members\nC. The Rule 23(b)(3) determination must take account of the defendant\u2019s right to resolution by the district court of challenges to absent class members\u2019 injury claims\nD. Proper application of the predominance and superiority requirements will make it difficult to certify classes that include uninjured individuals\nE. Courts of appeals have recognized that Rule 23(b)(3) precludes certification of proposed damages classes containing uninjured members who cannot easily be identified and excluded\nII. The Damages Class In This Case Should Never Have Been Certified Because It Contains Uninjured Members And There Is No Easy Way For A Court To Identify And Exclude Them\nIII. An Impermissibly Lax Approach To The Issue Of Uninjured Class Members At Class Certification Harms Businesses And The Judicial System\n",
    "reference": "A. Rule 23(b)(3) requires rigorous analysis before certifying a damages class"
  },
  {
    "file": "Docket24-304_Brief001.pdf",
    "text": "I. Rule 23(b)(3) Prohibits Certification If A Putative Damages Class Contains Uninjured Members Who Cannot Easily Be Identified And Excluded From The Class\nA. Rule 23(b)(3) requires rigorous analysis before certifying a damages class\nB. [MISSING]\nC. The Rule 23(b)(3) determination must take account of the defendant\u2019s right to resolution by the district court of challenges to absent class members\u2019 injury claims\nD. Proper application of the predominance and superiority requirements will make it difficult to certify classes that include uninjured individuals\nE. Courts of appeals have recognized that Rule 23(b)(3) precludes certification of proposed damages classes containing uninjured members who cannot easily be identified and excluded\nII. The Damages Class In This Case Should Never Have Been Certified Because It Contains Uninjured Members And There Is No Easy Way For A Court To Identify And Exclude Them\nIII. An Impermissibly Lax Approach To The Issue Of Uninjured Class Members At Class Certification Harms Businesses And The Judicial System\n",
    "reference": "B. A court\u2019s Rule 23(b)(3) analysis must recognize the defendant\u2019s right to identify and exclude uninjured absent class members"
  },
  {
    "file": "Docket24-304_Brief001.pdf",
    "text": "I. Rule 23(b)(3) Prohibits Certification If A Putative Damages Class Contains Uninjured Members Who Cannot Easily Be Identified And Excluded From The Class\nA. Rule 23(b)(3) requires rigorous analysis before certifying a damages class\nB. A court\u2019s Rule 23(b)(3) analysis must recognize the defendant\u2019s right to identify and exclude uninjured absent class members\nC. [MISSING]\nD. Proper application of the predominance and superiority requirements will make it difficult to certify classes that include uninjured individuals\nE. Courts of appeals have recognized that Rule 23(b)(3) precludes certification of proposed damages classes containing uninjured members who cannot easily be identified and excluded\nII. The Damages Class In This Case Should Never Have Been Certified Because It Contains Uninjured Members And There Is No Easy Way For A Court To Identify And Exclude Them\nIII. An Impermissibly Lax Approach To The Issue Of Uninjured Class Members At Class Certification Harms Businesses And The Judicial System\n",
    "reference": "C. The Rule 23(b)(3) determination must take account of the defendant\u2019s right to resolution by the district court of challenges to absent class members\u2019 injury claims"
  },
  {
    "file": "Docket24-304_Brief001.pdf",
    "text": "I. Rule 23(b)(3) Prohibits Certification If A Putative Damages Class Contains Uninjured Members Who Cannot Easily Be Identified And Excluded From The Class\nA. Rule 23(b)(3) requires rigorous analysis before certifying a damages class\nB. A court\u2019s Rule 23(b)(3) analysis must recognize the defendant\u2019s right to identify and exclude uninjured absent class members\nC. The Rule 23(b)(3) determination must take account of the defendant\u2019s right to resolution by the district court of challenges to absent class members\u2019 injury claims\nD. [MISSING]\nE. Courts of appeals have recognized that Rule 23(b)(3) precludes certification of proposed damages classes containing uninjured members who cannot easily be identified and excluded\nII. The Damages Class In This Case Should Never Have Been Certified Because It Contains Uninjured Members And There Is No Easy Way For A Court To Identify And Exclude Them\nIII. An Impermissibly Lax Approach To The Issue Of Uninjured Class Members At Class Certification Harms Businesses And The Judicial System\n",
    "reference": "D. Proper application of the predominance and superiority requirements will make it difficult to certify classes that include uninjured individuals"
  },
  {
    "file": "Docket24-304_Brief001.pdf",
    "text": "I. Rule 23(b)(3) Prohibits Certification If A Putative Damages Class Contains Uninjured Members Who Cannot Easily Be Identified And Excluded From The Class\nA. Rule 23(b)(3) requires rigorous analysis before certifying a damages class\nB. A court\u2019s Rule 23(b)(3) analysis must recognize the defendant\u2019s right to identify and exclude uninjured absent class members\nC. The Rule 23(b)(3) determination must take account of the defendant\u2019s right to resolution by the district court of challenges to absent class members\u2019 injury claims\nD. Proper application of the predominance and superiority requirements will make it difficult to certify classes that include uninjured individuals\nE. [MISSING]\nII. The Damages Class In This Case Should Never Have Been Certified Because It Contains Uninjured Members And There Is No Easy Way For A Court To Identify And Exclude Them\nIII. An Impermissibly Lax Approach To The Issue Of Uninjured Class Members At Class Certification Harms Businesses And The Judicial System\n",
    "reference": "E. Courts of appeals have recognized that Rule 23(b)(3) precludes certification of proposed damages classes containing uninjured members who cannot easily be identified and excluded"
  },
  {
    "file": "Docket24-304_Brief001.pdf",
    "text": "I. Rule 23(b)(3) Prohibits Certification If A Putative Damages Class Contains Uninjured Members Who Cannot Easily Be Identified And Excluded From The Class\nA. Rule 23(b)(3) requires rigorous analysis before certifying a damages class\nB. A court\u2019s Rule 23(b)(3) analysis must recognize the defendant\u2019s right to identify and exclude uninjured absent class members\nC. The Rule 23(b)(3) determination must take account of the defendant\u2019s right to resolution by the district court of challenges to absent class members\u2019 injury claims\nD. Proper application of the predominance and superiority requirements will make it difficult to certify classes that include uninjured individuals\nE. Courts of appeals have recognized that Rule 23(b)(3) precludes certification of proposed damages classes containing uninjured members who cannot easily be identified and excluded\nII. [MISSING]\nIII. An Impermissibly Lax Approach To The Issue Of Uninjured Class Members At Class Certification Harms Businesses And The Judicial System\n",
    "reference": "II. The Damages Class In This Case Should Never Have Been Certified Because It Contains Uninjured Members And There Is No Easy Way For A Court To Identify And Exclude Them"
  },
  {
    "file": "Docket24-304_Brief001.pdf",
    "text": "I. Rule 23(b)(3) Prohibits Certification If A Putative Damages Class Contains Uninjured Members Who Cannot Easily Be Identified And Excluded From The Class\nA. Rule 23(b)(3) requires rigorous analysis before certifying a damages class\nB. A court\u2019s Rule 23(b)(3) analysis must recognize the defendant\u2019s right to identify and exclude uninjured absent class members\nC. The Rule 23(b)(3) determination must take account of the defendant\u2019s right to resolution by the district court of challenges to absent class members\u2019 injury claims\nD. Proper application of the predominance and superiority requirements will make it difficult to certify classes that include uninjured individuals\nE. Courts of appeals have recognized that Rule 23(b)(3) precludes certification of proposed damages classes containing uninjured members who cannot easily be identified and excluded\nII. The Damages Class In This Case Should Never Have Been Certified Because It Contains Uninjured Members And There Is No Easy Way For A Court To Identify And Exclude Them\nIII. [MISSING]\n",
    "reference": "III. An Impermissibly Lax Approach To The Issue Of Uninjured Class Members At Class Certification Harms Businesses And The Judicial System"
  },
  {
    "file": "Docket24-304_Brief002.pdf",
    "text": "I. [MISSING]\nA. Article III requires that each class member have standing at the class-certificat ion stage\nB. Absent class members cannot circumvent Article III at the class- certification stage by relying on the standing of named plaintiffs\nC. Class certification rules do not permit federal courts to evade Article III\u2019s strictures\nD. Article III requires named plaintiffs to present evidence showing each absent class member has been  injured\nII. Alternatively, federal courts cannot certify a class that includes more than a de minimis number of uninjured members\nA. Due to constitutional and statutory constraints, Rule 23(b)(3) forbids class certification where the number of uninjured class members is more than de minimis\nB. Named plaintiffs must comply with stringent criteria before they can demonstrate class certification is warranted under this de minimis  standard\n",
    "reference": "I. Article III prohibits the certification of class actions that include any uninjured class members"
  },
  {
    "file": "Docket24-304_Brief002.pdf",
    "text": "I. Article III prohibits the certification of class actions that include any uninjured class members\nA. [MISSING]\nB. Absent class members cannot circumvent Article III at the class- certification stage by relying on the standing of named plaintiffs\nC. Class certification rules do not permit federal courts to evade Article III\u2019s strictures\nD. Article III requires named plaintiffs to present evidence showing each absent class member has been  injured\nII. Alternatively, federal courts cannot certify a class that includes more than a de minimis number of uninjured members\nA. Due to constitutional and statutory constraints, Rule 23(b)(3) forbids class certification where the number of uninjured class members is more than de minimis\nB. Named plaintiffs must comply with stringent criteria before they can demonstrate class certification is warranted under this de minimis  standard\n",
    "reference": "A. Article III requires that each class member have standing at the class-certificat ion stage"
  },
  {
    "file": "Docket24-304_Brief002.pdf",
