diff --git "a/question_data.json" "b/question_data.json"
--- "a/question_data.json"
+++ "b/question_data.json"
@@ -74,7 +74,7 @@
 		],
 		"generation_e5":"The relevant legal principles for determining whether the \"Employee's Report of Accident\" filled out by Handy is admissible revolve around the rules of hearsay and its exceptions, particularly the business records exception.\n\nPassage 4 notes an exception to the hearsay rule allowing certain statements made by employees at the time of an incident to be admissible. Specifically, the business records exception, under Federal Rule of Evidence 803(6), permits the admission of records kept in the regular course of a business activity if they are made at or near the time of the incident by someone with knowledge, as seen in the motion concerning Sheriff Roger Scott\u2019s affidavit (based on personal knowledge and supported by admissible business records). This indicates that Handy's accident report could be considered under this rule, given that it followed regular practice at Mart Department Store and was contemporaneously created.\n\nPassage 12 reinforces that reports made outside of court and introduced for the truth asserted in them are generally inadmissible as hearsay unless they meet an exception, such as the business records exception.\n\nTaken together, these passages suggest that Handy's report might be admissible if it meets the stringent criteria of the business records exception \u2014 it must be created as part of regular business practices and at or near the time of the incident by someone with relevant knowledge. If these conditions are met, Handy\u2019s availability as a witness does not preclude the document\u2019s admissibility under this exception.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"Hearsay is an out of court, unsworn, oral or written statement by a third person, which is offered for the truth of its content. Hearsay statements are inadmissible unless they fit into one of the recognized exceptions.\u201a\u00c4\u00f9 **6 State v. Gremillion, 542 So.2d 1074, 1077 (La.1989) (citation omitted). One such exception to the hearsay exclusionary rule applies to unavailable witnesses: A. Definition of unavailability. Except as otherwise provided by this Code, a declarant is \u201a\u00c4\u00faunavailable as a witness\u201a\u00c4\u00f9 when the declarant cannot or will not appear in court and testify to the substance of his statement made outside of court. This includes situations in which the declarant: .... (2) Persists in refusing to testify concerning the subject matter of his statement despite an order of the court to do so; .... B. Hearsay exceptions. The following are not excluded by the hearsay rule if the declarant is unavailable as a witness: .... (3) Statement against interest. A statement which was at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject him to civil or criminal liability, or to render invalid a claim by him against another, that a reasonable man in his position would not have made the statement unless he believed it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement. La.Code Evid. art. 804.",
+		"gold_passage":"Hearsay is an out of court, unsworn, oral or written statement by a third person, which is offered for the truth of its content. Hearsay statements are inadmissible unless they fit into one of the recognized exceptions.\" **6 State v. Gremillion, 542 So.2d 1074, 1077 (La.1989) (citation omitted). One such exception to the hearsay exclusionary rule applies to unavailable witnesses: A. Definition of unavailability. Except as otherwise provided by this Code, a declarant is \"unavailable as a witness\" when the declarant cannot or will not appear in court and testify to the substance of his statement made outside of court. This includes situations in which the declarant: .... (2) Persists in refusing to testify concerning the subject matter of his statement despite an order of the court to do so; .... B. Hearsay exceptions. The following are not excluded by the hearsay rule if the declarant is unavailable as a witness: .... (3) Statement against interest. A statement which was at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject him to civil or criminal liability, or to render invalid a claim by him against another, that a reasonable man in his position would not have made the statement unless he believed it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement. La.Code Evid. art. 804.",
 		"gold_passage_generation":"The passage outlines hearsay as an out-of-court statement offered to prove the truth of the matter asserted and notes it is generally inadmissible unless an exception applies. One exception is if the declarant is unavailable to testify, defined broadly to include those who refuse to testify even when ordered by the court. For such unavailable declarants, specific hearsay exceptions apply, such as statements against interest\u2014those statements that would not have been made unless the declarant believed them true because they were against their own interest. However, given Handy is available to testify, this exception does not apply, maintaining the report as inadmissible hearsay."
 	},
 	"mbe_287":{
@@ -100,7 +100,7 @@
 		],
 		"generation_colbert":"1. **Option Cost and Consideration**: Passage [\u00b625] highlights the principle that the cost of an option (here, Reggie\u2019s promise to pay $200) is viewed as separate from other contract considerations and is valid to secure an option agreement. Although forfeiture of such cost is acceptable if the option is terminated, it indicates that Reggie's promise to pay could constitute valid consideration for Harriet\u2019s offer.\n\n2. **Basic Contract Principles**: The last passage on Schinzel and Dinkins reaffirms that a valid contract requires an offer, acceptance, meeting of the minds, and consideration. The passage suggests that Reggie\u2019s arrangement to pay $200 for securing the offer, even if revocable, could be seen as fulfilling these contract elements.\n\n3. **Earnest Money and Specific Performance**: Passage [\u00b612] from the Davidson buy-sell agreement shows that earnest money typically serves as consideration, supporting the argument that Reggie's promise to pay $200 for Harriet\u2019s revocable offer serves as valid consideration, securing Harriet's commitment even if revocable.\n\n4. **Parol Evidence Rule and Consideration**: The reference to parol evidence (in passage [\u00b636]) generally supports using external evidence to prove underlying consideration that is not expressed in the written agreement, suggesting that Reggie could use parol evidence to establish his promise to pay $200 as consideration.\n\nTogether, these principles suggest that contractual elements like consideration, enforceability of option agreements, and the use of parol evidence might legitimately support Harriet\u2019s position in the lawsuit.",
 		"top10_e5":[
-			"Had defendant's bid expressly stated or clearly implied that it was revocable at any time before acceptance we would treat it accordingly. It was silent on revocation, however, and we must therefore determine whether there are conditions to the right of revocation imposed by law or reasonably inferable in fact. In the analogous problem of an offer for a unilateral contract, the theory is now obsolete that the offer is revocable at any time before complete performance. Thus section 45 of the Restatement of Contracts provides: \u201a\u00c4\u00f2If an offer for a unilateral contract is made, and part of the consideration requested in the offer is given or tendered by the offeree in response thereto, the offeror is bound by a contract, the duty of immediate performance of which is conditional on the full consideration being given or tendered within the time stated in the offer, or, if no time is stated therein, within a reasonable time.\u201a\u00c4\u00f4 In explanation, comment b states that the \u201a\u00c4\u00f2main offer includes as a subsidiary promise, necessarily implied, that if part of the requested performance is given, the offeror will not revoke his offer, and that if tender is made it will be accepted. Part performance or tender may thus furnish consideration for the subsidiary promise. Moreover, merely acting in justifiable reliance on an offer may in some cases serve as sufficient reason for making a promise binding (see s 90).\u201a\u00c4\u00f4 Whether implied in fact or law, the subsidiary promise serves to preclude the injustice that would result if the offer could be revoked after the offeree had acted in detrimental reliance thereon. Reasonable reliance resulting in a foreseeable prejudicial change in position affords a compelling basis also for implying a subsidiary promise not to revoke an offer for a bilateral contract. The absence of consideration is not fatal to the enforcement of such a promise. It is true that in the case of unilateral contracts the Restatement finds consideration for the implied subsidiary promise in the part performance of the bargained-for exchange, but its reference to section 90 makes clear that consideration for such a promise is not always necessary. The very purpose of section 90 is to make a promise binding even though there was no consideration \u201a\u00c4\u00f2in the sense of something that is bargained for and given in exchange.\u201a\u00c4\u00f4 (See 1 Corbin, Contracts 634 et seq.) Reasonable reliance serves to hold the offeror in lieu of the consideration ordinarily required to make the offer binding. In a case involving similar facts the Supreme Court of South Dakota stated that \u201a\u00c4\u00f2we believe that reason and justice demand that the doctrine (of section 90) be applied to the present facts. We cannot believe that by accepting this doctrine as controlling in the state of facts before us we will abolish the requirement of a consideration in contract *415 cases, in any different sense than an ordinary estoppel abolishes some legal requirement in its application. We are of the opinion, therefore, that the defendants in executing the agreement (which was not supported by consideration) made a promise which they should have reasonably expected would induce the plaintiff to submit a bid based thereon to the Government, that such promise did induce this action, and that injustice can be avoided only by enforcement of the promise.