Raymond J. LaJeunesse, Jr., Vice President and Legal Director (2001-present)
Foundation Staff Attorney, 1971-2001; Legislative Assistant (part-time), Virginia House of Delegates, 1972-73; self-employed political research consultant, Washington, DC, 1969-71; Research Director, United Republicans of America, Washington, DC, 1967-68; Martindale-Hubbell® AV® Peer Review Rated; American Lawyer Media 2013 Top Rated Lawyer in Labor & Employment and Virginia Top-Rated Lawyer; received Avvo's "Superb" rating in "Constitutional" and "Employment/Labor" law categories. Bar Admissions: Virginia, 1967; District of Columbia, 1972; U.S. Supreme Court, 1982 (admitted only in VA & DC). Law School: Washington & Lee University, LL.B., 1967. College: Providence College, A.B., Humanities, cum laude, 1964. Member: Vice Chairman, Labor and Employment Practice Group, Federalist Society National Lawyers Division, 2000-present; Advisor for Labor-Related Agencies, Office of the President-Elect, 1980-81. Publications: "The Controversial 'Card Check' Bill, Stalled in the United States Congress, Presents Serious Legal and Policy Issues," 14 TEXAS REVIEW OF LAW & POLITICS 209 (2010); "Workers' Experiences in Attempting to Exercise Their Rights Under Communications Workers v. Beck", Engage, Apr. 2002, at 102; "The Future of Unions," Federalist Society Labor & Employment Law News, Spring 1999, at 1; Comment on T.R. Haggard, "Union Security in the Context of Labor Arbitration," 1994 Proceedings of National Academy of Arbitrators124; "Employees' Freedom from Ideological Conformity: A Right Without a Remedy?," 5 Journal of Labor Research 265 (1984); Case Comment, "A Struck Carrier's Right to Attempt to Operate," 24 Washington & Lee Law Review 80 (1967). Reported Cases (partial listing): Marquez v. Screen Actors Guild, 525 U.S. 33 (1998); Airline Pilots Ass'n v. Miller, 523 U.S. 866 (1998); Lehnert v. Ferris Faculty Ass'n, 500 U.S. 507 (1991); Wessel v. City of Albuquerque, 299 F.3d 1186 (10th Cir. 2002), after remand, 463 F.3d 1138 (10th Cir. 2006); Hohe v. Casey, 956 F.2d 399 (3d Cir. 1992); Ferriso v. NLRB, 125 F.3d 865 (D.C. Cir. 1997); Bromley v. Michigan Education Ass'n, 82 F.3d 686 (6th Cir. 1996); Harrington v. City of Albuquerque, 222 F.R.D. 505 (D.N.M. 2004); Lutz v. Machinists, 121 F. Supp. 2d 498 (E.D. Va. 2000); Browne v. Wisconsin Employment Relations Commission, 485 N.W. 2d 376 (Wis. 1992).
Byron S. Andrus, Staff Attorney (2014-present)
Koch Associate, Charles Koch Institute, Arlington, VA, 2014-2015; Legal Intern, National Right to Work Legal Defense Foundation, 2012-2013; Legal Intern, National Organization for the Reform of Marijuana Laws, June 2011-August 2011; Intern, Office of U.S. Senator David Vitter, July 2010-August 2010. Bar Admissions: District of Columbia, 2014 (admitted in D.C. only). Law School: George Mason University School of Law, J.D., 2013. College: Louisiana State University, B.A. summa cum laude, 2010. Member: Federalist Society.