    "text": "I. Article III prohibits the certification of class actions that include any uninjured class members\nA. Article III requires that each class member have standing at the class-certificat ion stage\nB. [MISSING]\nC. Class certification rules do not permit federal courts to evade Article III\u2019s strictures\nD. Article III requires named plaintiffs to present evidence showing each absent class member has been  injured\nII. Alternatively, federal courts cannot certify a class that includes more than a de minimis number of uninjured members\nA. Due to constitutional and statutory constraints, Rule 23(b)(3) forbids class certification where the number of uninjured class members is more than de minimis\nB. Named plaintiffs must comply with stringent criteria before they can demonstrate class certification is warranted under this de minimis  standard\n",
    "reference": "B. Absent class members cannot circumvent Article III at the class- certification stage by relying on the standing of named plaintiffs"
  },
  {
    "file": "Docket24-304_Brief002.pdf",
    "text": "I. Article III prohibits the certification of class actions that include any uninjured class members\nA. Article III requires that each class member have standing at the class-certificat ion stage\nB. Absent class members cannot circumvent Article III at the class- certification stage by relying on the standing of named plaintiffs\nC. [MISSING]\nD. Article III requires named plaintiffs to present evidence showing each absent class member has been  injured\nII. Alternatively, federal courts cannot certify a class that includes more than a de minimis number of uninjured members\nA. Due to constitutional and statutory constraints, Rule 23(b)(3) forbids class certification where the number of uninjured class members is more than de minimis\nB. Named plaintiffs must comply with stringent criteria before they can demonstrate class certification is warranted under this de minimis  standard\n",
    "reference": "C. Class certification rules do not permit federal courts to evade Article III\u2019s strictures"
  },
  {
    "file": "Docket24-304_Brief002.pdf",
    "text": "I. Article III prohibits the certification of class actions that include any uninjured class members\nA. Article III requires that each class member have standing at the class-certificat ion stage\nB. Absent class members cannot circumvent Article III at the class- certification stage by relying on the standing of named plaintiffs\nC. Class certification rules do not permit federal courts to evade Article III\u2019s strictures\nD. [MISSING]\nII. Alternatively, federal courts cannot certify a class that includes more than a de minimis number of uninjured members\nA. Due to constitutional and statutory constraints, Rule 23(b)(3) forbids class certification where the number of uninjured class members is more than de minimis\nB. Named plaintiffs must comply with stringent criteria before they can demonstrate class certification is warranted under this de minimis  standard\n",
    "reference": "D. Article III requires named plaintiffs to present evidence showing each absent class member has been  injured"
  },
  {
    "file": "Docket24-304_Brief002.pdf",
    "text": "I. Article III prohibits the certification of class actions that include any uninjured class members\nA. Article III requires that each class member have standing at the class-certificat ion stage\nB. Absent class members cannot circumvent Article III at the class- certification stage by relying on the standing of named plaintiffs\nC. Class certification rules do not permit federal courts to evade Article III\u2019s strictures\nD. Article III requires named plaintiffs to present evidence showing each absent class member has been  injured\nII. [MISSING]\nA. Due to constitutional and statutory constraints, Rule 23(b)(3) forbids class certification where the number of uninjured class members is more than de minimis\nB. Named plaintiffs must comply with stringent criteria before they can demonstrate class certification is warranted under this de minimis  standard\n",
    "reference": "II. Alternatively, federal courts cannot certify a class that includes more than a de minimis number of uninjured members"
  },
  {
    "file": "Docket24-304_Brief002.pdf",
    "text": "I. Article III prohibits the certification of class actions that include any uninjured class members\nA. Article III requires that each class member have standing at the class-certificat ion stage\nB. Absent class members cannot circumvent Article III at the class- certification stage by relying on the standing of named plaintiffs\nC. Class certification rules do not permit federal courts to evade Article III\u2019s strictures\nD. Article III requires named plaintiffs to present evidence showing each absent class member has been  injured\nII. Alternatively, federal courts cannot certify a class that includes more than a de minimis number of uninjured members\nA. [MISSING]\nB. Named plaintiffs must comply with stringent criteria before they can demonstrate class certification is warranted under this de minimis  standard\n",
    "reference": "A. Due to constitutional and statutory constraints, Rule 23(b)(3) forbids class certification where the number of uninjured class members is more than de minimis"
  },
  {
    "file": "Docket24-304_Brief002.pdf",
    "text": "I. Article III prohibits the certification of class actions that include any uninjured class members\nA. Article III requires that each class member have standing at the class-certificat ion stage\nB. Absent class members cannot circumvent Article III at the class- certification stage by relying on the standing of named plaintiffs\nC. Class certification rules do not permit federal courts to evade Article III\u2019s strictures\nD. Article III requires named plaintiffs to present evidence showing each absent class member has been  injured\nII. Alternatively, federal courts cannot certify a class that includes more than a de minimis number of uninjured members\nA. Due to constitutional and statutory constraints, Rule 23(b)(3) forbids class certification where the number of uninjured class members is more than de minimis\nB. [MISSING]\n",
    "reference": "B. Named plaintiffs must comply with stringent criteria before they can demonstrate class certification is warranted under this de minimis  standard"
  },
  {
    "file": "Docket24-304_Brief003.pdf",
    "text": "I. [MISSING]\nA. Damages classes must be defined to exclude class members known to lack Article III standing\nB. Damages classes must be defined such that class members who may lack Article III standing can be winnowed out without predominant individual inquiries\nC. This damages class is rife with uninjured members\nII. Declining to enforce standing requirements at the class certification phase would raise significant concerns under the Article III \u201cjudicial Power .\u201d\nA. Rule 23(b)(3) damages class actions differ in significant ways from traditional joinder litigation\nB. No traditional exception to joinder justifies Rule 23(b)(3) damages class actions\nIII. Extending class certification to the uninjured harms American businesses and the economy as a whole\n",
    "reference": "I. Damages classes containing members without Article III standing stretch Article III past the breaking point"
  },
  {
    "file": "Docket24-304_Brief003.pdf",
    "text": "I. Damages classes containing members without Article III standing stretch Article III past the breaking point\nA. [MISSING]\nB. Damages classes must be defined such that class members who may lack Article III standing can be winnowed out without predominant individual inquiries\nC. This damages class is rife with uninjured members\nII. Declining to enforce standing requirements at the class certification phase would raise significant concerns under the Article III \u201cjudicial Power .\u201d\nA. Rule 23(b)(3) damages class actions differ in significant ways from traditional joinder litigation\nB. No traditional exception to joinder justifies Rule 23(b)(3) damages class actions\nIII. Extending class certification to the uninjured harms American businesses and the economy as a whole\n",
    "reference": "A. Damages classes must be defined to exclude class members known to lack Article III standing"
  },
  {
    "file": "Docket24-304_Brief003.pdf",
    "text": "I. Damages classes containing members without Article III standing stretch Article III past the breaking point\nA. Damages classes must be defined to exclude class members known to lack Article III standing\nB. [MISSING]\nC. This damages class is rife with uninjured members\nII. Declining to enforce standing requirements at the class certification phase would raise significant concerns under the Article III \u201cjudicial Power .\u201d\nA. Rule 23(b)(3) damages class actions differ in significant ways from traditional joinder litigation\nB. No traditional exception to joinder justifies Rule 23(b)(3) damages class actions\nIII. Extending class certification to the uninjured harms American businesses and the economy as a whole\n",
    "reference": "B. Damages classes must be defined such that class members who may lack Article III standing can be winnowed out without predominant individual inquiries"
  },
  {
    "file": "Docket24-304_Brief003.pdf",
    "text": "I. Damages classes containing members without Article III standing stretch Article III past the breaking point\nA. Damages classes must be defined to exclude class members known to lack Article III standing\nB. Damages classes must be defined such that class members who may lack Article III standing can be winnowed out without predominant individual inquiries\nC. [MISSING]\nII. Declining to enforce standing requirements at the class certification phase would raise significant concerns under the Article III \u201cjudicial Power .\u201d\nA. Rule 23(b)(3) damages class actions differ in significant ways from traditional joinder litigation\nB. No traditional exception to joinder justifies Rule 23(b)(3) damages class actions\nIII. Extending class certification to the uninjured harms American businesses and the economy as a whole\n",
    "reference": "C. This damages class is rife with uninjured members"
  },
  {
    "file": "Docket24-304_Brief003.pdf",
    "text": "I. Damages classes containing members without Article III standing stretch Article III past the breaking point\nA. Damages classes must be defined to exclude class members known to lack Article III standing\nB. Damages classes must be defined such that class members who may lack Article III standing can be winnowed out without predominant individual inquiries\nC. This damages class is rife with uninjured members\nII. [MISSING]\nA. Rule 23(b)(3) damages class actions differ in significant ways from traditional joinder litigation\nB. No traditional exception to joinder justifies Rule 23(b)(3) damages class actions\nIII. Extending class certification to the uninjured harms American businesses and the economy as a whole\n",