\u201a\u00c4\u00f4 Northwestern Engineering Co. v. Ellerman, 69 S.D. 397, 408, 10 N.W.2d 879, 884; see also, Robert Gordon, Inc., v. Ingersoll-Rand Co., 7 Cir., 117 F.2d 654, 661; cf. James Baird Co. v. Gimbel Bros., 2 Cir., 64 F.2d 344. When plaintiff used defendant's offer in computing his own bid, he bound himself to perform in reliance on defendant's terms. Though defendant did not bargain for this use of its bid neither did defendant make it idly, indifferent to whether it would be used or not. On the contrary it is reasonable to suppose that defendant submitted its bid to obtain the subcontract. It was bound to realize the substantial possibility that its bid would be the lowest, and that it would be included by plaintiff in his bid. It was to its own interest that the contractor be awarded the general contract; the lower the subcontract bid, the lower the general contractor's bid was likely to be and the greater its cnance of acceptance and hence the greater defendant's chance of getting the paving subcontract. Defendant had reason not only to expect plaintiff to rely on its bid but to want him to. Clearly defendant had a stake in plaintiff's reliance on its bid. Given this interest and the fact that plaintiff is bound by his own bid, it is only fair that plaintiff should have at least an opportunity to accept defendant's bid after the general contract has been awarded to him.",
+			"Had defendant's bid expressly stated or clearly implied that it was revocable at any time before acceptance we would treat it accordingly. It was silent on revocation, however, and we must therefore determine whether there are conditions to the right of revocation imposed by law or reasonably inferable in fact. In the analogous problem of an offer for a unilateral contract, the theory is now obsolete that the offer is revocable at any time before complete performance. Thus section 45 of the Restatement of Contracts provides: 'If an offer for a unilateral contract is made, and part of the consideration requested in the offer is given or tendered by the offeree in response thereto, the offeror is bound by a contract, the duty of immediate performance of which is conditional on the full consideration being given or tendered within the time stated in the offer, or, if no time is stated therein, within a reasonable time.' In explanation, comment b states that the \"main offer includes as a subsidiary promise, necessarily implied, that if part of the requested performance is given, the offeror will not revoke his offer, and that if tender is made it will be accepted. Part performance or tender may thus furnish consideration for the subsidiary promise. Moreover, merely acting in justifiable reliance on an offer may in some cases serve as sufficient reason for making a promise binding (see s 90).' Whether implied in fact or law, the subsidiary promise serves to preclude the injustice that would result if the offer could be revoked after the offeree had acted in detrimental reliance thereon. Reasonable reliance resulting in a foreseeable prejudicial change in position affords a compelling basis also for implying a subsidiary promise not to revoke an offer for a bilateral contract. The absence of consideration is not fatal to the enforcement of such a promise. It is true that in the case of unilateral contracts the Restatement finds consideration for the implied subsidiary promise in the part performance of the bargained-for exchange, but its reference to section 90 makes clear that consideration for such a promise is not always necessary. The very purpose of section 90 is to make a promise binding even though there was no consideration \"in the sense of something that is bargained for and given in exchange.' (See 1 Corbin, Contracts 634 et seq.) Reasonable reliance serves to hold the offeror in lieu of the consideration ordinarily required to make the offer binding. In a case involving similar facts the Supreme Court of South Dakota stated that \"we believe that reason and justice demand that the doctrine (of section 90) be applied to the present facts. We cannot believe that by accepting this doctrine as controlling in the state of facts before us we will abolish the requirement of a consideration in contract *415 cases, in any different sense than an ordinary estoppel abolishes some legal requirement in its application. We are of the opinion, therefore, that the defendants in executing the agreement (which was not supported by consideration) made a promise which they should have reasonably expected would induce the plaintiff to submit a bid based thereon to the Government, that such promise did induce this action, and that injustice can be avoided only by enforcement of the promise.' Northwestern Engineering Co. v. Ellerman, 69 S.D. 397, 408, 10 N.W.2d 879, 884; see also, Robert Gordon, Inc., v. Ingersoll-Rand Co., 7 Cir., 117 F.2d 654, 661; cf. James Baird Co. v. Gimbel Bros., 2 Cir., 64 F.2d 344. When plaintiff used defendant's offer in computing his own bid, he bound himself to perform in reliance on defendant's terms. Though defendant did not bargain for this use of its bid neither did defendant make it idly, indifferent to whether it would be used or not. On the contrary it is reasonable to suppose that defendant submitted its bid to obtain the subcontract. It was bound to realize the substantial possibility that its bid would be the lowest, and that it would be included by plaintiff in his bid. It was to its own interest that the contractor be awarded the general contract; the lower the subcontract bid, the lower the general contractor's bid was likely to be and the greater its cnance of acceptance and hence the greater defendant's chance of getting the paving subcontract. Defendant had reason not only to expect plaintiff to rely on its bid but to want him to. Clearly defendant had a stake in plaintiff's reliance on its bid. Given this interest and the fact that plaintiff is bound by his own bid, it is only fair that plaintiff should have at least an opportunity to accept defendant's bid after the general contract has been awarded to him.",
 			"Missouri law governs this case. See Baker v. Bristol Care, Inc. , 450 S.W.3d 770, 774 (Mo. 2014) (en banc). Missouri law requires (1) an offer, (2) acceptance, and (3) consideration to form a valid and enforceable contract. Id . An offer is made when the offeree-the person receiving the offer-would \"reasonably believe that an offer has been made.\" Jackson , 497 S.W.3d at 288 (internal quotation omitted). A valid offer does not require the use of any specific terms of art. See id . The use of typical contractual terms can be helpful to discern intent. Id . at 289. A valid offer will include the ability to accept through some affirmative words or action. See id . at 290. An acceptance is present when the offeree signifies assent to the terms of the offer in a \"positive and unambiguous\" manner. Katz v. Anheuser-Busch, Inc. , 347 S.W.3d 533, 545 (Mo. Ct. App. 2011) (quoting Kunzie v. Jack-In-The-Box, Inc. , 330 S.W.3d 476, 484 (Mo. Ct. App. 2010) ). Together, offer and acceptance constitute mutual assent. See Guidry v. Charter Commc'ns, Inc. , 269 S.W.3d 520, 528 (Mo. Ct. App. 2008). Third, an agreement must have an exchange of consideration: a promise to do something or refrain from doing something, or the transfer of something of value to the other party. Baker , 450 S.W.3d at 774.",
 			"\u00ac\u00df 2A-205. FIRM OFFERS. An offer by a merchant to lease goodsto or from another person in a signed writing that by its terms gives assurance it will be held open is not revocable, for lack of consideration, during the time stated or, if no time is stated, for a reasonable time, but in no event may the period of irrevocability exceed 3 months. Any such term of assurance on a form supplied by the offeree must be separately signed by the offeror.",
 			"\u00ac\u00df 2-205. Firm Offers. An offer by a merchant to buy or sell goods in a signed writing which by its terms gives assurance that it will be held open is not revocable, for lack of consideration, during the time stated or if no time is stated for a reasonable time, but in no event may such period of irrevocability exceed three months; but any such term of assurance on a form supplied by the offeree must be separately signed by the offeror.",
@@ -140,7 +140,7 @@
 		"generation_colbert":"The relevant principles for answering the legal question derive from understanding which federal officers fall under the protection of Article III, which guarantees life tenure and protection from salary diminution for judges. Article III judges are appointed for life, have protections against removal unless for cause, and receive undiminished compensation during their tenure in office. Passage 4 specifies that Article I judges, such as civilian judges on the Court of Military Commission Review (CMCR) and administrative positions, do not benefit from these same constitutional protections as Article III judges. These judges can be removed for cause and do not have the same salary protection. Additionally, the historical context provided by court precedents (e.g., Morrison v. Olson) helps differentiate between principal and inferior officers but still underscores the lack of Article III protections for positions not explicitly created under Article III. Passages 8 and 9 indicate that review of administrative actions, or actions by military boards, can be conducted under the Administrative Procedure Act (APA), but this review doesn't alter the classification of the officer under Article III. Lastly, no passages suggest that roles like Hobson's within a tribunal, established under a congressional act, enjoy the specific constitutional protections reserved for Article III judges.",
 		"top10_e5":[