Bruce N. Cameron, Staff Attorney (1976-present)
Reed Larson Professor of Labor Law, Regent University School of Law, 2007-present; Intern, U.S. Attorneys Office, Justice Honors Program, Atlanta, GA, U.S. Department of Justice, 1975-76. Bar Admissions: Georgia, 1976; U.S. Supreme Court, 1982; District of Columbia, 1984; Massachusetts Supreme Judicial Court, 1984 (admitted only in GA, DC & MA). Law School: Emory University, J.D., 1976. College: Andrews University, B.A., Business Administration/Political Science, with honors, 1973. Member: Virginia State Advisory Committee to the U.S. Commission on Civil Rights (2015-2019); Federalist Society Faculty Division; Christian Legal Society. Publications (partial listing): "The Hardison Case," Liberty, Sept.-Oct. 1977, at 15; "Rebuttal: Right to Work Law Note," 14 Georgia State Bar Journal 138 (1978); "Labor Unions and Rights of Conscience," Liberty, May-June 1981, at 6; "Caution: Agency Fee Payers Can Be Harmful to Your Financial Health," Illinois Public Employee Relations Report, Summer 1987, at 7; Co-author, "Agency Service Fee Litigation," in Lawyers Weekly, A Judicial Guide to Labor and Employment 423 (1990); "Union Dues and Ethical Don'ts," Vision, July-Aug. 1996, at 4; "An Employee's Guide to Union Dues and Religious Do Nots," monograph published by the Foundation; "Jethro Was Right: Arbitrate, Not Litigate," Adventist Lawyer 2002; "Your Other Right," 97 Liberty, July-Aug. 2002, at 21. "Card Sharks and Marks," LIBERTY, Jan.-Feb. 2006, at 26; "Religious Accomodation in Forced Dues Environments," ENGAGE, Mar. 2006, at 122; "Where Are The Bridges of Madison?" 106 LIBERTY 12, July-August 2011; "EI, EI, Oh What An Employee: The Biblical Basis for Teaching Emotional Intelligence in the Workplace," (2011). Reported Cases (partial listing): Equal Opportunity Employment Commission v. University of Detroit, 904 F.2d 331 (6th Cir. 1990); Wilson v. NLRB, 920 F.2d 1282 (6th Cir. 1990); Machinists Lodge 720 v. NLRB, 626 F.2d 119 (9th Cir. 1980); Katter v. Ohio Employment Labor Relations Bd., 492 F.Supp.2d 851 (S.D. OH 2007); Sheridan v. Electrical Workers Local 455, 940 F. Supp. 368 (D. Mass. 1996); Equal Employment Opportunity Commission v. AFSCME Council 82, 937 F. Supp. 166 (N.D. N.Y. 1996); Wareham Education Ass'n v. Labor Relations Commission, 713 N.E.2d 363 (Mass. 1999); Conley v. Massachusetts Bay Transportation Authority, 539 N.E.2d 1024 (Mass. 1989); Lyons v. Labor Relations Commission, 492 N.E.2d 343 (Mass. 1986); School Committee v. Greenfield Education Ass'n, 431 N.E.2d 180 (Mass. 1982).
Milton L. Chappell, Staff Attorney (1976-present)
Foundation Law Clerk, 1975-76; Legal Intern, Counsel for the Columbia Union Conference Association of Seventh-day Adventists, Takoma Park, MD, 1974-75. Bar Admissions: Maryland, 1976; District of Columbia, 1977; U.S. Supreme Court, 1980 (admitted only in MD & DC). Law School: Catholic University, J.D., 1976. College: Washington Adventist University, B.A., Sociology/Political Science, summa cum laude, 1972. Member: Federalist Society. Publications: "Protecting the Rights of State Employees Against Compulsory Unionism," California Public Employee Relations, No. 143 (Aug. 2000); "Legislative and Practical Alternatives to the Current Monopoly Bargaining Model That Will Enhance the Viability of Independent Teacher Groups," Government Union Review, Summer 1995, at 1; "From Abood to Tierney: The Protection of Nonunion Employees in an Agency Shop: You've Come a Long Way," 15 Ohio Northern University Law Review 1 (1988). Reported Cases (partial listing): Davenport v. Washington Education Association, 551 U.S. 177 (2007); Otto v. Pennsylvania State Education Ass'n, 330 F.3d 125 (3d Cir. 2003); Damiano v. Matish, 830 F.2d 1363 (6th Cir. 1987); Swanson v. University of Hawaii Professional Assembly, 269 F. Supp. 2d 1252 (D. Hawaii 2003); Leer v. Washington Education Ass'n., 172 F.R.D. 439 (W.D. Wash. 1997); George v. Baltimore City Public Schools, 117 F.R.D. 368 (D. Md. 1987); FEC v. NEA, 457 F. Supp. 1102 (D.D.C. 1978); Elvin v. Oregon Public Employees Union, 832 P.2d 26 (Or. 1992); Albro v. Indianapolis Educ. Ass’n, 585 N.E.2d 666 (Ind.App.), aff’d sum nom., Fort Wayne Educ. Ass’n v. Aldrich, 594 N.E.2d 781 (Ind. 1992); Ball v. City of Detroit, 84 Mich. App. 383, 269 N.W.2d 607 (1978); Marceau v. International Broth. of Elec. Workers, 618 F.Supp.2d 1127 (D. Ariz. 2009); Wilson v. NLRB, 920 F.2d 1282 (6th Cir. 1990).