    "reference": "II. Declining to enforce standing requirements at the class certification phase would raise significant concerns under the Article III \u201cjudicial Power .\u201d"
  },
  {
    "file": "Docket24-304_Brief003.pdf",
    "text": "I. Damages classes containing members without Article III standing stretch Article III past the breaking point\nA. Damages classes must be defined to exclude class members known to lack Article III standing\nB. Damages classes must be defined such that class members who may lack Article III standing can be winnowed out without predominant individual inquiries\nC. This damages class is rife with uninjured members\nII. Declining to enforce standing requirements at the class certification phase would raise significant concerns under the Article III \u201cjudicial Power .\u201d\nA. [MISSING]\nB. No traditional exception to joinder justifies Rule 23(b)(3) damages class actions\nIII. Extending class certification to the uninjured harms American businesses and the economy as a whole\n",
    "reference": "A. Rule 23(b)(3) damages class actions differ in significant ways from traditional joinder litigation"
  },
  {
    "file": "Docket24-304_Brief003.pdf",
    "text": "I. Damages classes containing members without Article III standing stretch Article III past the breaking point\nA. Damages classes must be defined to exclude class members known to lack Article III standing\nB. Damages classes must be defined such that class members who may lack Article III standing can be winnowed out without predominant individual inquiries\nC. This damages class is rife with uninjured members\nII. Declining to enforce standing requirements at the class certification phase would raise significant concerns under the Article III \u201cjudicial Power .\u201d\nA. Rule 23(b)(3) damages class actions differ in significant ways from traditional joinder litigation\nB. [MISSING]\nIII. Extending class certification to the uninjured harms American businesses and the economy as a whole\n",
    "reference": "B. No traditional exception to joinder justifies Rule 23(b)(3) damages class actions"
  },
  {
    "file": "Docket24-304_Brief003.pdf",
    "text": "I. Damages classes containing members without Article III standing stretch Article III past the breaking point\nA. Damages classes must be defined to exclude class members known to lack Article III standing\nB. Damages classes must be defined such that class members who may lack Article III standing can be winnowed out without predominant individual inquiries\nC. This damages class is rife with uninjured members\nII. Declining to enforce standing requirements at the class certification phase would raise significant concerns under the Article III \u201cjudicial Power .\u201d\nA. Rule 23(b)(3) damages class actions differ in significant ways from traditional joinder litigation\nB. No traditional exception to joinder justifies Rule 23(b)(3) damages class actions\nIII. [MISSING]\n",
    "reference": "III. Extending class certification to the uninjured harms American businesses and the economy as a whole"
  },
  {
    "file": "Docket24-316_Brief001.pdf",
    "text": "I. [MISSING]\nII. If Subsection (a)(6) Renders Task Force Members Principal Officers, It Should Be Severed\nIII. Enjoining Enforcement Of The Task Force\u2019s Recommendations Would Negatively Impact Public Health Outcomes\n",
    "reference": "I. The Structure Of The Task Force Does Not Violate The Appointments Clause Because Task Force Members Serve As Inferior Officers Subordinate To The Secretary"
  },
  {
    "file": "Docket24-316_Brief001.pdf",
    "text": "I. The Structure Of The Task Force Does Not Violate The Appointments Clause Because Task Force Members Serve As Inferior Officers Subordinate To The Secretary\nII. [MISSING]\nIII. Enjoining Enforcement Of The Task Force\u2019s Recommendations Would Negatively Impact Public Health Outcomes\n",
    "reference": "II. If Subsection (a)(6) Renders Task Force Members Principal Officers, It Should Be Severed"
  },
  {
    "file": "Docket24-316_Brief001.pdf",
    "text": "I. The Structure Of The Task Force Does Not Violate The Appointments Clause Because Task Force Members Serve As Inferior Officers Subordinate To The Secretary\nII. If Subsection (a)(6) Renders Task Force Members Principal Officers, It Should Be Severed\nIII. [MISSING]\n",
    "reference": "III. Enjoining Enforcement Of The Task Force\u2019s Recommendations Would Negatively Impact Public Health Outcomes"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I. [MISSING]\nA.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP\n1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures\n2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History\nB.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures\nC .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support\nII.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV\nA.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health\nB.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence\n",
    "reference": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE\nA. [MISSING]\n1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures\n2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History\nB.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures\nC .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support\nII.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV\nA.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health\nB.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence\n",
    "reference": "A.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE\nA.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP\n1. [MISSING]\n2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History\nB.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures\nC .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support\nII.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV\nA.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health\nB.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence\n",
    "reference": "1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE\nA.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP\n1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures\n [MISSING]\nB.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures\nC .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support\nII.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV\nA.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health\nB.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence\n",
    "reference": "2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE\nA.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP\n1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures\n2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History\nB. [MISSING]\nC .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support\nII.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV\nA.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health\nB.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence\n",
    "reference": "B.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE\nA.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP\n1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures\n2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History\nB.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures\n [MISSING]\nII.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV\nA.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health\nB.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence\n",
    "reference": "C .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE\nA.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP\n1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures\n2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History\nB.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures\nC .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support\nII. [MISSING]\nA.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health\nB.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence\n",
    "reference": "II.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE\nA.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP\n1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures\n2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History\nB.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures\nC .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support\nII.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV\nA. [MISSING]\nB.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence\n",
    "reference": "A.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health"
  },
  {
    "file": "Docket24-316_Brief002.pdf",
    "text": "I.  ELIMINATION OF FATAL EPIDEMICS IN THE UNITED STATES, INCLUDING HIV/AIDS, HINGES ON ACCESS TO  PREVENTIVE CARE\nA.  Success in HIV/AIDS Eradication Is Contingent Upon Widespread,  Continuous Access to PrEP\n1.  Decades of History Exhibit the Devastating and Indiscriminate Impact of HIV/AIDS Absent  Preventive Care Measures\n2 .   Decreased Risk of HIV Transmission Through Preventive Care Measures Is One of the Most Salient Public-Health  Victories in U.S. History\nB.  Public Health Progress Will Be Undermined Without Widespread Access to PrEP and Other Preventive  Care Measures\nC .   Reliance on Preventive Care Measures to Combat the HIV/ AIDS Epidemic Is Deeply Rooted in  Historic, Bipartisan Support\nII.  PROMOTING  PUBLIC  HEALTH REQUIRES NO-COST ACCESS TO EVIDENCE-BASED PREVENTIVE CARE MEASURES, INCLUDING  WITH REGARD TO HIV\nA.  No-Cost Access to Preventive Health Measures like PrEP Dramatically Improves Individual Outcomes and  National Public Health\nB. [MISSING]\n",
    "reference": "B.  The USPSTF\u2019s Designation of Evidence-Based Preventive Care Measures like PrEP for No-Cost Coverage Successfully Decreases  Disease Prevalence and Incidence"
  },
  {
    "file": "Docket24-316_Brief003.pdf",
    "text": "I. [MISSING]\nII. Our Fragmented Health Insurance System Necessitates that All Insurers, Public and Private, Cover Preventive Services Without Cost-Sharing\nIII. The Preventive Services Provision Enhances Workforce Productivity and Supports a Strong Economy\n",
    "reference": "I. The Preventive Services Provision Rests on Sound Economic Principles Specific to Preventive Care"
  },
  {
    "file": "Docket24-316_Brief003.pdf",
    "text": "I. The Preventive Services Provision Rests on Sound Economic Principles Specific to Preventive Care\nII. [MISSING]\nIII. The Preventive Services Provision Enhances Workforce Productivity and Supports a Strong Economy\n",