 			"Article I Section 6. The Senators and Representatives shall receive a compensation for their services, to be ascertained by law, and paid out of the treasury of the United States. They shall in all cases, except treason, felony and breach of the peace, be privileged from arrest during their attendance at the session of their respective Houses, and in going to and returning from the same; and for any speech or debate in either House, they shall not be questioned in any other place. No Senator or Representative shall, during the time for which he was elected, be appointed to any civil office under the authority of the United States, which shall have been created, or the emoluments whereof shall have been increased during such time: and no person holding any office under the United States, shall be a member of either House during his continuance in office.",
-			"The Appointments Clause of Article II of the Constitution reads as follows: \u201a\u00c4\u00fa[The President] shall nominate, and by and with the Advice and Consent of the Senate, shall appoint Ambassadors, other public Ministers and Consuls, Judges of the supreme Court, and all other Officers of the United States, whose Appointments are not herein otherwise provided for, and which shall be established by Law: but the Congress may by Law vest the Appointment of such inferior Officers, as they think proper, in the President alone, in the Courts of Law, or in the Heads of Departments.\u201a\u00c4\u00f9 U.S. Const., Art. II, \u00ac\u00df 2, cl. 2. 5678As we recognized in Buckley v. Valeo, 424 U.S. 1, 125, 96 S.Ct. 612, 685, 46 L.Ed.2d 659 (1976) (per curiam), the Appointments Clause of Article II is more than a matter of \u201a\u00c4\u00faetiquette or protocol\u201a\u00c4\u00f9; it is among the significant structural safeguards of the constitutional scheme. By vesting the President with the exclusive power to select the principal (noninferior) officers of the United States, the Appointments Clause prevents congressional encroachment upon the Executive and Judicial Branches. See id., at 128\u201a\u00c4\u00ec131, 96 S.Ct., at 686\u201a\u00c4\u00ec688; Weiss, supra, at 183\u201a\u00c4\u00ec185, 114 S.Ct., at 763\u201a\u00c4\u00ec765 (SOUTER, J., concurring); Freytag v. Commissioner, 501 U.S. 868, 904, and n. 4, 111 S.Ct. 2631, 2652, and n. 4, 115 L.Ed.2d 764 (1991) (SCALIA, J., concurring). This disposition was also designed to assure a higher quality of appointments: The Framers anticipated that the President would be less vulnerable to interest-group pressure and personal favoritism than would a collective body. \u201a\u00c4\u00faThe sole and undivided responsibility of one man will naturally beget a livelier sense of duty, and a more exact regard to reputation.\u201a\u00c4\u00f9 The Federalist No. 76, p. 387 (M. Beloff ed. 1987) (A. Hamilton); accord, 3 J. Story, Commentaries on the Constitution of the United States 374\u201a\u00c4\u00ec375 (1833). The President's power to select principal officers of the United States was not left unguarded, however, as Article II further requires the \u201a\u00c4\u00faAdvice and Consent of the Senate.\u201a\u00c4\u00f9 This serves both to curb Executive abuses of the appointment power, see 3 Story, supra, at 376\u201a\u00c4\u00ec377, and \u201a\u00c4\u00fato promote a judicious choice of [persons] for filling the offices of the union,\u201a\u00c4\u00f9 The Federalist No. 76, at 386\u201a\u00c4\u00ec387. *660 By requiring the joint participation of the President and the Senate, the Appointments Clause was designed to ensure public accountability for both the making of a bad appointment and the rejection of a good one. Hamilton observed: \u201a\u00c4\u00faThe blame of a bad nomination would fall upon the president singly and absolutely. The censure of rejecting a good one would lie entirely at the door of the senate; aggravated by the consideration of their having counteracted the good intentions of the executive. If an ill appointment should be made, the executive for nominating, and the senate for approving, would participate, though in different degrees, in the opprobrium and disgrace.\u201a\u00c4\u00f9 Id., No. 77, at 392. See also 3 Story, supra, at 375 (\u201a\u00c4\u00faIf [the President] should ... surrender the public patronage into the hands of profligate men, or low adventurers, it will be impossible for him long to retain public favour\u201a\u00c4\u00f9). The prescribed manner of appointment for principal officers is also the default manner of appointment for inferior officers. \u201a\u00c4\u00fa[B]ut,\u201a\u00c4\u00f9 the Appointments Clause continues, \u201a\u00c4\u00fathe Congress may by Law vest the Appointment of such inferior Officers, as they think proper, in the President alone, in the Courts of Law, or in the Heads of Departments.\u201a\u00c4\u00f9 This provision, sometimes referred to as the \u201a\u00c4\u00faExcepting Clause,\u201a\u00c4\u00f9 was added to the proposed Constitution on the last day of the Grand Convention, with little discussion. See 2 M. Farrand, Records of the Federal Convention of 1787, pp. 627\u201a\u00c4\u00ec628 (1911 ed.). As one of our early opinions suggests, its obvious purpose is administrative convenience, see United States v. Germaine, 99 U.S. 508, 510, 25 L.Ed. 482 (1879)\u201a\u00c4\u00eebut that convenience was deemed to outweigh the benefits of the more cumbersome procedure only with respect to the appointment of \u201a\u00c4\u00fainferior Officers.\u201a\u00c4\u00f9 Section 323(a), which confers appointment power upon the Secretary of Transportation, can constitutionally be *661 applied to the appointment of Court of Criminal Appeals judges only if those judges are \u201a\u00c4\u00fainferior Officers.\u201a\u00c4\u00f9 Our cases have not set forth an exclusive criterion for distinguishing between principal and inferior officers for Appointments Clause purposes. Among the offices that we have found to be inferior are that of a district court clerk, Ex parte Hennen, 38 U.S. (13 Pet.) 225, 229, 10 L.Ed. 136 (1839), an election supervisor, Ex parte Siebold, 100 U.S. 371, 397\u201a\u00c4\u00ec398, 25 L.Ed. 717 (1880), a vice consul charged temporarily with the duties of the consul, United States v. Eaton, 169 U.S. 331, 343, 18 S.Ct. 374, 379, 42 L.Ed. 767 (1898), and a \u201a\u00c4\u00faUnited States commissioner\u201a\u00c4\u00f9 in district court proceedings, Go\u201a\u00c4\u00ecBart Importing Co. v. United States, 282 U.S. 344, 352\u201a\u00c4\u00ec354, 51 S.Ct. 153, 156\u201a\u00c4\u00ec157, 75 L.Ed. 374 (1931). Most recently, in Morrison v. Olson, 487 U.S. 654, 108 S.Ct. 2597, 101 L.Ed.2d 569 (1988), we held that the independent counsel created by provisions of the Ethics in Government Act of 1978, 28 U.S.C. \u00ac\u00df\u00ac\u00df 591\u201a\u00c4\u00ec599, was an inferior officer. In reaching that conclusion, we relied on several factors: that the independent counsel was subject to removal by a higher officer (the Attorney General), that she performed only limited duties, that her jurisdiction was narrow, and that her tenure was limited. 487 U.S., at 671\u201a\u00c4\u00ec672, 108 S.Ct., at 2608\u201a\u00c4\u00ec2609.",
+			"The Appointments Clause of Article II of the Constitution reads as follows: \"[The President] shall nominate, and by and with the Advice and Consent of the Senate, shall appoint Ambassadors, other public Ministers and Consuls, Judges of the supreme Court, and all other Officers of the United States, whose Appointments are not herein otherwise provided for, and which shall be established by Law: but the Congress may by Law vest the Appointment of such inferior Officers, as they think proper, in the President alone, in the Courts of Law, or in the Heads of Departments.\" U.S. Const., Art. II, \u00ac\u00df 2, cl. 2. 5678As we recognized in Buckley v. Valeo, 424 U.S. 1, 125, 96 S.Ct. 612, 685, 46 L.Ed.2d 659 (1976) (per curiam), the Appointments Clause of Article II is more than a matter of \"etiquette or protocol\"; it is among the significant structural safeguards of the constitutional scheme. By vesting the President with the exclusive power to select the principal (noninferior) officers of the United States, the Appointments Clause prevents congressional encroachment upon the Executive and Judicial Branches. See id., at 128\u201a\u00c4\u00ec131, 96 S.Ct., at 686\u201a\u00c4\u00ec688; Weiss, supra, at 183\u201a\u00c4\u00ec185, 114 S.Ct., at 763\u201a\u00c4\u00ec765 (SOUTER, J., concurring); Freytag v. Commissioner, 501 U.S. 868, 904, and n. 4, 111 S.Ct. 2631, 2652, and n. 4, 115 L.Ed.2d 764 (1991) (SCALIA, J., concurring). This disposition was also designed to assure a higher quality of appointments: The Framers anticipated that the President would be less vulnerable to interest-group pressure and personal favoritism than would a collective body. \"The sole and undivided responsibility of one man will naturally beget a livelier sense of duty, and a more exact regard to reputation.\" The Federalist No. 76, p. 387 (M. Beloff ed. 1987) (A. Hamilton); accord, 3 J. Story, Commentaries on the Constitution of the United States 374\u201a\u00c4\u00ec375 (1833). The President's power to select principal officers of the United States was not left unguarded, however, as Article II further requires the \"Advice and Consent of the Senate.\" This serves both to curb Executive abuses of the appointment power, see 3 Story, supra, at 376\u201a\u00c4\u00ec377, and \"to promote a judicious choice of [persons] for filling the offices of the union,\" The Federalist No. 76, at 386\u201a\u00c4\u00ec387. *660 By requiring the joint participation of the President and the Senate, the Appointments Clause was designed to ensure public accountability for both the making of a bad appointment and the rejection of a good one. Hamilton observed: \"The blame of a bad nomination would fall upon the president singly and absolutely. The censure of rejecting a good one would lie entirely at the door of the senate; aggravated by the consideration of their having counteracted the good intentions of the executive. If an ill appointment should be made, the executive for nominating, and the senate for approving, would participate, though in different degrees, in the opprobrium and disgrace.