Richard J. Clair, Corporate Counsel and Staff Attorney (1993-present)
Foundation Staff Attorney, 1979-1993; Tax Law Specialist, Exempt Organizations Division, IRS, Washington, DC, 1977-79. Bar Admissions: Louisiana, 1976; Virginia, 1977; U.S. Supreme Court, 1982 (admitted in only LA & VA). Law School: Loyola University, New Orleans, LA, J.D., 1976. College: Catholic University, B.A., Spanish, 1972. Member: Federalist Society. Publications: "Catholic Social Teaching and the Right to Work," monograph published by the Foundation (http://www.nrtw.org/a/Catholic.pdf). Reported Cases: (partial listing):Machinists Local 2771 v. DynCorp, Aerospace Operations, Sheppard ENJJPT Division, 796 F. Supp. 976 (N.D. Tex. 1991); Davidson v. Cook, 567 F. Supp. 225 (E.D. Va. 1983), aff'd, 734 F.2d 10 (4th Cir. 1984);National Right to Work Legal Defense Foundation v. United States, 487 F. Supp. 801 (E.D.N.C. 1979); Food & Commercial Workers Locals 951, 7 & 1036, 329 N.L.R.B. 730 (1999).
Amanda K. Freeman, Staff Attorney (2013-present)
Judicial Clerk, Honorable Glen A. Huff, Virginia Court of Appeals, August 2011–August 2013; Judicial Clerk, Honorable Robert J. Humphreys, Virginia Court of Appeals, August 2009–July 2011; Intern, Lentz, Stepanovich & Bergethon, PLC, Virginia Beach, VA, May 2008–August 2008, October 2008; Paralegal, Mauck & Baker, LLC, Chicago, IL, Summer 2007 and Feb. 2006–Aug. 2006. Bar Admission: Commonwealth of Virginia, 2009; U.S. Supreme Court, 2013 (admitted only in VA). Law School: Regent University School of Law, J.D., 2009; Study Abroad: International Human Rights, Strasbourg, France, Summer 2007. College: Bob Jones University, B.S. cum laude, 2005. Member: Federalist Society. Publication: Does "Emergency" Trump Conscience Thus Drawing Another Line In the Sand For Pharmacists?, 21 REGENT U. L. REV. 181 (2008).
Matthew B. Gilliam, Staff Attorney (2014-present)
Associate Attorney, Robinson & McElwee, PLLC, 2013-2014; Legal Associate, Cato Institute, Center for Constitutional Studies, 2012-2013; Law Clerk, U.S. Department of Justice, Federal Bureau of Prisons, Office of General Counsel-Legislative and Correctional Issues, 2010-2011; Intern, Bullard Falla Ezcurra, Summer 2009; Territory Manager, Marathon Petroleum, Marketing Division, 2000-2007. Bar Admission: New York, 2012; West Virginia, 2013; U.S. District Court, Southern District of West Virginia, 2013 (admitted only in NY and WV). Law School: Georgetown University Law Center, J.D. 2011. College: Transylvania University, B.A. 1999, magna cum laude. Member: Federalist Society. Spanish-fluent.
Sarah E. Hartsfield, Staff Attorney (2011-present)
Legal Intern, The Singer Legal Group, Virginia Beach, VA, 2010-2011; Intern and Executive Assistant, The Ashcroft Group, L.L.C., Washington, DC, 2010; Legal Intern, Chesapeake Public Defender's Office, Chesapeake, VA, 2009. Bar Admissions: Virginia, 2011, U.S. District Court, Eastern District of Virginia, 2012 (admitted only in VA). Law School: Regent University School of Law, J.D. 2011. College: University of Texas, B.A. 2008. Member: Federalist Society.
Nathan J. McGrath, Staff Attorney (2012-present)
Associate Attorney, Lawlor & Lawlor, P.C. Pittsburgh, PA, 2010-2012; Intern, Honorable Robert J. Humphreys at Virginia Court of Appeals, August 2008-April 2010; Legislative Assistant, U.S. House of Representatives, Representative Donald A. Manzullo, June 2005-July 2007; Director of Communication, National Right to Work Committee, November 2004-June 2005. Bar Admissions: Commonwealth of Pennsylvania, 2010; U.S. District Court, Western District of Pennsylvania, 2010; U.S. Supreme Court, 2014 (admitted only in PA). Law School: Regent University School of Law, J.D., 2010. College: Grove City College, B.A., 2004. Member: Federalist Society; Pennsylvania Bar Association. Publications: Reed v. UAW: An Adverse Ruling on Adverse Action, 23 REGENT U. L. REV. 391 (2011).