    "reference": "II. Our Fragmented Health Insurance System Necessitates that All Insurers, Public and Private, Cover Preventive Services Without Cost-Sharing"
  },
  {
    "file": "Docket24-316_Brief003.pdf",
    "text": "I. The Preventive Services Provision Rests on Sound Economic Principles Specific to Preventive Care\nII. Our Fragmented Health Insurance System Necessitates that All Insurers, Public and Private, Cover Preventive Services Without Cost-Sharing\nIII. [MISSING]\n",
    "reference": "III. The Preventive Services Provision Enhances Workforce Productivity and Supports a Strong Economy"
  },
  {
    "file": "Docket24-316_Brief004.pdf",
    "text": "I. [MISSING]\nII. Colorectal cancer screening is cost-effective health care\nIII. Cost is a major barrier to colorectal cancer screening\nIV. Colorectal cancer screening rates would likely fall and death rates would likely rise if the decision below is affirmed\n",
    "reference": "I. Colorectal cancer screening saves lives"
  },
  {
    "file": "Docket24-316_Brief004.pdf",
    "text": "I. Colorectal cancer screening saves lives\nII. [MISSING]\nIII. Cost is a major barrier to colorectal cancer screening\nIV. Colorectal cancer screening rates would likely fall and death rates would likely rise if the decision below is affirmed\n",
    "reference": "II. Colorectal cancer screening is cost-effective health care"
  },
  {
    "file": "Docket24-316_Brief004.pdf",
    "text": "I. Colorectal cancer screening saves lives\nII. Colorectal cancer screening is cost-effective health care\nIII. [MISSING]\nIV. Colorectal cancer screening rates would likely fall and death rates would likely rise if the decision below is affirmed\n",
    "reference": "III. Cost is a major barrier to colorectal cancer screening"
  },
  {
    "file": "Docket24-316_Brief004.pdf",
    "text": "I. Colorectal cancer screening saves lives\nII. Colorectal cancer screening is cost-effective health care\nIII. Cost is a major barrier to colorectal cancer screening\nIV. [MISSING]\n",
    "reference": "IV. Colorectal cancer screening rates would likely fall and death rates would likely rise if the decision below is affirmed"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. [MISSING]\nA. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision\nB. The Other Three Factors Are Also Met\n1. Narrow Jurisdiction\n2. Certain, Limited Duties\n3. Limited Tenure\nII. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide\nA. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations\nB. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve\n",
    "reference": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary\nA. [MISSING]\nB. The Other Three Factors Are Also Met\n1. Narrow Jurisdiction\n2. Certain, Limited Duties\n3. Limited Tenure\nII. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide\nA. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations\nB. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve\n",
    "reference": "A. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary\nA. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision\nB. [MISSING]\n1. Narrow Jurisdiction\n2. Certain, Limited Duties\n3. Limited Tenure\nII. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide\nA. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations\nB. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve\n",
    "reference": "B. The Other Three Factors Are Also Met"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary\nA. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision\nB. The Other Three Factors Are Also Met\n1. [MISSING]\n2. Certain, Limited Duties\n3. Limited Tenure\nII. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide\nA. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations\nB. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve\n",
    "reference": "1. Narrow Jurisdiction"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary\nA. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision\nB. The Other Three Factors Are Also Met\n1. Narrow Jurisdiction\n2. [MISSING]\n3. Limited Tenure\nII. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide\nA. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations\nB. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve\n",
    "reference": "2. Certain, Limited Duties"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary\nA. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision\nB. The Other Three Factors Are Also Met\n1. Narrow Jurisdiction\n2. Certain, Limited Duties\n3. [MISSING]\nII. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide\nA. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations\nB. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve\n",
    "reference": "3. Limited Tenure"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary\nA. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision\nB. The Other Three Factors Are Also Met\n1. Narrow Jurisdiction\n2. Certain, Limited Duties\n3. Limited Tenure\nII. [MISSING]\nA. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations\nB. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve\n",
    "reference": "II. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary\nA. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision\nB. The Other Three Factors Are Also Met\n1. Narrow Jurisdiction\n2. Certain, Limited Duties\n3. Limited Tenure\nII. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide\nA. [MISSING]\nB. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve\n",
    "reference": "A. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations"
  },
  {
    "file": "Docket24-316_Brief005.pdf",
    "text": "I. Members of the U.S. Preventive Services Task Force Are Inferior Officers Who Are Subordinate To The HHS Secretary\nA. The Task Force Members are Removable at Will and Subject to the HHS Secretary\u2019s Direct Supervision\nB. The Other Three Factors Are Also Met\n1. Narrow Jurisdiction\n2. Certain, Limited Duties\n3. Limited Tenure\nII. The Task Force Makes Critical, Evidence- Based Recommendations to Improve Health Outcomes Nationwide\nA. The Task Force\u2019s Mandate Is Narrow, But Critical to Developing Objective and Evidence-Based Preventive Care Services Recommendations\nB. [MISSING]\n",
    "reference": "B. The Task Force\u2019s Recommendations Have Had an Immeasurable Impact on the Southern Black and Brown LGBTQ+ Communities Amici Serve"
  },
  {
    "file": "Docket24-354_Brief001.pdf",
    "text": "I. [MISSING]\nII. Section 254 Violates the Original Understanding of Nondelegation\nIII. Section 254 Violates the Modern Nondelegation Test\nIV. The USF Revenue-Raising Scheme Also Violates the Private Nondelegation Doctrine\nV. The Combination of Delegations Is Unconstitutional\nVI. This Case Is Not Moot\n",
    "reference": "I. Revenue-Raising Is a Legislative Power"
  },
  {
    "file": "Docket24-354_Brief001.pdf",
    "text": "I. Revenue-Raising Is a Legislative Power\nII. [MISSING]\nIII. Section 254 Violates the Modern Nondelegation Test\nIV. The USF Revenue-Raising Scheme Also Violates the Private Nondelegation Doctrine\nV. The Combination of Delegations Is Unconstitutional\nVI. This Case Is Not Moot\n",
    "reference": "II. Section 254 Violates the Original Understanding of Nondelegation"
  },
  {
    "file": "Docket24-354_Brief001.pdf",
    "text": "I. Revenue-Raising Is a Legislative Power\nII. Section 254 Violates the Original Understanding of Nondelegation\nIII. [MISSING]\nIV. The USF Revenue-Raising Scheme Also Violates the Private Nondelegation Doctrine\nV. The Combination of Delegations Is Unconstitutional\nVI. This Case Is Not Moot\n",
    "reference": "III. Section 254 Violates the Modern Nondelegation Test"
  },
  {
    "file": "Docket24-354_Brief001.pdf",
    "text": "I. Revenue-Raising Is a Legislative Power\nII. Section 254 Violates the Original Understanding of Nondelegation\nIII. Section 254 Violates the Modern Nondelegation Test\nIV. [MISSING]\nV. The Combination of Delegations Is Unconstitutional\nVI. This Case Is Not Moot\n",
    "reference": "IV. The USF Revenue-Raising Scheme Also Violates the Private Nondelegation Doctrine"
  },
  {
    "file": "Docket24-354_Brief001.pdf",
    "text": "I. Revenue-Raising Is a Legislative Power\nII. Section 254 Violates the Original Understanding of Nondelegation\nIII. Section 254 Violates the Modern Nondelegation Test\nIV. The USF Revenue-Raising Scheme Also Violates the Private Nondelegation Doctrine\nV. [MISSING]\nVI. This Case Is Not Moot\n",
    "reference": "V. The Combination of Delegations Is Unconstitutional"
  },
  {
    "file": "Docket24-354_Brief001.pdf",
    "text": "I. Revenue-Raising Is a Legislative Power\nII. Section 254 Violates the Original Understanding of Nondelegation\nIII. Section 254 Violates the Modern Nondelegation Test\nIV. The USF Revenue-Raising Scheme Also Violates the Private Nondelegation Doctrine\nV. The Combination of Delegations Is Unconstitutional\nVI. [MISSING]\n",
    "reference": "VI. This Case Is Not Moot"
  },
  {
    "file": "Docket24-362_Brief001.pdf",
    "text": "I. [MISSING]\nII.  THE ELEVENTH CIRCUIT \u2019S DISTORTION OF THE SUPREMACY CLAUSE UNDERMINES CONGRESS \u2019S POWER AND CONFIRMS THE NEED FOR REVIEW\nIII. THE QUESTIONS PRESENTED ARE EXCEPTIONALLY IMPORTANT\n",
    "reference": "I. THE ELEVENTH CIRCUIT \u2019S DECISION DEFEATS CONGRESS \u2019S CORE OBJECTIVE IN ENACTING THE FTCA\u2019 S LAW-ENFORCEMENT PROVISO"
  },
  {
    "file": "Docket24-362_Brief001.pdf",
    "text": "I. THE ELEVENTH CIRCUIT \u2019S DECISION DEFEATS CONGRESS \u2019S CORE OBJECTIVE IN ENACTING THE FTCA\u2019 S LAW-ENFORCEMENT PROVISO\nII. [MISSING]\nIII. THE QUESTIONS PRESENTED ARE EXCEPTIONALLY IMPORTANT\n",
    "reference": "II.  THE ELEVENTH CIRCUIT \u2019S DISTORTION OF THE SUPREMACY CLAUSE UNDERMINES CONGRESS \u2019S POWER AND CONFIRMS THE NEED FOR REVIEW"
  },
  {
    "file": "Docket24-362_Brief001.pdf",
    "text": "I. THE ELEVENTH CIRCUIT \u2019S DECISION DEFEATS CONGRESS \u2019S CORE OBJECTIVE IN ENACTING THE FTCA\u2019 S LAW-ENFORCEMENT PROVISO\nII.  THE ELEVENTH CIRCUIT \u2019S DISTORTION OF THE SUPREMACY CLAUSE UNDERMINES CONGRESS \u2019S POWER AND CONFIRMS THE NEED FOR REVIEW\nIII. [MISSING]\n",
    "reference": "III. THE QUESTIONS PRESENTED ARE EXCEPTIONALLY IMPORTANT"
  },
  {
    "file": "Docket24-362_Brief002.pdf",
    "text": "I. [MISSING]\nA. Claims based on discretionary functions do not arise out of the law-enforcement proviso\ni. The exception does not reach intentional torts like those the proviso permits\nii. The lower courts\u2019 expansion of the exception creates needless conflict with the proviso\nB. If the discretionary-function exception and law-enforcement proviso conflict, the proviso prevails\nII. The Supremacy Clause does not bar FTCA claims because the FTCA is a federal statute\n",