\" Id., No. 77, at 392. See also 3 Story, supra, at 375 (\"If [the President] should ... surrender the public patronage into the hands of profligate men, or low adventurers, it will be impossible for him long to retain public favour\"). The prescribed manner of appointment for principal officers is also the default manner of appointment for inferior officers. \"[B]ut,\" the Appointments Clause continues, \"the Congress may by Law vest the Appointment of such inferior Officers, as they think proper, in the President alone, in the Courts of Law, or in the Heads of Departments.\" This provision, sometimes referred to as the \"Excepting Clause,\" was added to the proposed Constitution on the last day of the Grand Convention, with little discussion. See 2 M. Farrand, Records of the Federal Convention of 1787, pp. 627\u201a\u00c4\u00ec628 (1911 ed.). As one of our early opinions suggests, its obvious purpose is administrative convenience, see United States v. Germaine, 99 U.S. 508, 510, 25 L.Ed. 482 (1879)—but that convenience was deemed to outweigh the benefits of the more cumbersome procedure only with respect to the appointment of \"inferior Officers.\" Section 323(a), which confers appointment power upon the Secretary of Transportation, can constitutionally be *661 applied to the appointment of Court of Criminal Appeals judges only if those judges are \"inferior Officers.\" Our cases have not set forth an exclusive criterion for distinguishing between principal and inferior officers for Appointments Clause purposes. Among the offices that we have found to be inferior are that of a district court clerk, Ex parte Hennen, 38 U.S. (13 Pet.) 225, 229, 10 L.Ed. 136 (1839), an election supervisor, Ex parte Siebold, 100 U.S. 371, 397\u201a\u00c4\u00ec398, 25 L.Ed. 717 (1880), a vice consul charged temporarily with the duties of the consul, United States v. Eaton, 169 U.S. 331, 343, 18 S.Ct. 374, 379, 42 L.Ed. 767 (1898), and a \"United States commissioner\" in district court proceedings, Go\u201a\u00c4\u00ecBart Importing Co. v. United States, 282 U.S. 344, 352\u201a\u00c4\u00ec354, 51 S.Ct. 153, 156\u201a\u00c4\u00ec157, 75 L.Ed. 374 (1931). Most recently, in Morrison v. Olson, 487 U.S. 654, 108 S.Ct. 2597, 101 L.Ed.2d 569 (1988), we held that the independent counsel created by provisions of the Ethics in Government Act of 1978, 28 U.S.C. \u00ac\u00df\u00ac\u00df 591\u201a\u00c4\u00ec599, was an inferior officer. In reaching that conclusion, we relied on several factors: that the independent counsel was subject to removal by a higher officer (the Attorney General), that she performed only limited duties, that her jurisdiction was narrow, and that her tenure was limited. 487 U.S., at 671\u201a\u00c4\u00ec672, 108 S.Ct., at 2608\u201a\u00c4\u00ec2609.",
 			"The majority relies for its contrary vision on Article II's Vesting Clause, see ante, at 2197, 2204 - 2205, but the provision can't carry all that weight. Or as Chief Justice Rehnquist wrote of a similar claim in Morrison v. Olson , 487 U.S. 654, 108 S.Ct. 2597, 101 L.Ed.2d 569 (1988), \"extrapolat[ing]\" an unrestricted removal power from such \"general constitutional language\"-which says only that \"[t]he executive Power shall be vested in a President\"-is \"more than the text will bear.\" Id., at 690, n. 29, 108 S.Ct. 2597. Dean John Manning has well explained why, even were it not obvious from the Clause's \"open-ended language.\" Separation of Powers as Ordinary Interpretation, 124 Harv. L. Rev. 1939, 1971 (2011). The Necessary and Proper Clause, he writes, makes it impossible to \"establish a constitutional violation simply by showing that Congress has constrained the way '[t]he executive Power' is implemented\"; that is exactly what the Clause gives Congress the power to do. Id., at 1967. Only \"a specific historical understanding\" can bar Congress from enacting a given constraint. Id., at 2024. And nothing of that sort broadly prevents Congress from limiting the President's removal power. I'll turn soon to the Decision of 1789 and other evidence of Post-Convention thought. See infra , at 2228 - 2231. For now, note two points about practice before the Constitution's drafting. First, in that era, Parliament often restricted the King's power to remove royal officers-and the President, needless to say, wasn't supposed to be a king. See Birk, Interrogating the Historical Basis for a Unitary Executive, 73 Stan. L. Rev. (forthcoming 2021). Second, many States at the time allowed limits on gubernatorial removal power even though their constitutions had similar vesting clauses. See Shane, The Originalist Myth of the Unitary Executive, 19 U. Pa. J. Const. L. 323, 334-344 (2016). Historical understandings thus belie the majority's \"general rule.\"",
 			"Article III Section 1. The judicial power of the United States, shall be vested in one Supreme Court, and in such inferior courts as the Congress may from time to time ordain and establish. The judges, both of the supreme and inferior courts, shall hold their offices during good behaviour, and shall, at stated times, receive for their services, a compensation, which shall not be diminished during their continuance in office.",
 			"Because the elimination of the solicited-fax rule applies to Safemark, we need not decide whether the district court violated the Hobbs Act when it refused to apply that rule. But I write separately to explain that our precedents have misconstrued the Act's grant of \"exclusive jurisdiction\" to the circuit courts \"to enjoin, set aside, suspend (in whole or in part), or to determine the validity of\" certain agency orders, 28 U.S.C. \u00ac\u00df 2342. Our precedents, Self v. Bellsouth Mobility, Inc. , 700 F.3d 453 (11th Cir. 2012), and Mais v. Gulf Coast Collection Bureau , 768 F.3d 1110 (11th Cir. 2014), interpret the Act to mean that an agency's interpretation of federal law in a final order is subject to only a single 60-day window for judicial review in a single circuit-court proceeding, outside of which no party to any proceeding in any court may question the agency's interpretation, no matter how wrong. Four justices of the Supreme Court have recently explained-with good reason and without any justice voicing a contrary interpretation-that the Act means no such thing and might well be unconstitutional if it did. See PDR Network, LLC v. Carlton & Harris Chiropractic, Inc. , --- U.S. ----, 139 S. Ct. 2051, 2057, 2062-66, --- L.Ed.2d ---- (2019) (Kavanaugh, J., concurring in the judgment); see also id. at 2056-57 (Thomas, J., concurring in the judgment). The Hobbs Act, correctly construed, does not require district courts adjudicating cases within their ordinary jurisdiction to treat agency orders that interpret federal statutes as binding precedent. Our precedents' interpretation of the Hobbs Act ignores the statutory context, generates absurd results, and raises serious constitutional doubts. In the earliest appropriate case, we should correct our mistake en banc.",
@@ -152,7 +152,7 @@
 		],
 		"generation_e5":"The principle legal concepts referenced in the provided passages center mainly around the distinction between Article III judges and other types of federal officers appointed under Articles I and II of the Constitution. Article III Section 1 establishes that judges of the supreme and inferior courts hold their offices during good behavior, and their compensation cannot be diminished during their time in office. This protection, however, extends specifically to judges defined under Article III, who have life tenure and salary protection. Article II outlines the Appointments Clause, distinguishing between principal officers, appointed by the President with Senate consent, and inferior officers, which Congress can give the appointment power to various entities. This clause ensures executive accountability and administrative convenience.\n\nCongress has power under Article I Section 8 to constitute tribunals inferior to the Supreme Court, which indicates it can create and reorganize non-Article III tribunals without breaching constitutional protections afforded to Article III judges. The passage also touches on historical interpretations and judiciary's essential attributes, reinforcing separation of powers principles and contextualizing constraints on Congress's authority regarding executive appointments. \n\nThis collective information is pertinent to assessing whether Hobson's role falls under Article III protections or if his employment is subject to the administrative reorganizations and compensatory limitations applicable to non-Article III positions.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"Article III states that these judges \u201a\u00c4\u00fahold their office during good behavior,\u201a\u00c4\u00f9 which means they have a lifetime appointment, except under very limited circumstances. Article III judges can be removed from office only through impeachment by the House of Representatives and conviction by the Senate.",
+		"gold_passage":"Article III states that these judges \"hold their office during good behavior,\" which means they have a lifetime appointment, except under very limited circumstances. Article III judges can be removed from office only through impeachment by the House of Representatives and conviction by the Senate.",
 		"gold_passage_generation":"The passage clarifies that judges appointed under Article III of the Constitution have lifetime appointments, provided they exhibit good behavior, and can only be removed through the specific process of impeachment by the House of Representatives followed by conviction by the Senate. This ensures their independence once appointed. However, these protections apply exclusively to Article III judges. Therefore, the passage suggests that if Hobson was not an Article III judge, the protections of lifetime tenure and fixed compensation do not apply to him, which is a critical point in resolving the legal question presented."