William L. Messenger, Staff Attorney (2001-present)
Foundation Law Clerk, 2001, 1999-2000; Law Clerk, National Association of Manufacturers, Washington, DC, 2000-01; Law Clerk, Office of General Counsel, Federal Election Commission, Washington, DC, 2000; Intern, Assistant Majority Leader's Office, U.S. Senate, 1998; Intern, Republican Policy Committee, U.S. Senate, 1997; Intern, Office of U.S. Senator Mike DeWine (R-OH), 1996. Bar Admissions: Virginia, 2001; U.S. Supreme Court, 2009 (admitted only in VA). Law School: George Washington University, J.D., cum laude, 2001. College: Ohio University, B.B.A., 1997. Member: Federalist Society. Publications: "Does the First Amendment Allow States to Compel Recipients of Government Monies to Support State-Designated Representatives?," ENGAGE, Sept. 2010, at 88; "Pre-Recognition Agreements: Can Employers Lawfully Acquire Control Over the Future Representative of their Employees under § 8(a)(2) of the NLRA?," ENGAGE, Oct. 2006, at 131. Reported Cases: Harris v. Quinn, 134 S. Ct. 2618 (2014); Mulhall v. UNITE HERE Local 355, 618 F.3d 1279 (2010), after remand, 667 F.3d 1211 (11th Cir. 2012), cert. dismissed, 134 S. Ct. 594 (2013) (per curiam 6-3 decision) (argued Nov. 13, 2013); Dana Corp., 341 N.L.R.B. No. 150, 2004 WL 1329345 (June 7, 2004).
John N. Raudabaugh, Staff Attorney (2012-present)
Reed Larson Professor of Labor Law, Ave Maria School of Law, 2012-present; Nixon Peabody LLP, 2010-2012; Baker & McKenzie LLP, 2006-2010; Butzel Long, 2004-2006; Matkov Salzman, 1993-2004; Member, U.S. National Labor Relations Board, 1990-1993; Constangy Brooks & Smith, 1989-1990; Powell Goldstein, 1977-1989. Bar Admissions: Georgia, 1977; U.S. Supreme Court, 1982; District of Columbia, 1993; Michigan, 2005 (admitted only in GA, DC, and MI). Law School: University of Virginia, J.D. 1977; Graduate School: New York State School of Labor and Industrial Relations, Cornell University, M.S. Labor Economics and Econometrics, 1974. College: Wharton School of Finance and Commerce, University of Pennsylvania, B.S. Labor Economics, cum laude, 1968. Military Service: Flag Lieutenant, U.S. Navy Supply Corps, 1968-1972. Member: Senior Advisor, Labor and Employment Practice Group, Federalist Society National Lawyers Division; Labor and Employment Relations Association; American Bar Association. Publications and Testimony: "Labored Law: Bilateralism or Pluralism, Ossification or Reformation?," 87 Indiana L.J. 105(2012); "Protecting Private Ballot Rights for American Workers," U.S. Senate Republican Conference, 2008; "NLRB Representation Elections and Initial Collective Bargaining Agreements: Safeguarding Workers' Rights?", U.S. Senate Subcommittee on Labor, Health and Human Services, Education and Related Agencies of the Committee on Appropriations, 2008; "National Labor Relations Board 2007 Year in Review: Fueling Union's Demand for Euro-Centric Labor Law Reform," CCH Labor Law Journal, Spring 2008, pp. 16–25; "Contract Modification and Unilateral Change—Bath Iron Works," ABA Section of Labor and Employment Law, 2006; "Secret Ballot Protection Act of 2004," U.S. House Subcommittee on Employer-Employee Relations of the Committee on Education and the Workforce, 2004; "Foreward," A Guide to Sources of Information on the National Labor Relations Board, 2003; "Employee Voting Rights: Industrial Stability vs. Employee Free Choice," ABA Section of Labor and Employment Law, 2001; "Electromation: An Opportunity Lost or Just Postponed?" Chapter 29, Non-Union Employee Representation, 2000; "Employee Relations Law Reform," Industrial Relations Research Association, 50th Anniversary Volume, Government Regulation of the Employment Relationship, 1997; "One Former Board Member's Recommended Changes to the National Labor Relations Act," IRRA, 1995; "Perspectives on Labor Law Reform," IRRA Spring Proceedings, 1994.