    "reference": "I. The discretionary-function exception is categorically inapplicable to claims arising out of the law-enforcement proviso"
  },
  {
    "file": "Docket24-362_Brief002.pdf",
    "text": "I. The discretionary-function exception is categorically inapplicable to claims arising out of the law-enforcement proviso\nA. [MISSING]\ni. The exception does not reach intentional torts like those the proviso permits\nii. The lower courts\u2019 expansion of the exception creates needless conflict with the proviso\nB. If the discretionary-function exception and law-enforcement proviso conflict, the proviso prevails\nII. The Supremacy Clause does not bar FTCA claims because the FTCA is a federal statute\n",
    "reference": "A. Claims based on discretionary functions do not arise out of the law-enforcement proviso"
  },
  {
    "file": "Docket24-362_Brief002.pdf",
    "text": "I. The discretionary-function exception is categorically inapplicable to claims arising out of the law-enforcement proviso\nA. Claims based on discretionary functions do not arise out of the law-enforcement proviso\ni. [MISSING]\nii. The lower courts\u2019 expansion of the exception creates needless conflict with the proviso\nB. If the discretionary-function exception and law-enforcement proviso conflict, the proviso prevails\nII. The Supremacy Clause does not bar FTCA claims because the FTCA is a federal statute\n",
    "reference": "i. The exception does not reach intentional torts like those the proviso permits"
  },
  {
    "file": "Docket24-362_Brief002.pdf",
    "text": "I. The discretionary-function exception is categorically inapplicable to claims arising out of the law-enforcement proviso\nA. Claims based on discretionary functions do not arise out of the law-enforcement proviso\ni. The exception does not reach intentional torts like those the proviso permits\nii. [MISSING]\nB. If the discretionary-function exception and law-enforcement proviso conflict, the proviso prevails\nII. The Supremacy Clause does not bar FTCA claims because the FTCA is a federal statute\n",
    "reference": "ii. The lower courts\u2019 expansion of the exception creates needless conflict with the proviso"
  },
  {
    "file": "Docket24-362_Brief002.pdf",
    "text": "I. The discretionary-function exception is categorically inapplicable to claims arising out of the law-enforcement proviso\nA. Claims based on discretionary functions do not arise out of the law-enforcement proviso\ni. The exception does not reach intentional torts like those the proviso permits\nii. The lower courts\u2019 expansion of the exception creates needless conflict with the proviso\nB. [MISSING]\nII. The Supremacy Clause does not bar FTCA claims because the FTCA is a federal statute\n",
    "reference": "B. If the discretionary-function exception and law-enforcement proviso conflict, the proviso prevails"
  },
  {
    "file": "Docket24-362_Brief002.pdf",
    "text": "I. The discretionary-function exception is categorically inapplicable to claims arising out of the law-enforcement proviso\nA. Claims based on discretionary functions do not arise out of the law-enforcement proviso\ni. The exception does not reach intentional torts like those the proviso permits\nii. The lower courts\u2019 expansion of the exception creates needless conflict with the proviso\nB. If the discretionary-function exception and law-enforcement proviso conflict, the proviso prevails\nII. [MISSING]\n",
    "reference": "II. The Supremacy Clause does not bar FTCA claims because the FTCA is a federal statute"
  },
  {
    "file": "Docket24-362_Brief003.pdf",
    "text": "I. [MISSING]\nII. Congress Intended for the Discretionary Function Exception to Preclude Liability Only for Acts Grounded in Social, Economic, and Political Policy\nIII. Lower Courts Have Misinterpreted and Misapplied Gaubert\nIV. Lower Courts\u2019 Application of The Exception Is Antithetical to The FTCA\u2019s Plain Text and Original Understanding\nA. \u201cBased Upon\u201d\nB. \u201cDiscretionary Function or Duty\u201d\nC. \u201cThe Exercise or Performance or the Failure to Exercise or Perform a Discretionary Function or Duty\u201d\nV. The Eleventh Circuit\u2019s Decision in This Case Illustrates the Need for this Court\u2019s Review\n",
    "reference": "I. Congress Intended the FTCA to be a Broad Waiver of Sovereign Immunity"
  },
  {
    "file": "Docket24-362_Brief003.pdf",
    "text": "I. Congress Intended the FTCA to be a Broad Waiver of Sovereign Immunity\nII. [MISSING]\nIII. Lower Courts Have Misinterpreted and Misapplied Gaubert\nIV. Lower Courts\u2019 Application of The Exception Is Antithetical to The FTCA\u2019s Plain Text and Original Understanding\nA. \u201cBased Upon\u201d\nB. \u201cDiscretionary Function or Duty\u201d\nC. \u201cThe Exercise or Performance or the Failure to Exercise or Perform a Discretionary Function or Duty\u201d\nV. The Eleventh Circuit\u2019s Decision in This Case Illustrates the Need for this Court\u2019s Review\n",
    "reference": "II. Congress Intended for the Discretionary Function Exception to Preclude Liability Only for Acts Grounded in Social, Economic, and Political Policy"
  },
  {
    "file": "Docket24-362_Brief003.pdf",
    "text": "I. Congress Intended the FTCA to be a Broad Waiver of Sovereign Immunity\nII. Congress Intended for the Discretionary Function Exception to Preclude Liability Only for Acts Grounded in Social, Economic, and Political Policy\nIII. [MISSING]\nIV. Lower Courts\u2019 Application of The Exception Is Antithetical to The FTCA\u2019s Plain Text and Original Understanding\nA. \u201cBased Upon\u201d\nB. \u201cDiscretionary Function or Duty\u201d\nC. \u201cThe Exercise or Performance or the Failure to Exercise or Perform a Discretionary Function or Duty\u201d\nV. The Eleventh Circuit\u2019s Decision in This Case Illustrates the Need for this Court\u2019s Review\n",
    "reference": "III. Lower Courts Have Misinterpreted and Misapplied Gaubert"
  },
  {
    "file": "Docket24-362_Brief003.pdf",
    "text": "I. Congress Intended the FTCA to be a Broad Waiver of Sovereign Immunity\nII. Congress Intended for the Discretionary Function Exception to Preclude Liability Only for Acts Grounded in Social, Economic, and Political Policy\nIII. Lower Courts Have Misinterpreted and Misapplied Gaubert\nIV. [MISSING]\nA. \u201cBased Upon\u201d\nB. \u201cDiscretionary Function or Duty\u201d\nC. \u201cThe Exercise or Performance or the Failure to Exercise or Perform a Discretionary Function or Duty\u201d\nV. The Eleventh Circuit\u2019s Decision in This Case Illustrates the Need for this Court\u2019s Review\n",
    "reference": "IV. Lower Courts\u2019 Application of The Exception Is Antithetical to The FTCA\u2019s Plain Text and Original Understanding"
  },
  {
    "file": "Docket24-362_Brief003.pdf",
    "text": "I. Congress Intended the FTCA to be a Broad Waiver of Sovereign Immunity\nII. Congress Intended for the Discretionary Function Exception to Preclude Liability Only for Acts Grounded in Social, Economic, and Political Policy\nIII. Lower Courts Have Misinterpreted and Misapplied Gaubert\nIV. Lower Courts\u2019 Application of The Exception Is Antithetical to The FTCA\u2019s Plain Text and Original Understanding\nA. [MISSING]\nB. \u201cDiscretionary Function or Duty\u201d\nC. \u201cThe Exercise or Performance or the Failure to Exercise or Perform a Discretionary Function or Duty\u201d\nV. The Eleventh Circuit\u2019s Decision in This Case Illustrates the Need for this Court\u2019s Review\n",
    "reference": "A. \u201cBased Upon\u201d"
  },
  {
    "file": "Docket24-362_Brief003.pdf",
    "text": "I. Congress Intended the FTCA to be a Broad Waiver of Sovereign Immunity\nII. Congress Intended for the Discretionary Function Exception to Preclude Liability Only for Acts Grounded in Social, Economic, and Political Policy\nIII. Lower Courts Have Misinterpreted and Misapplied Gaubert\nIV. Lower Courts\u2019 Application of The Exception Is Antithetical to The FTCA\u2019s Plain Text and Original Understanding\nA. \u201cBased Upon\u201d\nB. [MISSING]\nC. \u201cThe Exercise or Performance or the Failure to Exercise or Perform a Discretionary Function or Duty\u201d\nV. The Eleventh Circuit\u2019s Decision in This Case Illustrates the Need for this Court\u2019s Review\n",
    "reference": "B. \u201cDiscretionary Function or Duty\u201d"
  },
  {
    "file": "Docket24-362_Brief003.pdf",
    "text": "I. Congress Intended the FTCA to be a Broad Waiver of Sovereign Immunity\nII. Congress Intended for the Discretionary Function Exception to Preclude Liability Only for Acts Grounded in Social, Economic, and Political Policy\nIII. Lower Courts Have Misinterpreted and Misapplied Gaubert\nIV. Lower Courts\u2019 Application of The Exception Is Antithetical to The FTCA\u2019s Plain Text and Original Understanding\nA. \u201cBased Upon\u201d\nB. \u201cDiscretionary Function or Duty\u201d\nC. [MISSING]\nV. The Eleventh Circuit\u2019s Decision in This Case Illustrates the Need for this Court\u2019s Review\n",
    "reference": "C. \u201cThe Exercise or Performance or the Failure to Exercise or Perform a Discretionary Function or Duty\u201d"
  },
  {
    "file": "Docket24-362_Brief003.pdf",
    "text": "I. Congress Intended the FTCA to be a Broad Waiver of Sovereign Immunity\nII. Congress Intended for the Discretionary Function Exception to Preclude Liability Only for Acts Grounded in Social, Economic, and Political Policy\nIII. Lower Courts Have Misinterpreted and Misapplied Gaubert\nIV. Lower Courts\u2019 Application of The Exception Is Antithetical to The FTCA\u2019s Plain Text and Original Understanding\nA. \u201cBased Upon\u201d\nB. \u201cDiscretionary Function or Duty\u201d\nC. \u201cThe Exercise or Performance or the Failure to Exercise or Perform a Discretionary Function or Duty\u201d\nV. [MISSING]\n",
    "reference": "V. The Eleventh Circuit\u2019s Decision in This Case Illustrates the Need for this Court\u2019s Review"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. [MISSING]\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "I. St. Isidore is not engaged in state action"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. [MISSING]\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "A. St. Isidore does not satisfy this Court\u2019s state-action tests"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. [MISSING]\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "1. Rendell-Baker \u2019s principles guide the analysis"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. [MISSING]\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. [MISSING]\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "a. Labels don\u2019t control"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. [MISSING]\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "b. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor."