 	},
 	"mbe_334":{
@@ -179,7 +179,7 @@
 		"generation_colbert":"The passages most relevant to assessing the constitutionality of the act in question primarily address the limitations on congressional authority regarding federal court procedures and the interpretation of the Equal Protection Clause of the Fourteenth Amendment.\n\n1. **Equal Protection Clause and Federal Courts**: It is established that Congress cannot engage in activities that promote segregation, as indicated under the Equal Protection provisions of the Due Process Clause of the Fifth Amendment. The Constitution generally aims to prevent government action that violates equal protection, highlighting the critical role of constitutional protections against segregative actions.\n\n2. **Court Authority**: Courts have a primary responsibility to define the requirements of the Equal Protection Clause, suggesting that Congress may not have the authority to limit judicial actions that ensure constitutional rights, including ordering desegregation plans that might involve student transportation to achieve equal protection.\n\n3. **Congressional Intent and Preemption**: When analyzing conflicts between federal actions and congressional purposes, courts reference congressional intent. If an act of Congress obstructs the implementation of constitutional principles, such as equal protection in public schools, it can be seen as improperly limiting judicial authority, thus raising constitutional concerns regarding preemption and legislative overreach into judicial functions.\n\nIn summary, the strongest argument against the constitutionality of the act is likely rooted in the principle that the courts have the primary responsibility to define the minimum requirements of the Equal Protection Clause of the Fourteenth Amendment, which aligns with the separation of powers and prevents Congress from unduly limiting judicial authority in desegregation matters.",
 		"top10_e5":[
 			"An equal-protection claim merits strict scrutiny, our most exacting inquiry, only if the state-crafted classification disadvantages a suspect class or \"impermissibly interferes\" with a fundamental right. Segovia v. United States , 880 F.3d 384, 390 (7th Cir. 2018). Otherwise rational-basis review governs. See Armour v. City of Indianapolis, Ind. , 566 U.S. 673, 680, 132 S.Ct. 2073, 182 L.Ed.2d 998 (2012) ; Hooper v. Bernalillo Cty. Assessor , 472 U.S. 612, 618, 105 S.Ct. 2862, 86 L.Ed.2d 487 (1985). This case does not involve a suspect class, like race, and neither education nor free transportation to school is a fundamental right. Kadrmas v. Dickinson Pub. Sch. , 487 U.S. 450, 457-62, 108 S.Ct. 2481, 101 L.Ed.2d 399 (1988) ; Plyler v. Doe , 457 U.S. 202, 223, 102 S.Ct. 2382, 72 L.Ed.2d 786 (1982) ; San Antonio Indep. Sch. Dist. v. Rodriguez , 411 U.S. 1, 33-35, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973) ; Racine Charter One, Inc. v. Racine Unified Sch. Dist. , 424 F.3d 677, 690 n.4 (7th Cir. 2005).",
-			"\u201a\u00c4\u00a2 20 U.S.C. \u00ac\u00df 1705 (Assignment on Neighborhood Basis Not a Denial of Equal Educational Opportunity)",
+			"20 U.S.C. \u00ac\u00df 1705 (Assignment on Neighborhood Basis Not a Denial of Equal Educational Opportunity)",
 			"Although Benner did not articulate his concern in precise legal language, a fair reading of his testimony shows that he was relying on well-established law holding that, by and large, it is illegal for public schools to treat students differently based solely on the color of their skin. See, e.g. , Parents Involved in Comty. Schools v. Seattle Sch. Dist. No. 1 , 551 U.S. 701, 747, 127 S.Ct. 2738, 168 L.Ed.2d 508 (2007) (holding that school district could not rely solely on race in allocating students to various schools in the district, and noting that \"the Fourteenth Amendment [to the U.S. Constitution] prevents states from according differential treatment to American children on the basis of their color or race\"); Alexander v. Sandoval , 532 U.S. 275, 280-81, 121 S.Ct. 1511, 149 L.Ed.2d 517 (2001) (explaining that Title VI of the Civil Rights Act of 1964 bars recipients of federal funds, which could include school districts, from intentionally discriminating on the basis of race). Indeed, in his brief, Benner points out that at least one federal circuit court has specifically stated that \"racial disciplinary quotas\" are both illegal and inequitable. See People Who Care v. Rockford Bd. of Educ., Sch. Dist. No. 205 , 111 F.3d 528, 528 (7th Cir. 1997) (Posner, J.,) (\"Racial disciplinary quotas violate equity in its root sense. They entail either systematically overpunishing the innocent or systematically underpunishing the guilty. They place race at war with justice. They teach schoolchildren an unedifying lesson of racial entitlements. And they incidentally are inconsistent with another provision of the [at-issue desegregation] decree, which requires that discipline be administered without regard to race or ethnicity.\").",
 			"See U.S. Const. amend. XIV, \u00ac\u00df 1 (providing that no state shall \"deny to any person within its jurisdiction the equal protection of the laws\").",
 			"An equal protection issue is involved. Under the Equal Protection Clause, state classifications based on alienage are subject to strict scrutiny and so must serve a compelling interest to be constitutional.",
@@ -191,7 +191,7 @@
 		],
 		"generation_e5":"The provided passages suggest that the strongest argument against the constitutionality of the act revolves around the principle that the courts, not Congress, have the primary responsibility for defining and enforcing the requirements of the equal protection clause of the Fourteenth Amendment. The passages emphasize various roles of the judiciary in interpreting equal protection, citing landmark cases such as *Brown v. Board of Education* where the judiciary determined the constitutionality and appropriate remedies for segregation. This underscores the judiciary's established role in defining how equal protection applies to public school desegregation. Thus, an argument that Congress overstepped its bounds by restricting judicial authority to prescribe desegregation remedies\u2014specifically, the transportation of students\u2014aligns with this principle.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"Application of the Privileges and Immunities Clause to a particular instance of discrimination against out-of-state residents entails a two-step inquiry. As an initial matter, the court must decide whether the ordinance burdens one of those privileges and immunities protected by the Clause. Baldwin v. Montana Fish and Game Comm'n, 436 U.S. 371, 383, 98 S.Ct. 1852, 1860, 56 L.Ed.2d 354 (1978). Not all forms of discrimination against citizens of other States are constitutionally suspect. \u201a\u00c4\u00faSome distinctions between residents and nonresidents merely reflect the fact that this is a Nation composed of individual States, and are permitted; other distinctions are prohibited because they hinder the formation, the purpose, or the development of a single Union of those States. Only with respect to those \u201a\u00c4\u00f2privileges' and \u201a\u00c4\u00f2immunities' bearing upon the vitality of the Nation as a single entity must the State treat all citizens, resident and nonresident, equally.\u201a\u00c4\u00f9 Ibid. As a threshold matter, then, we must determine whether an out-of-state resident's **1028 interest in employment on public works contracts in another State is sufficiently \u201a\u00c4\u00fafundamental\u201a\u00c4\u00f9 to the promotion of interstate harmony so as to \u201a\u00c4\u00fafall within the purview of the Privileges and Immunities Clause.\u201a\u00c4\u00f9 Id., at 388, 98 S.Ct., at 1862. See also *219 Canadian Northern Ry. Co. v. Eggen, 252 U.S. 553, 560, 40 S.Ct. 402, 403, 64 L.Ed. 713 (1920); Blake v. McClung, 172 U.S. 239, 248, 19 S.Ct. 165, 169, 43 L.Ed. 432 (1898).",
