1141 Luke Ledbetter is law clerk to the Honorable James R. Nowlin, U.S. District Judge for the Western District of Texas. He received his J.D. degree from the University of Texas School of Law in August 2006 and his LL.M. from The University of Cambridge in July 2006. This article is the winner of the 2005 Bracewell and Guiliani Outstanding Law Reform Note. The author thanks Professor Wendy Wagner, Professor Charles Silver, and University of Texas—Austin President William Powers for their help...