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. [MISSING]\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "3. The State is not entwined with St. Isidore"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. [MISSING]\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct."
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. [MISSING]\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "5. Education is not and has never been an exclusive public function"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. [MISSING]\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. [MISSING]\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "7. Countervailing reasons weigh against finding state action"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. [MISSING]\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "B. St. Isidore is not a governmental entity for First Amendment purposes"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. [MISSING]\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "II. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. [MISSING]\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "A. The affiliation ban discriminates based on religious status"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. [MISSING]\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "B. The sectarian-use ban discriminates based on religious use"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. [MISSING]\nA. Historical practices support public funding for religious schools\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "III. Neutrally administering the charter-school program does not violate the Establishment Clause"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. [MISSING]\nB. The Establishment Clause does not forbid the neutral administration of generally available public programs\n",
    "reference": "A. Historical practices support public funding for religious schools"
  },
  {
    "file": "Docket24-394_Brief001.pdf",
    "text": "I. St. Isidore is not engaged in state action\nA. St. Isidore does not satisfy this Court\u2019s state-action tests\n1. Rendell-Baker \u2019s principles guide the analysis\n2. Labeling charter schools \u201cpublic\u201d doesn\u2019t make them state actors\na. Labels don\u2019t control\nb. The substance of the \u201cpublic\u201d label shows St. Isidore is not a state actor.\n3. The State is not entwined with St. Isidore\n4. The State does not compel or encourage St. Isidore\u2019s religious status or conduct.\n5. Education is not and has never been an exclusive public function\n6. Contracting with private entities to provide more educational options does not delegate a state duty. Contracting with private entities to provide more educational options does not delegate a state duty\n7. Countervailing reasons weigh against finding state action\nB. St. Isidore is not a governmental entity for First Amendment purposes\nII. The Free Exercise Clause forbids the State from excluding St. Isidore because of its religious character\nA. The affiliation ban discriminates based on religious status\nB. The sectarian-use ban discriminates based on religious use\nIII. Neutrally administering the charter-school program does not violate the Establishment Clause\nA. Historical practices support public funding for religious schools\nB. [MISSING]\n",
    "reference": "B. The Establishment Clause does not forbid the neutral administration of generally available public programs"
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. [MISSING]\nII. St. Isidore Is A Private Entity And Its Conduct Is Not State Action\nA. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model\nB. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail\n1. St. Isidore Is Not A Government Entity\n2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations\n3. Education Is Not A Traditional And Exclusive Public Function\n4. Respondent\u2019s Invocation Of Carson Likewise Fails\nIII. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights\n",
    "reference": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious."
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious.\nII. [MISSING]\nA. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model\nB. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail\n1. St. Isidore Is Not A Government Entity\n2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations\n3. Education Is Not A Traditional And Exclusive Public Function\n4. Respondent\u2019s Invocation Of Carson Likewise Fails\nIII. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights\n",
    "reference": "II. St. Isidore Is A Private Entity And Its Conduct Is Not State Action"
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious.\nII. St. Isidore Is A Private Entity And Its Conduct Is Not State Action\nA. [MISSING]\nB. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail\n1. St. Isidore Is Not A Government Entity\n2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations\n3. Education Is Not A Traditional And Exclusive Public Function\n4. Respondent\u2019s Invocation Of Carson Likewise Fails\nIII. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights\n",
    "reference": "A. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model"
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious.\nII. St. Isidore Is A Private Entity And Its Conduct Is Not State Action\nA. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model\nB. [MISSING]\n1. St. Isidore Is Not A Government Entity\n2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations\n3. Education Is Not A Traditional And Exclusive Public Function\n4. Respondent\u2019s Invocation Of Carson Likewise Fails\nIII. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights\n",
    "reference": "B. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail"
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious.\nII. St. Isidore Is A Private Entity And Its Conduct Is Not State Action\nA. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model\nB. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail\n1. [MISSING]\n2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations\n3. Education Is Not A Traditional And Exclusive Public Function\n4. Respondent\u2019s Invocation Of Carson Likewise Fails\nIII. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights\n",
    "reference": "1. St. Isidore Is Not A Government Entity"
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious.\nII. St. Isidore Is A Private Entity And Its Conduct Is Not State Action\nA. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model\nB. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail\n1. St. Isidore Is Not A Government Entity\n2. [MISSING]\n3. Education Is Not A Traditional And Exclusive Public Function\n4. Respondent\u2019s Invocation Of Carson Likewise Fails\nIII. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights\n",
    "reference": "2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations"
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious.\nII. St. Isidore Is A Private Entity And Its Conduct Is Not State Action\nA. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model\nB. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail\n1. St. Isidore Is Not A Government Entity\n2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations\n3. [MISSING]\n4. Respondent\u2019s Invocation Of Carson Likewise Fails\nIII. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights\n",
    "reference": "3. Education Is Not A Traditional And Exclusive Public Function"
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious.\nII. St. Isidore Is A Private Entity And Its Conduct Is Not State Action\nA. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model\nB. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail\n1. St. Isidore Is Not A Government Entity\n2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations\n3. Education Is Not A Traditional And Exclusive Public Function\n4. [MISSING]\nIII. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights\n",
    "reference": "4. Respondent\u2019s Invocation Of Carson Likewise Fails"
  },
  {
    "file": "Docket24-394_Brief002.pdf",
    "text": "I. A State Cannot Deny Generally Available Funding To A School Because It Is Religious.\nII. St. Isidore Is A Private Entity And Its Conduct Is Not State Action\nA. St. Isidore Is A Private Entity That Independently Develops And Delivers Its Unique Educational Model\nB. The Lower Court\u2019s Attempts To Portray St. Isidore As A State Actor All Fail\n1. St. Isidore Is Not A Government Entity\n2. The State Is Not Closely Entwined With St. Isidore\u2019s Private Operations\n3. Education Is Not A Traditional And Exclusive Public Function\n4. Respondent\u2019s Invocation Of Carson Likewise Fails\nIII. [MISSING]\n",
    "reference": "III. The Establishment Clause Does Not Require The State To Violate St. Isidore\u2019s Free Exercise Rights"
  },
  {
    "file": "Docket24-394_Brief003.pdf",
    "text": "A. [MISSING]\n1. The Free Exercise Clause generally forbids a State from excluding otherwise qualified schools from public funding programs based on religious exercise\n2. Oklahoma\u2019s exclusion of St. Isidore from the charter-school program based on religious exercise violates the Free Exercise Clause\nB. The Free Exercise Clause protects St. Isidore\n1. St. Isidore is not part of the State itself\n2. St. Isidore\u2019s conduct is not generally attributable to the State\n",
    "reference": "A. Excluding St. Isidore from the State\u2019s charter-school program violates the Free Exercise Clause"
  },
  {
    "file": "Docket24-394_Brief003.pdf",
    "text": "A. Excluding St. Isidore from the State\u2019s charter-school program violates the Free Exercise Clause\n1. [MISSING]\n2. Oklahoma\u2019s exclusion of St. Isidore from the charter-school program based on religious exercise violates the Free Exercise Clause\nB. The Free Exercise Clause protects St. Isidore\n1. St. Isidore is not part of the State itself\n2. St. Isidore\u2019s conduct is not generally attributable to the State\n",
    "reference": "1. The Free Exercise Clause generally forbids a State from excluding otherwise qualified schools from public funding programs based on religious exercise"
  },
  {
    "file": "Docket24-394_Brief003.pdf",
    "text": "A. Excluding St. Isidore from the State\u2019s charter-school program violates the Free Exercise Clause\n1. The Free Exercise Clause generally forbids a State from excluding otherwise qualified schools from public funding programs based on religious exercise\n2. [MISSING]\nB. The Free Exercise Clause protects St. Isidore\n1. St. Isidore is not part of the State itself\n2. St. Isidore\u2019s conduct is not generally attributable to the State\n",
    "reference": "2. Oklahoma\u2019s exclusion of St. Isidore from the charter-school program based on religious exercise violates the Free Exercise Clause"
  },
  {
    "file": "Docket24-394_Brief003.pdf",
    "text": "A. Excluding St. Isidore from the State\u2019s charter-school program violates the Free Exercise Clause\n1. The Free Exercise Clause generally forbids a State from excluding otherwise qualified schools from public funding programs based on religious exercise\n2. Oklahoma\u2019s exclusion of St. Isidore from the charter-school program based on religious exercise violates the Free Exercise Clause\nB. [MISSING]\n1. St. Isidore is not part of the State itself\n2. St. Isidore\u2019s conduct is not generally attributable to the State\n",
    "reference": "B. The Free Exercise Clause protects St. Isidore"
  },
  {
    "file": "Docket24-394_Brief003.pdf",
    "text": "A. Excluding St. Isidore from the State\u2019s charter-school program violates the Free Exercise Clause\n1. The Free Exercise Clause generally forbids a State from excluding otherwise qualified schools from public funding programs based on religious exercise\n2. Oklahoma\u2019s exclusion of St. Isidore from the charter-school program based on religious exercise violates the Free Exercise Clause\nB. The Free Exercise Clause protects St. Isidore\n1. [MISSING]\n2. St. Isidore\u2019s conduct is not generally attributable to the State\n",