+		"gold_passage":"Application of the Privileges and Immunities Clause to a particular instance of discrimination against out-of-state residents entails a two-step inquiry. As an initial matter, the court must decide whether the ordinance burdens one of those privileges and immunities protected by the Clause. Baldwin v. Montana Fish and Game Comm'n, 436 U.S. 371, 383, 98 S.Ct. 1852, 1860, 56 L.Ed.2d 354 (1978). Not all forms of discrimination against citizens of other States are constitutionally suspect. \"Some distinctions between residents and nonresidents merely reflect the fact that this is a Nation composed of individual States, and are permitted; other distinctions are prohibited because they hinder the formation, the purpose, or the development of a single Union of those States. Only with respect to those 'privileges' and 'immunities' bearing upon the vitality of the Nation as a single entity must the State treat all citizens, resident and nonresident, equally.\" Ibid. As a threshold matter, then, we must determine whether an out-of-state resident's **1028 interest in employment on public works contracts in another State is sufficiently \"fundamental\" to the promotion of interstate harmony so as to \"fall within the purview of the Privileges and Immunities Clause.\" Id., at 388, 98 S.Ct., at 1862. See also *219 Canadian Northern Ry. Co. v. Eggen, 252 U.S. 553, 560, 40 S.Ct. 402, 403, 64 L.Ed. 713 (1920); Blake v. McClung, 172 U.S. 239, 248, 19 S.Ct. 165, 169, 43 L.Ed. 432 (1898).",
 		"gold_passage_generation":"The passage discusses the application of the Privileges and Immunities Clause, emphasizing a two-step inquiry to determine if an ordinance burdens the rights protected by the Clause. The court must first decide if the discrimination against out-of-state residents involves a privilege or immunity fundamental to promoting interstate harmony and the union of states. If so, the state must treat resident and nonresident citizens equally regarding that privilege or immunity. This principle is relevant to assessing the constitutionality of laws that may treat different groups differently."
 	},
 	"mbe_389":{
@@ -230,7 +230,7 @@
 		],
 		"generation_e5":"The provided passages highlight several key legal principles relevant to the plaintiffs' case regarding the State Bar Association's payment of dues to a discriminatory private club. The core principle discussed is the Equal Protection Clause of the Fourteenth Amendment, which mandates that state actors must not \"deny to any person within its jurisdiction the equal protection of the laws.\" This clause prompts strict scrutiny when state actions classify individuals based on suspect classes like race, or when they impinge on fundamental rights. \n\nThe passages explain that if officials treat individuals differently under like circumstances, they must provide a justification, particularly if such treatment involves suspect classifications (e.g., race, religion, sex) or fundamental rights. State actions must be \"suitably tailored to serve a compelling state interest\" to pass strict scrutiny, though rational basis review applies to non-suspect classifications, where actions are upheld if they serve a legitimate state interest.\n\nMoreover, establishing an equal protection violation requires demonstrating not just differential treatment but also discriminatory intent. This can involve evidence that a state practice disadvantageously affects a suspect class or impinges on a fundamental right, necessitating a compelling justification for such actions.\n\nThese principles collectively underscore that state agencies like the Bar Association, comprised of state officials and holding significant influence over state policy, must justify practices implicating suspect classifications and fundamental rights to withstand constitutional scrutiny under the Equal Protection Clause.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"When the government expressly classifies persons on the basis of race or national origin, however, its action is \u201a\u00c4\u00fa \u201a\u00c4\u00f2immediately suspect.\u201a\u00c4\u00f4 \u201a\u00c4\u00f9 Johnson v. California, 543 U.S. 499, 125 S.Ct. 1141, 1148, 160 L.Ed.2d 949 (2005) (quoting Shaw v. Reno, 509 U.S. 630, 642, 113 S.Ct. 2816, 125 L.Ed.2d 511 (1993)). A plaintiff in such a lawsuit need not make an extrinsic showing of discriminatory animus or a discriminatory effect to trigger strict scrutiny. \u201a\u00c4\u00faNo inquiry into legislative purpose is necessary when the racial classification appears on the face of the statute.\u201a\u00c4\u00f9 Shaw, 509 U.S. at 642, 113 S.Ct. 2816. The burden of proof shifts, strict scrutiny applies, and \u201a\u00c4\u00fa[u]nder strict scrutiny, the government [defending the constitutionality of the law] has the burden of proving that racial classifications \u201a\u00c4\u00f2are narrowly tailored measures that further compelling governmental interests.\u201a\u00c4\u00f4 \u201a\u00c4\u00f9 Johnson, 125 S.Ct. at 1146 (quoting Adarand, 515 U.S. at 227, 115 S.Ct. 2097). As noted above, the Supreme Court has explained that we \u201a\u00c4\u00fa \u201a\u00c4\u00f2apply strict scrutiny to all racial classifications to \u201a\u00c4\u00fasmoke out\u201a\u00c4\u00f9 illegitimate uses of race by assuring that government is pursuing a goal important enough to warrant use of a highly suspect tool.\u201a\u00c4\u00f4 \u201a\u00c4\u00f9 Id. (quoting Croson, 488 U.S. at 493, 109 S.Ct. 706 (plurality opinion)) (emphasis in Johnson; alteration incorporated).",
+		"gold_passage":"When the government expressly classifies persons on the basis of race or national origin, however, its action is \" 'immediately suspect.' \" Johnson v. California, 543 U.S. 499, 125 S.Ct. 1141, 1148, 160 L.Ed.2d 949 (2005) (quoting Shaw v. Reno, 509 U.S. 630, 642, 113 S.Ct. 2816, 125 L.Ed.2d 511 (1993)). A plaintiff in such a lawsuit need not make an extrinsic showing of discriminatory animus or a discriminatory effect to trigger strict scrutiny. \"No inquiry into legislative purpose is necessary when the racial classification appears on the face of the statute.\" Shaw, 509 U.S. at 642, 113 S.Ct. 2816. The burden of proof shifts, strict scrutiny applies, and \"[u]nder strict scrutiny, the government [defending the constitutionality of the law] has the burden of proving that racial classifications 'are narrowly tailored measures that further compelling governmental interests.' \" Johnson, 125 S.Ct. at 1146 (quoting Adarand, 515 U.S. at 227, 115 S.Ct. 2097). As noted above, the Supreme Court has explained that we \" 'apply strict scrutiny to all racial classifications to \"smoke out\" illegitimate uses of race by assuring that government is pursuing a goal important enough to warrant use of a highly suspect tool.' \" Id. (quoting Croson, 488 U.S. at 493, 109 S.Ct. 706 (plurality opinion)) (emphasis in Johnson; alteration incorporated).",
 		"gold_passage_generation":"The passage outlines that any government action classifying persons based on race or national origin is immediately suspect and subject to strict scrutiny, as established in cases like *Johnson v. California* and *Shaw v. Reno*. Under strict scrutiny, the government must prove that such racial classifications are narrowly tailored to serve a compelling governmental interest. This stringent standard aims to prevent illegitimate uses of race by ensuring that any racial classification is justified by a sufficiently important governmental objective."