Brandon K. Rowland, Staff Attorney (2012-present)
Koch Associate, Charles Koch Institute, Arlington, VA, 2012-2013; Legislative Correspondent, Office of U.S. Congressman Tim Scott (R-SC), Washington, DC, 2011; Deputy Campaign Manager, Tim Scott for Congress, Charleston, SC, 2010; Associate Attorney, Lowe & Associates, P.C., Charleston, SC, 2008-2009; Owner, Cherokee Vending, LLC, Athens, TN, 2007-2012; Law Clerk, Office of the 10th Judicial District Attorney General, Cleveland, TN, 2003; Intern, Office of U.S. Senator Fred Thompson (R-TN), Chattanooga, TN, 2002. Bar Admissions: South Carolina, 2007; U.S. District Court, District of South Carolina, 2008; United States Court of Appeals for the Armed Forces, 2012; District of Columbia, 2012 (admitted only in SC & DC). Law School: Charleston School of Law, J.D. 2007. College: The Citadel, B.A. 2004. Military Service: Captain, Judge Advocate General's Corps, South Carolina Army National Guard, 2010-Present.
John C. Scully, Staff Attorney (1982-89, 1992-present)
Counsel, Washington Legal Foundation, Washington, DC, 1989-92; Captain, Judge Advocate General's Corps, U.S. Army, 1978-81; Intern, Special Projects Division, Missouri Attorney General's Office, 1977. Bar Admissions: Missouri, 1978; U.S. Supreme Court, 1983 (admitted only in MO). Law School: George Washington University, LL.M., 1987; Missouri University, J.D., 1978. College: George Mason University, M.A., History, 1998; Creighton University, B.A., History, cum laude, 1974. Member: Federalist Society. Publications: "Mandatory Pro Bono: An Attack on the Constitution," 19 Hofstra Law Review 1229 (1991); "Hidden Scheme to Finance Radical Lawyers Plagues Pacific Northwest," Washington Legal Foundation Legal Backgrounder, Mar. 31, 1992; "Washington Legal Foundation Brings Contingency Fee Reform to the State Of Washington," Washington Legal Foundation Legal Backgrounder, Mar. 31, 1992; "Lawyer Associations' Use of Dues and Client Money Is Politicized and Must Be Stopped," Washington Legal Foundation Legal Opinion Letter, Oct. 23, 1992; "Victims of Special Interest Lawyers Fight Back in the Pacific Northwest," Washington Legal Foundation Legal Opinion Letter, Dec. 6, 1991. Reported Cases (partial listing): Lee v. NLRB, 393 F.3d 491 (4th Cir. 2005); NLRB v. Pueblo of San Juan, 276 F.3d 1186 (10th Cir. 2002); Andrews v. Education Ass'n of Cheshire, 829 F.2d 335 (2d Cir. 1987); Paperworkers Local 1033, 320 N.L.R.B. 349 (1995), review denied sub nom. Buzenius v. NLRB, 191 F.3d 641 (6th Cir. 1999); Teamsters Local 1150, 323 N.L.R.B. 1173 (1997); Carpenters Local 943, 322 N.L.R.B. 825 (1997); Elvin v. Oregon Public Employees Union, 793 P.2d 338 (Or. Ct. App. 1990), aff?d, 832 P.2d 26 (Or. 1992); Weissenstein v. Burlington Board of School Commissioners, 543 A.2d 691 (Vt. 1988).
Aaron B. Solem, Staff Attorney (2012-present)
Koch Associate, Charles Koch Institute, Arlington, VA, 2012-2013; Legislative Assistant, Office of U.S. Congressman Geoff Davis (R-KY), Washington DC, 2011-2012; Committee Administrator, Minnesota House of Representatives Education Finance Committee, St. Paul, MN, 2011; Summer Associate, Bryan Cave, Phoenix, 2009. Bar Admissions: Minnesota, 2012 (admitted only in MN). Law School: University of Notre Dame Law School, J.D., cum laude, 2010. College: University of Minnesota, B.A., 2006. Member: Federalist Society.