    "reference": "1. St. Isidore is not part of the State itself"
  },
  {
    "file": "Docket24-394_Brief003.pdf",
    "text": "A. Excluding St. Isidore from the State\u2019s charter-school program violates the Free Exercise Clause\n1. The Free Exercise Clause generally forbids a State from excluding otherwise qualified schools from public funding programs based on religious exercise\n2. Oklahoma\u2019s exclusion of St. Isidore from the charter-school program based on religious exercise violates the Free Exercise Clause\nB. The Free Exercise Clause protects St. Isidore\n1. St. Isidore is not part of the State itself\n2. [MISSING]\n",
    "reference": "2. St. Isidore\u2019s conduct is not generally attributable to the State"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. [MISSING]\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. [MISSING]\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "A. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. [MISSING]\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. [MISSING]\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. [MISSING]\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. [MISSING]\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "B. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. [MISSING]\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. [MISSING]\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. [MISSING]\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "II. The IRS\u2019s counterarguments lack merit"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. [MISSING]\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "A. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. [MISSING]\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. [MISSING]\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. [MISSING]\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "3. Royal Canin  doesn\u2019t help the government"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. [MISSING]\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "4. The government\u2019s policy argument is meritless"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. [MISSING]\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "B. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. [MISSING]\nD. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial\n",
    "reference": "C. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect"
  },
  {
    "file": "Docket24-416_Brief001.pdf",
    "text": "I. The Tax Court had jurisdiction under I.R.C. \u00a7 6330 to review and rule on Zuch\u2019s unpaid tax or tax liability, so the case isn\u2019t moot\nA. The Tax Court had jurisdiction to review the Appeals Office\u2019s determination of Zuch\u2019s entitlement to the estimated payments\n1. Section 6330\u2019s plain text states that the Tax Court has jurisdiction to review the Appeals Office\u2019s \u201cdetermination\u201d of a taxpayer\u2019s challenge to \u201cany relevant issue relating to [her] unpaid tax\u201d or her \u201cunderlying liability.\u201d\n2. Statutory context confirms that Congress gave the Tax Court continuing jurisdiction to resolve issues relating to the unpaid tax and tax liability disputes\n3. The Tax Court had jurisdiction under \u00a7  6330 to review the Appeals Office\u2019s determination, including its resolution of Zuch\u2019s entitlement to the estimated payments\nB. Zuch\u2019s case did not become moot when the IRS decided to stop pursuing the levy, because the parties disputed, and the Tax Court had the power to adjudicate, Zuch\u2019s entitlement to the estimated payments\n1. A case becomes moot only when the parties no longer have a concrete interest in the outcome of the litigation and judicial relief is not likely to redress any injury\n2. Zuch\u2019s challenge isn\u2019t moot because a favorable Tax Court ruling on underlying liability or unpaid tax would likely redress her pocketbook injury\nII. The IRS\u2019s counterarguments lack merit\nA. The Tax Court\u2019s jurisdiction to review whether Zuch was entitled to the prepayments didn\u2019t dissolve once the IRS no longer needed the levy\n1. There is no textual basis in \u00a7  6330 for the government\u2019s continuing - levy requirement\n2. The government misconstrues \u00a7 6330\u2019s history and downplays its remedial purpose, which both support the Tax Court\u2019s \u00a7  6330 jurisdiction to review unpaid tax and liability disputes even if the IRS no longer pursues the levy\n3. Royal Canin  doesn\u2019t help the government\n4. The government\u2019s policy argument is meritless\nB. The Tax Court\u2019s authority is not limited to approving or rejecting a proposed levy, but includes the power to issue binding judgments\nC. The government\u2019s claim that the parties lack a legally cognizable interest in the case once the IRS decides not to move forward with the levy is incorrect\nD. [MISSING]\n",
    "reference": "D. Whether Zuch\u2019s challenge is a dispute about an unpaid tax or underlying liability is immaterial"
  },
  {
    "file": "Docket24-416_Brief002.pdf",
    "text": " [MISSING]\nA. The text of Section 6330 makes clear that a pre-levy proceeding is moot when the IRS no longer seeks to levy on a taxpayer\u2019s property\nB. Section 6330\u2019s history and function within the Internal  Revenue Code confirm that a pre-levy proceeding becomes moot when there is no longer a live dispute over a proposed levy\nC. The contrary arguments offered by respondent and the court of appeals lack merit\n1. The Tax Court lacks jurisdiction to consider a taxpayer\u2019s \u201cunderlying tax liability\u201d when there is no live dispute over a proposed levy\n2. The Tax Court has no \u201cimplicit\u201d jurisdiction to review offsets in a Section 6330 proceeding\nD. The instant case is moot\n",
    "reference": "A pre-levy proceeding under 26 U.S.C . 6330 is moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding"
  },
  {
    "file": "Docket24-416_Brief002.pdf",
    "text": "A pre-levy proceeding under 26 U.S.C . 6330 is moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding\nA. [MISSING]\nB. Section 6330\u2019s history and function within the Internal  Revenue Code confirm that a pre-levy proceeding becomes moot when there is no longer a live dispute over a proposed levy\nC. The contrary arguments offered by respondent and the court of appeals lack merit\n1. The Tax Court lacks jurisdiction to consider a taxpayer\u2019s \u201cunderlying tax liability\u201d when there is no live dispute over a proposed levy\n2. The Tax Court has no \u201cimplicit\u201d jurisdiction to review offsets in a Section 6330 proceeding\nD. The instant case is moot\n",
    "reference": "A. The text of Section 6330 makes clear that a pre-levy proceeding is moot when the IRS no longer seeks to levy on a taxpayer\u2019s property"
  },
  {
    "file": "Docket24-416_Brief002.pdf",
    "text": "A pre-levy proceeding under 26 U.S.C . 6330 is moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding\nA. The text of Section 6330 makes clear that a pre-levy proceeding is moot when the IRS no longer seeks to levy on a taxpayer\u2019s property\nB. [MISSING]\nC. The contrary arguments offered by respondent and the court of appeals lack merit\n1. The Tax Court lacks jurisdiction to consider a taxpayer\u2019s \u201cunderlying tax liability\u201d when there is no live dispute over a proposed levy\n2. The Tax Court has no \u201cimplicit\u201d jurisdiction to review offsets in a Section 6330 proceeding\nD. The instant case is moot\n",
    "reference": "B. Section 6330\u2019s history and function within the Internal  Revenue Code confirm that a pre-levy proceeding becomes moot when there is no longer a live dispute over a proposed levy"
  },
  {
    "file": "Docket24-416_Brief002.pdf",
    "text": "A pre-levy proceeding under 26 U.S.C . 6330 is moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding\nA. The text of Section 6330 makes clear that a pre-levy proceeding is moot when the IRS no longer seeks to levy on a taxpayer\u2019s property\nB. Section 6330\u2019s history and function within the Internal  Revenue Code confirm that a pre-levy proceeding becomes moot when there is no longer a live dispute over a proposed levy\nC. [MISSING]\n1. The Tax Court lacks jurisdiction to consider a taxpayer\u2019s \u201cunderlying tax liability\u201d when there is no live dispute over a proposed levy\n2. The Tax Court has no \u201cimplicit\u201d jurisdiction to review offsets in a Section 6330 proceeding\nD. The instant case is moot\n",
    "reference": "C. The contrary arguments offered by respondent and the court of appeals lack merit"
  },
  {
    "file": "Docket24-416_Brief002.pdf",
    "text": "A pre-levy proceeding under 26 U.S.C . 6330 is moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding\nA. The text of Section 6330 makes clear that a pre-levy proceeding is moot when the IRS no longer seeks to levy on a taxpayer\u2019s property\nB. Section 6330\u2019s history and function within the Internal  Revenue Code confirm that a pre-levy proceeding becomes moot when there is no longer a live dispute over a proposed levy\nC. The contrary arguments offered by respondent and the court of appeals lack merit\n1. [MISSING]\n2. The Tax Court has no \u201cimplicit\u201d jurisdiction to review offsets in a Section 6330 proceeding\nD. The instant case is moot\n",
    "reference": "1. The Tax Court lacks jurisdiction to consider a taxpayer\u2019s \u201cunderlying tax liability\u201d when there is no live dispute over a proposed levy"
  },
  {
    "file": "Docket24-416_Brief002.pdf",
    "text": "A pre-levy proceeding under 26 U.S.C . 6330 is moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding\nA. The text of Section 6330 makes clear that a pre-levy proceeding is moot when the IRS no longer seeks to levy on a taxpayer\u2019s property\nB. Section 6330\u2019s history and function within the Internal  Revenue Code confirm that a pre-levy proceeding becomes moot when there is no longer a live dispute over a proposed levy\nC. The contrary arguments offered by respondent and the court of appeals lack merit\n1. The Tax Court lacks jurisdiction to consider a taxpayer\u2019s \u201cunderlying tax liability\u201d when there is no live dispute over a proposed levy\n2. [MISSING]\nD. The instant case is moot\n",
    "reference": "2. The Tax Court has no \u201cimplicit\u201d jurisdiction to review offsets in a Section 6330 proceeding"
  },
  {
    "file": "Docket24-416_Brief002.pdf",
    "text": "A pre-levy proceeding under 26 U.S.C . 6330 is moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding\nA. The text of Section 6330 makes clear that a pre-levy proceeding is moot when the IRS no longer seeks to levy on a taxpayer\u2019s property\nB. Section 6330\u2019s history and function within the Internal  Revenue Code confirm that a pre-levy proceeding becomes moot when there is no longer a live dispute over a proposed levy\nC. The contrary arguments offered by respondent and the court of appeals lack merit\n1. The Tax Court lacks jurisdiction to consider a taxpayer\u2019s \u201cunderlying tax liability\u201d when there is no live dispute over a proposed levy\n2. The Tax Court has no \u201cimplicit\u201d jurisdiction to review offsets in a Section 6330 proceeding\nD. [MISSING]\n",