 	},
 	"mbe_563":{
@@ -257,7 +257,7 @@
 		"generation_colbert":"The passages collectively highlight significant principles regarding the interplay between federal and state constitutional interpretations, particularly under the Equal Protection Clause. Key points include the concept that state courts can interpret their constitutions to offer greater protection than the federal counterpart, but they are bound by the minimum standards set by the federal Constitution. It is also noted that the U.S. Supreme Court has jurisdiction to review state court decisions when federal constitutional questions are involved (e.g., Baker v. Carr). Additionally, state constitutions can independently provide more rigorous protections, but interpretations aligning state equal protection with the federal Fourteenth Amendment must adhere to federal standards. The passages also emphasize the rational basis review applied to economic legislation unless suspect classifications or fundamental rights are involved. Finally, principles such as the Supremacy Clause and the Court\u2019s avoidance of political questions (as seen in Baker) frame the judiciary\u2019s discretion in reviewing state court decisions on federal constitutional grounds.",
 		"top10_e5":[
 			"Whether State Courts Have Jurisdiction over the Plaintiff's Federal Constitutional Claims, Regardless of the State Elections Clause",
-			"Martin v. Hunter's Lessee (1816): Martin v. Hunter\u201a\u00c4\u00f4s Lessee (1816), is a Supreme Court case that established the Supreme Court\u201a\u00c4\u00f4s authority over state courts in matters of federal law. The plaintiff in this case, Martin, sued the defendant, Hunter\u201a\u00c4\u00f4s Lessee, in Virginia State court over a land dispute. The Virginia Court of Appeals decided in favor of Hunter\u201a\u00c4\u00f4s Lessee but the Supreme Court of the United States reversed this holding. The Virginia State court rejected the Supreme Court\u201a\u00c4\u00f4s reversal stating that Section 25 of the Judiciary Act (a law that granted the United States Supreme Court appellate review power over state-court decisions) was unconstitutional. The State court reasoned that under the principle of dual sovereignty, both State and Federal Supreme Courts were most powerful in their own governments with neither having superiority over the other. The United States Supreme Court reconsidered the case and upheld the Judiciary Act, reasoning that questions of federal law were within the Supreme Court\u201a\u00c4\u00f4s jurisdiction. The Court rejected the notion that state governments held equal sovereignty with the federal government. The Court emphasized the importance of having a single, coherent interpretation of the Constitution and federal laws rather than multiple competing interpretations from various state courts and referred to Article III which implicitly states that the Supreme Court has the right to review decisions of state courts. The case established the Supreme Court\u201a\u00c4\u00f4s supremacy in matters of constitutional interpretation and over state courts, making it the most powerful court in the United States. In the later half of the nineteenth century, the Court went on to limit its power over state-law issues in appeals that involved federal questions. In Murdock v. Memphis (1874), the Court held that it will only consider cases with federal issues even though a revised Section 25 of the Judiciary Act omitted language indicating that the Court could only decide federal-issues. [Last updated in July of 2020 by the Wex Definitions Team]",
+			"Martin v. Hunter's Lessee (1816): Martin v. Hunter's Lessee (1816), is a Supreme Court case that established the Supreme Court's authority over state courts in matters of federal law. The plaintiff in this case, Martin, sued the defendant, Hunter's Lessee, in Virginia State court over a land dispute. The Virginia Court of Appeals decided in favor of Hunter's Lessee but the Supreme Court of the United States reversed this holding. The Virginia State court rejected the Supreme Court's reversal stating that Section 25 of the Judiciary Act (a law that granted the United States Supreme Court appellate review power over state-court decisions) was unconstitutional. The State court reasoned that under the principle of dual sovereignty, both State and Federal Supreme Courts were most powerful in their own governments with neither having superiority over the other. The United States Supreme Court reconsidered the case and upheld the Judiciary Act, reasoning that questions of federal law were within the Supreme Court's jurisdiction. The Court rejected the notion that state governments held equal sovereignty with the federal government. The Court emphasized the importance of having a single, coherent interpretation of the Constitution and federal laws rather than multiple competing interpretations from various state courts and referred to Article III which implicitly states that the Supreme Court has the right to review decisions of state courts. The case established the Supreme Court's supremacy in matters of constitutional interpretation and over state courts, making it the most powerful court in the United States. In the later half of the nineteenth century, the Court went on to limit its power over state-law issues in appeals that involved federal questions. In Murdock v. Memphis (1874), the Court held that it will only consider cases with federal issues even though a revised Section 25 of the Judiciary Act omitted language indicating that the Court could only decide federal-issues. [Last updated in July of 2020 by the Wex Definitions Team]",
 			"On the surface, my colleagues purport to take issue with this Court's procedure for certification. But, on a more fundamental level, they appear to challenge this Court's very jurisdiction to decide matters of state law in diversity cases, a power that emanates from Article III and which Congress has codified in 28 U.S.C. \u00ac\u00df 1332. It is an \"undisputed constitutional principle that Congress, and not the Judiciary, defines the scope of federal jurisdiction within the constitutionally permissible bounds.\" New Orleans Pub. Serv., Inc. v. Council of City of New Orleans , 491 U.S. 350, 359, 109 S.Ct. 2506, 105 L.Ed.2d 298 (1989). Federal courts have a \"virtually unflagging obligation ... to exercise the jurisdiction given them,\" Colo. River Water Conservation Dist. v. United States , 424 U.S. 800, 817, 96 S.Ct. 1236, 47 L.Ed.2d 483 (1976), and \"have no more right to decline the exercise of jurisdiction which is given, than to usurp that which is not given,\" Cohens v. Virginia , 19 U.S. (6 Wheat.) 264, 404, 5 L.Ed. 257 (1821). Thus, when diversity jurisdiction is properly invoked, federal courts have a \"duty ... to decide questions of state law whenever necessary to the rendition of a judgment.\" Meredith v. City of Winter Haven , 320 U.S. 228, 234, 64 S.Ct. 7, 88 L.Ed. 9 (1943) ; see Burgess v. Seligman , 107 U.S. 20, 33, 2 S.Ct. 10, 27 L.Ed. 359 (1883) (explaining that \"[t]he federal courts have an independent jurisdiction in the administration of state laws, co-ordinate with, and not subordinate to, that of the state courts\"). And \"it is still the duty of the federal courts, where the state law supplies the rule of decision, to ascertain and apply that law even though it has not been expounded by the highest court of the State.\" Fid. Union Tr. Co. v. Field , 311 U.S. 169, 177, 61 S.Ct. 176, 85 L.Ed. 109 (1940) (call number omitted).",
 			"b. The Court Has Federal Question Jurisdiction, and Supplemental Jurisdiction Over the State-Law Claims",
 			"b. The Court Has Federal Question Jurisdiction, and Supplemental Jurisdiction Over the State-Law Claims",
@@ -308,7 +308,7 @@
 		],
 		"generation_e5":"The relevant legal principles discussed in the provided passages focus on the concepts of foreseeability, negligence, causation, and intervening causes within tort law. The passages related to res ipsa loquitur suggest that the court considers whether the harm would typically occur without negligence and whether the defendant had control over the instrumentality causing the injury. The doctrine of foreseeability examines whether it was predictable that a particular act could lead to harm. Additionally, intervening causes, such as the ambulance driver's unforeseeable heart attack, are analyzed to determine if they supersede the original negligent act, breaking the chain of causation and absolving the initial actor of liability for subsequent injuries. These principles help in evaluating if Donald could be held liable for Peter's broken leg due to the chain of events set in motion by the harmful cake.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"The elements of proximate cause are cause in fact and foreseeability. See Doe v. Boys Club of Greater Dallas, Inc., 907 S.W.2d 472, 477 (Tex.1995). Cause in fact means that the act or omission was a substantial factor in bringing about the injury, and without it harm would not have occurred. See Travis v. City of Mesquite, 830 S.W.2d 94, 98 (Tex.1992). Foreseeability means that the actor, as a person of ordinary intelligence, should have anticipated the dangers that his negligent act or omission created for others. See D. Houston, Inc. v. Love, 92 S.W.3d 450, 454 (Tex.2002). This test requires \u201a\u00c4\u00faonly that the general danger, not the exact sequence of events that produced the harm, be foreseeable.\u201a\u00c4\u00f9 See Timberwalk Apartments, Partners, Inc. v. Cain, 972 S.W.2d 749, 756 (Tex.1998); Walker v. Harris, 924 S.W.2d 375, 377 (Tex.1996).",
+		"gold_passage":"The elements of proximate cause are cause in fact and foreseeability. See Doe v. Boys Club of Greater Dallas, Inc., 907 S.W.2d 472, 477 (Tex.1995). Cause in fact means that the act or omission was a substantial factor in bringing about the injury, and without it harm would not have occurred. See Travis v. City of Mesquite, 830 S.W.2d 94, 98 (Tex.1992). Foreseeability means that the actor, as a person of ordinary intelligence, should have anticipated the dangers that his negligent act or omission created for others. See D. Houston, Inc. v. Love, 92 S.W.3d 450, 454 (Tex.2002). This test requires \"only that the general danger, not the exact sequence of events that produced the harm, be foreseeable.\" See Timberwalk Apartments, Partners, Inc. v. Cain, 972 S.W.2d 749, 756 (Tex.1998); Walker v. Harris, 924 S.W.2d 375, 377 (Tex.1996).",
 		"gold_passage_generation":"The passage outlines the elements of proximate cause, which include cause in fact and foreseeability. Cause in fact requires that the act or omission was a substantial factor in bringing about the injury, without which the harm would not have occurred. Foreseeability means that a person of ordinary intelligence should have anticipated the general dangers created by their negligent actions, though not necessarily the exact sequence of events. The test for foreseeability only requires that the general danger was foreseeable, not the precise manner in which the injury occurred. This principle is crucial in determining liability in negligence cases."
 	},
 	"mbe_642":{
@@ -347,7 +347,7 @@
 		],
 		"generation_e5":"The passages clarify several high-level legal rules and principles regarding joint tenancy, judgment liens, and their effects on property interests:\n\n1. **Joint Tenancy Characteristics**: Joint tenancy includes ownership by two or more individuals with identical interests and the right of survivorship. Upon the death of a joint tenant, their interest typically transfers automatically to the surviving joint tenants (Black's Law Dictionary; Poulson v. Poulson).\n\n2. **Effect of Judgment Liens**: A judgment lien can attach to a joint tenant's interest in property, rendering it subject to execution and foreclosure ([14]; Thornburg v. Wiggins). However, the survivorship right complicates matters, as demonstrated in various case law:\n   - In some jurisdictions, the lien survives the death of a joint tenant, transferring the property subject to the lien ([15]; Chandler case, indicating the surviving tenant inherits the deceased tenant's share but subject to any liens).\n   - Conversely, some cases suggest the lien may not survive if not specifically addressed by statute, implying that the survivorship right might extinguish the lien upon death unless litigation or execution action is taken beforehand ([BAP case]; Grathwohl, Crowther v. Mower).\n\n3. **Severance and Alienation**: Joint tenants can unilaterally sever their joint tenancy, converting it to tenancy in common by actions such as conveyance or judgment lien attachment, thus eliminating the right of survivorship for that interest ([27]; Crowther v. Mower).\n\n4. **Impact on Survivors and Other Tenants**: A surviving joint tenant may inherit the deceased joint tenant\u2019s share free of personal obligations like liens if no severance occurred before death. The real property, upon the death of a co-tenant, typically vests fully in the surviving tenant by operation of law, often unaffected by personal judgment debts of the deceased ([8]; Indiana Code; Poulson v. Poulson).\n\nThese principles collectively indicate that joint tenancy includes a potent survivorship right potentially negating some third-party claims upon a tenant's death, unless effectively severed or alienated during the tenant's lifetime.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"As stated, there is no dispute that a joint tenancy with right of survivorship was created. Under New York law, a \u201a\u00c4\u00fajoint tenancy is an estate held by two or more persons jointly, with equal rights to share in its enjoyment during their lives, and creating in each joint tenant a right of survivorship\u201a\u00c4\u00f9 (24 NY Jur.2d, Cotenancy and Partition \u00ac\u00df 16, at 332, 333). \u201a\u00c4\u00faThe continuance of the joint tenancy depends on the maintenance of the unities of title, interest and possession, and the destruction of any of these unities leads to a severance of the tenancy, and to the creation of a tenancy in common or of several tenancies\u201a\u00c4\u00f9 (Loker v. Edmans, 204 App.Div.223, 226, 197 N.Y.S. 857 [3rd Dep't 1923] [internal quotation marks omitted]).\u201a\u00c4\u00f9 Goetz v. Slobey, 76 A.D.3d 954, 956, 908 N.Y.S.2d 237 (2nd Dep't 2010).",
+		"gold_passage":"As stated, there is no dispute that a joint tenancy with right of survivorship was created. Under New York law, a \"joint tenancy is an estate held by two or more persons jointly, with equal rights to share in its enjoyment during their lives, and creating in each joint tenant a right of survivorship\" (24 NY Jur.2d, Cotenancy and Partition \u00ac\u00df 16, at 332, 333). \"The continuance of the joint tenancy depends on the maintenance of the unities of title, interest and possession, and the destruction of any of these unities leads to a severance of the tenancy, and to the creation of a tenancy in common or of several tenancies\" (Loker v. Edmans, 204 App.Div.223, 226, 197 N.Y.S. 857 [3rd Dep't 1923] [internal quotation marks omitted]).\" Goetz v. Slobey, 76 A.D.3d 954, 956, 908 N.Y.S.2d 237 (2nd Dep't 2010).",
 		"gold_passage_generation":"The passage explains that a joint tenancy is characterized by equal rights to the property's enjoyment and includes a right of survivorship, meaning that when one joint tenant dies, their interest passes to the surviving tenant. The joint tenancy exists as long as the unities of title, interest, and possession are maintained, and it is destroyed if any of these unities is severed, converting the ownership into a tenancy in common. Key for Tent's lien is that, with Hal's death, the joint tenancy was terminated, meaning the right of survivorship granted Wan full ownership of Blackacre immediately, nullifying any separate claims on Hal's prior interest."
