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95 M. Christine Fotopulos (cfotopulos@gmail.com) is an Attorney-Advisor with the Disability Rights Section, Civil Rights Division of the U.S. Department of Justice. She would like to express her appreciation to Professor Christopher R. Yukins of The George Washington Univerrsit Law School for his generous support and feedback on earlier drafts of this article. The views expressed in this article are those of the author and do not represent those of the U.S. Department of Justice. CIVIL RIGHTS...

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