    "reference": "D. The instant case is moot"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. [MISSING]\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. [MISSING]\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "A. Petitioners suffered classic  pocketbook injuries"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. [MISSING]\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "B. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. [MISSING]\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "II. Petitioners\u2019 injuries are redressable"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. [MISSING]\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "A. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. [MISSING]\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "1. Removing the coercive effect of government standards provides redress"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. [MISSING]\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. [MISSING]\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "B. Petitioners have established redressability because they can rely on the predictable  effect of emission standards"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. [MISSING]\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "1. Litigants can rely on common sense and basic economics to demonstrate redressability"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. [MISSING]\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. [MISSING]\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "C. The court of appeals\u2019 redressability analysis is wrong"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. [MISSING]\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "1. The decision below contradicts this Court\u2019s precedents and common sense"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. [MISSING]\n3. The decision below creates bad policy\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "2. The decision below conflates redressability with mootness"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. [MISSING]\nD. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity\n",
    "reference": "3. The decision below creates bad policy"
  },
  {
    "file": "Docket24-7_Brief001.pdf",
    "text": "I. Petitioners suffered an injury-in-fact caused by EPA\u2019s action\nA. Petitioners suffered classic  pocketbook injuries\nB. Petitioners\u2019 injuries are fairly traceable to EPA\u2019s waiver\nII. Petitioners\u2019 injuries are redressable\nA. Petitioners have established redressability because they are challenging a regulatory hurdle to the use of their product s\n1. Removing the coercive effect of government standards provides redress\n2. California\u2019s standards impose a new regulatory hurdle to the use of petitioners\u2019 products\nB. Petitioners have established redressability because they can rely on the predictable  effect of emission standards\n1. Litigants can rely on common sense and basic economics to demonstrate redressability\n2. Automakers would predictably adjust their fleets if EPA\u2019s waiver were vacated\nC. The court of appeals\u2019 redressability analysis is wrong\n1. The decision below contradicts this Court\u2019s precedents and common sense\n2. The decision below conflates redressability with mootness\n3. The decision below creates bad policy\nD. [MISSING]\n",
    "reference": "D. At the very least, petitioners have established redressability because the challenged waiver continues in perpetuity"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. [MISSING]\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "I. Petitioners failed to establish redressability"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. [MISSING]\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "A. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. [MISSING]\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "B. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. [MISSING]\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "C. Petitioners did not introduce evidence establishing re dressability"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. [MISSING]\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "II. Petitioners identify no valid basis for reversal"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. [MISSING]\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "A. Government regulations implicating the use of a product do not categorically establish standing for producers to sue"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. [MISSING]\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. [MISSING]\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "2. Petitioners\u2019 rule would violate basic principles of Article III standing"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. [MISSING]\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "3. Petitioners\u2019 policy arguments do not justify their rule"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. [MISSING]\nC. The duration of the waiver does not, by itself, establish standing\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "B. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. [MISSING]\nD. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing\n",
    "reference": "C. The duration of the waiver does not, by itself, establish standing"
  },
  {
    "file": "Docket24-7_Brief002.pdf",
    "text": "I. Petitioners failed to establish redressability\nA. It was petitioners\u2019 burden to introduce evidence establishing each element of Article III standing\nB. The circumstances of this case raised a serious question as to whether  petitioners\u2019 claim was redressable\nC. Petitioners did not introduce evidence establishing re dressability\nII. Petitioners identify no valid basis for reversal\nA. Government regulations implicating the use of a product do not categorically establish standing for producers to sue\n1. Petitioners\u2019 proposed rule is at odds with the precedent they invoke\n2. Petitioners\u2019 rule would violate basic principles of Article III standing\n3. Petitioners\u2019 policy arguments do not justify their rule\nB. Unsupported predictions about the effect of a judgment on a third party are insufficient to establish redressability\nC. The duration of the waiver does not, by itself, establish standing\nD. [MISSING]\n",
    "reference": "D. Petitioners\u2019 post hoc attempts to identify evidence on redressability fail to establish standing"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": " [MISSING]\nA. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound\n1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party\n2. Petitioners were not exempt from making the case-specific showing of proof required by Article III\nB. On the particular record here, petitioners failed to carry their burden of demonstrating redressability\n1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case\n2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce\n3. Petitioners\u2019 policy arguments are irrelev ant and unsound\nC. The court of appeals\u2019 error regarding the duration of the waiver was harmless\n",
    "reference": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid\nA. [MISSING]\n1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party\n2. Petitioners were not exempt from making the case-specific showing of proof required by Article III\nB. On the particular record here, petitioners failed to carry their burden of demonstrating redressability\n1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case\n2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce\n3. Petitioners\u2019 policy arguments are irrelev ant and unsound\nC. The court of appeals\u2019 error regarding the duration of the waiver was harmless\n",
    "reference": "A. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid\nA. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound\n1. [MISSING]\n2. Petitioners were not exempt from making the case-specific showing of proof required by Article III\nB. On the particular record here, petitioners failed to carry their burden of demonstrating redressability\n1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case\n2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce\n3. Petitioners\u2019 policy arguments are irrelev ant and unsound\nC. The court of appeals\u2019 error regarding the duration of the waiver was harmless\n",
    "reference": "1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid\nA. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound\n1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party\n2. [MISSING]\nB. On the particular record here, petitioners failed to carry their burden of demonstrating redressability\n1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case\n2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce\n3. Petitioners\u2019 policy arguments are irrelev ant and unsound\nC. The court of appeals\u2019 error regarding the duration of the waiver was harmless\n",
    "reference": "2. Petitioners were not exempt from making the case-specific showing of proof required by Article III"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid\nA. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound\n1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party\n2. Petitioners were not exempt from making the case-specific showing of proof required by Article III\nB. [MISSING]\n1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case\n2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce\n3. Petitioners\u2019 policy arguments are irrelev ant and unsound\nC. The court of appeals\u2019 error regarding the duration of the waiver was harmless\n",
    "reference": "B. On the particular record here, petitioners failed to carry their burden of demonstrating redressability"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid\nA. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound\n1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party\n2. Petitioners were not exempt from making the case-specific showing of proof required by Article III\nB. On the particular record here, petitioners failed to carry their burden of demonstrating redressability\n1. [MISSING]\n2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce\n3. Petitioners\u2019 policy arguments are irrelev ant and unsound\nC. The court of appeals\u2019 error regarding the duration of the waiver was harmless\n",
    "reference": "1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid\nA. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound\n1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party\n2. Petitioners were not exempt from making the case-specific showing of proof required by Article III\nB. On the particular record here, petitioners failed to carry their burden of demonstrating redressability\n1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case\n2. [MISSING]\n3. Petitioners\u2019 policy arguments are irrelev ant and unsound\nC. The court of appeals\u2019 error regarding the duration of the waiver was harmless\n",
    "reference": "2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid\nA. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound\n1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party\n2. Petitioners were not exempt from making the case-specific showing of proof required by Article III\nB. On the particular record here, petitioners failed to carry their burden of demonstrating redressability\n1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case\n2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce\n3. [MISSING]\nC. The court of appeals\u2019 error regarding the duration of the waiver was harmless\n",
    "reference": "3. Petitioners\u2019 policy arguments are irrelev ant and unsound"
  },
  {
    "file": "Docket24-7_Brief003.pdf",
    "text": "Petitioners failed to create a record showing that their asserted injuries would likely be redressed if EPA\u2019s 2022 reinstatement of its 2013 waiver were held to be invalid\nA. Because Article III requires the party invoking a federal court\u2019s jurisdiction to prove redressability, petitioners\u2019 proposed categorical rule is unsound\n1. Article III demands more than mere speculation when a party\u2019s theory of standing relies on future conduct by a third party\n2. Petitioners were not exempt from making the case-specific showing of proof required by Article III\nB. On the particular record here, petitioners failed to carry their burden of demonstrating redressability\n1. Petitioners failed  to adduce the affirmative evidence required to prove standing in this case\n2. Attorney argument cannot substitute  for the record evidence that petitioners failed to adduce\n3. Petitioners\u2019 policy arguments are irrelev ant and unsound\nC. [MISSING]\n",
    "reference": "C. The court of appeals\u2019 error regarding the duration of the waiver was harmless"
  },
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