Glenn M. Taubman, Staff Attorney (1982-present)
Law Clerk, Senior Circuit Judge Warren L. Jones, U.S. Court of Appeals for the Fifth and Eleventh Circuits, Jacksonville, FL, 1981-82; Staff Attorney, U.S. District Court, Middle District of Florida, Jacksonville, FL, 1980-81. Bar Admissions: Georgia, 1980; New York, 1981; U.S. Supreme Court, 1983; District of Columbia, 1985 (admitted only in GA, NY & DC). Law School: Georgetown University, LL.M., 1985; Emory University, J.D., with distinction, 1980. College: State University of New York at Stony Brook, B.A., Political Science & Urban Policy, 1977. Member: Federalist Society. Publications: "'Neutrality Agreements' and the Destruction of Employees' Section 7 Rights," ENGAGE, May 2005, at 101; Co-author, "Union Discipline and Employee Rights," monograph published by the Foundation (http://www.nrtw.org/RDA.htm). Reported Cases (partial listing): Nat'l Ass'n of Mfrs. v. N.L.R.B., 846 F. Supp. 2d 34 (D.D.C. 2012), aff'd in part, rev'd in part, 717 F.3d 947 (D.C. Cir. 2013); Lucas v. NLRB, 333 F.3d 927 (9th Cir. 2003) , on remand, IATSE Local 720, 352 NLRB 29 (2008); Penrod v. NLRB, 203 F.3d 41 (D.C. Cir. 2000); Production Workers v. NLRB, 161 F.3d 1047 (7th Cir. 1998); Food & Commercial Workers Local 951 v. Mulder, 31 F.3d 365 (6th Cir. 1994); NLRB v. Office Employees Local 2, 902 F.2d 1164 (4th Cir. 1990); Tierney v. City of Toledo, 824 F.2d 1497 (6th Cir. 1987), further proceedings, 917 F.2d 927 (1990); Lowary v. Lexington Local Board of Education, 854 F.2d 131 (6th Cir. 1988), further proceedings, 902 F.2d 422 (1990); Masiello v. US Airways, Inc., 113 F. Supp. 2d 870 (W.D.N.C. 2000); Jordan v. City of Bucyrus, 739 F. Supp. 1124 (1990), further proceedings, 754 F. Supp. 554 (N.D. Ohio 1991); Dana Corp., 351 N.L.R.B. 434 (2007); California Saw & Knife Works, 320 N.L.R.B. 224 (1995), enforced, 133 F.3d 1012 (7th Cir. 1998); IAM (L-3 Communications), 355 NLRB 1062 (2010).
W. James Young, Staff Attorney (1989-present)
Associate, Borland & Borland, Wilkes-Barre, PA, 1989; Intern, Criminal Division, U.S. Attorney's Office, Atlanta, GA, U.S. Justice Department, 1988-89; Martindale-Hubbell® AV® Peer Review Rated. Bar Admissions: Pennsylvania, 1989; District of Columbia, 1991; U.S. Supreme Court, 1992 (admitted only in PA & DC). Law School: Emory University, J.D., 1989. College: Hampden-Sydney College, B.A., with Honors in Political Science and History, magna cum laude, 1986. Member: Federalist Society. Publications: "Casting an Overdue Skeptical Eye: Knox v. SEIU," CATO SUPREME COURT REVIEW, September 2012, at 333; "Making Windows into Litigants' Souls: The Pernicious Potential of Gilpin v. AFSCME," Engage, Apr. 2004, at 90; Co-author, "Big Labor's Tyranny of the Minority: Forced Union Dues in Politics," Federalist Society Free Speech & Election Law Newsletter, Fall 1996. Reported Decisions (partial listing): Knox v. SEIU Local 1000, 132 S.Ct. 2277 (2012); Locke v. Karass, 555 U.S. 207 (2009); Cummings v. Connell, 402 F. 3d 935 (9th Cir. 2005); Prescott v. County of El Dorado, 177 F.3d 1102 (9th Cir. 1999), vacated, 528 U.S. 1111, reinstated in part, 204 F.3d 984 (9th Cir. 2000); Knight v. Kenai Peninsula Borough School District, 131 F.3d 807 (9th Cir. 1997); Johnson v. Lafayette Firefighters Ass'n, 51 F.3d 726 (7th Cir. 1995); Weaver v. University of Cincinnati, 942 F.2d 1039 (1991), further proceedings, 970 F.2d 1523 (6th Cir. 1992); Dixon v. City of Chicago, 948 F.2d 355 (7th Cir. 1991); Orr v. National Football League Players Ass'n, 147 L.R.R.M. (BNA) 2845 (Va. Cir. Ct. 1994), aff?d, 150 L.R.R.M. (BNA) 2191 (Va. 1995).