 	},
 	"mbe_747":{
@@ -376,7 +376,7 @@
 			"a. The Oregon Rule, The Pennsylvania Rule, and Res Ipsa Loquitur",
 			"Comparative negligence jurisdictions allow a plaintiff to recover some percentage of his damages even though he was contributorily negligent intcausing the accident. Pure comparative negligence allows a plaintiff some recovery no matter how great his negligence was. On the MBE, examinees are instructed to assume that pure comparative negligence, with joint and several liability, is the applicable rule unless stated otherwise The doctrine of joint and several liability makes each of several tortfeasors liable to the plaintiff for the entire amount of damages to which the plaintiff is entitled. However, if one tortfeasor does have to pay the plaintiff the entire judgment, the rule of contribution allows the paying tortfeasor to recover the excess over his share from the nonpaying tortfeasor. Contribution in most comparative negligence jurisdictions is based on comparative fault, whereby the nonpaying tortfeasor is required to contribute an amount in proportion to his relative fault.",
 			"Defendant was driving under the influence of intoxicants late at night when he struck the victim, who had walked onto the road in a dark area that was not marked for pedestrian crossing. He pleaded guilty to one count of driving under the influence of intoxicants and one count of assault in the third degree, but he resisted the state's request for restitution in the amount of the victim's full medical bills. Defendant offered evidence that the victim's own negligence was the primary cause of the collision and urged the trial court to apply the civil doctrine of comparative fault to reduce the requested restitution. The trial court refused to consider the victim's alleged negligence and ordered defendant to pay the requested restitution.",
-			"contributory negligence: Contributory negligence is a common law tort rule which bars plaintiffs from recovering for the negligence of others if they too were negligent in causing the harm. Contributory negligence has been replaced in many jurisdictions with the doctrine of comparative negligence. In the field of tort law, a plaintiff can recover against a negligent defendant by proving that: The defendant owed a duty to the plaintiff. The defendant breached that duty to the plaintiff. The plaintiff suffered harm due to the defendant\u201a\u00c4\u00f4s breach. In a jurisdiction that follows contributory negligence, a plaintiff who is at all negligent cannot recover, even if they establish the above elements. For the purposes of contributory negligence, the degree of the plaintiff\u201a\u00c4\u00f4s/defendant\u201a\u00c4\u00f4s respective negligence is irrelevant, thus a plaintiff who was 1% negligent will receive nothing from a defendant who was 99% negligent. The advantage of this all or nothing rule is that it does not require the courts to accurately determine the degree of blame each party shares for the harm. On the other hand, the application of contributory negligence can lead to outcomes society deems inequitable. Because of the all or nothing nature of contributory negligence, courts developed a collection of exceptions to standard contributory negligence over the years. For example, under the doctrine of last clear chance, a negligent plaintiff can still recover if the defendant was the only party capable of preventing the harm through reasonable means and nonetheless failed to do so. The majority of jurisdictions, however, have gone even further in limiting the application of contributory negligence by eliminating the doctrine altogether in favor of comparative negligence. Under comparative negligence, a negligent plaintiff can recover against a negligent defendant for the defendant\u201a\u00c4\u00f4s share of the blame. For example, a plaintiff who was 5% negligent can recover compensation for 95% of the harm. Nonetheless, the doctrine of comparative negligence is still followed in Maryland, Virginia, Alabama, and North Carolina. [Last updated in July of 2022 by the Wex Definitions Team]",
+			"contributory negligence: Contributory negligence is a common law tort rule which bars plaintiffs from recovering for the negligence of others if they too were negligent in causing the harm. Contributory negligence has been replaced in many jurisdictions with the doctrine of comparative negligence. In the field of tort law, a plaintiff can recover against a negligent defendant by proving that: The defendant owed a duty to the plaintiff. The defendant breached that duty to the plaintiff. The plaintiff suffered harm due to the defendant's breach. In a jurisdiction that follows contributory negligence, a plaintiff who is at all negligent cannot recover, even if they establish the above elements. For the purposes of contributory negligence, the degree of the plaintiff's/defendant's respective negligence is irrelevant, thus a plaintiff who was 1% negligent will receive nothing from a defendant who was 99% negligent. The advantage of this all or nothing rule is that it does not require the courts to accurately determine the degree of blame each party shares for the harm. On the other hand, the application of contributory negligence can lead to outcomes society deems inequitable. Because of the all or nothing nature of contributory negligence, courts developed a collection of exceptions to standard contributory negligence over the years. For example, under the doctrine of last clear chance, a negligent plaintiff can still recover if the defendant was the only party capable of preventing the harm through reasonable means and nonetheless failed to do so. The majority of jurisdictions, however, have gone even further in limiting the application of contributory negligence by eliminating the doctrine altogether in favor of comparative negligence. Under comparative negligence, a negligent plaintiff can recover against a negligent defendant for the defendant's share of the blame. For example, a plaintiff who was 5% negligent can recover compensation for 95% of the harm. Nonetheless, the doctrine of comparative negligence is still followed in Maryland, Virginia, Alabama, and North Carolina. [Last updated in July of 2022 by the Wex Definitions Team]",
 			"\u00ac\u22021 This case stems from a car accident in which Defendant Ricardo Carrera ran a stop sign and struck Plaintiff Kathleen Pinney's vehicle. Subsequently, Plaintiff filed suit, claiming personal injuries. At trial, Defendant made three separate oral motions for judgment as a matter of law-each on a discrete point of law. One of those motions was granted, and two were denied. At the close of his case-in-chief, Defendant again renewed the third motion for judgment as a matter of law related to Utah's no-fault tort threshold, but the court again denied the motion. Prior to submission of the case to the jury, Defendant also objected to the trial court's refusal to give a requested jury instruction. The jury returned a verdict in favor of Plaintiff, awarding $300,000 in general damages. Defendant then filed a motion for judgment notwithstanding the verdict, or alternatively, for a new trial, which the trial court denied. Defendant appeals and we affirm.",
 			"comparative negligence: Comparative negligence is a tort principle used by the court to reduce the amount of damages that a plaintiff can recover in a negligence-based claim according to the degree of negligence each party contributed to the incident. Specifically, when an injured victim was partially at fault because of their own negligence, the court may assign a percentage of fault to both the injured victim and the defendant. For instance, if the court assigns 60% fault to the defendant and 40% to the plaintiff, the plaintiff may only recover 60% of the damages, rather than the full. There are two types of comparative negligence in the United States, as well as contributory negligence, so damages awarded vary from state to state. Pure Comparative Negligence: Under the pure comparative negligence rule, the state allows the plaintiff to claim damages for the 1% they are not at fault even when they are 99% at fault. In other words, the amount of damages that the plaintiff can collect is limited based on the assigned fault determined by the court. Almost one-third of states follow this rule, including California, Florida, and New York. Modified Comparative Negligence: Two types of modified comparative negligence exist: 50 percent bar rule and 51 percent bar rule. Under the 50 percent bar rule: the plaintiff may not recover damages if they are found to be 50% or more at fault. Under the 51 percent bar rule: the plaintiff may not recover damages if they are assigned 51% or more of the fault. The modified comparative negligence principle is followed by the majority of states. Compare: Contributory Negligence: Under the contributory negligence rule, the plaintiff cannot recover any damages if they contributed in any way to the incident. In other words, the state recognizing contributory negligence rule prevents the plaintiff from collecting damages even when they were found to only be 1% negligent. Only four states and the District of Columbia recognize the contributory negligence rule: Alabama, Maryland, North Carolina, and Virginia. [Last updated in July of 2022 by the Wex Definitions Team]",
 			"\u00ac\u220244 Nutt contends, in the first instance, that the allocation of negligence between a plaintiff and a defendant is a question of fact that must be decided by a jury. He is incorrect. \"While the apportionment of negligence is ordinarily a jury question, where the plaintiff's negligence clearly exceeds the defendant's, courts may so hold as a matter of law.\" Hertelendy v. Agway Ins. Co. , 177 Wis. 2d 329, 334, 501 N.W.2d 903 (Ct. App. 1993). In fact, our supreme court has held that, \"when it is apparent to the court that the plaintiff's negligence is, as a matter of law, greater than any negligence on defendant's part, it is the court's duty to so hold.\" Peters v. Menard, Inc. , 224 Wis. 2d 174, 193, 589 N.W.2d 395 (1999).",
@@ -386,7 +386,7 @@
 		],
 		"generation_e5":"The principle of pure comparative negligence allows a plaintiff to recover damages even if they are significantly negligent, with their recovery reduced by their percentage of fault. The doctrine of joint and several liability means that each defendant can be held responsible for the entire amount of damages, but can seek contribution from the other defendant based on their relative fault. Assumption of risk has been abolished in this jurisdiction, thus plaintiffs are not barred from recovery even if they knowingly engaged in risky behavior. Instead, any voluntary assumption of risk is treated as a factor to apportion comparative negligence. Furthermore, courts will uphold the rule that a plaintiff who was negligent will have their damages reduced accordingly, yet they can still recover some portion of damages from the defendants unless their negligence exceeds a specific threshold in modified jurisdictions, which is not applicable here. Finally, apportionment of negligence is generally a fact question for the jury, unless it is clear that the plaintiff\u2019s negligence primarily caused the harm.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"Mississippi follows the \u201a\u00c4\u00facomparative negligence doctrine,\u201a\u00c4\u00f9 which measures negligence \u201a\u00c4\u00fain terms of percentage, and any damages allowed shall be diminished in proportion to amount of negligence attributable to the person for whose injury, damage or death recovery is sought.\u201a\u00c4\u00f9 Meka, 67 So.3d at 23 (\u00ac\u2202 15) (citations omitted).",
+		"gold_passage":"Mississippi follows the \"comparative negligence doctrine,\" which measures negligence \"in terms of percentage, and any damages allowed shall be diminished in proportion to amount of negligence attributable to the person for whose injury, damage or death recovery is sought.\" Meka, 67 So.3d at 23 (\u00ac\u2202 15) (citations omitted).",
 		"gold_passage_generation":"The passage highlights that Mississippi follows the comparative negligence doctrine, under which negligence is measured in percentages and any damages awarded are reduced according to the percentage of negligence attributable to the injured party. This approach ensures that a plaintiff\u2019s recovery is diminished in direct proportion to their own fault in contributing to their injuries. Thus, if the plaintiff is found to be partially negligent, their overall damages are proportionately reduced by their degree of fault."
 	},
 	"mbe_779":{
@@ -425,7 +425,7 @@
 		],
 		"generation_e5":"The key legal principles addressing the enforceability of the real property contract between Able and Baker focus on the doctrine of part performance, the Statute of Frauds, and the sufficiency of consideration in real estate transactions. \n\nThe Statute of Frauds generally requires that contracts for the sale of land be in writing and signed by the party to be charged (typically the buyer in a case like this), in order to be enforceable. However, the doctrine of part performance can serve as an exception to the Statute of Frauds. This doctrine hinges on whether actions taken by the purchaser unequivocally indicate the existence of the contract. For example, part performance can be demonstrated if the purchaser physically occupied the land or made improvements in reliance on the agreement. Acts of part performance must be clear and convincing, specifically pointing to the existence of the contract and leading the purchaser to act to their detriment.\n\nIn this context, Baker\u2019s frequent use of Blackacre for parking\u2014often allowed by Able\u2014could potentially be viewed as part performance, satisfying the evidentiary needs to bring the agreement out of the Statute of Frauds. This usage would need to unmistakably point to the underlying agreement and show substantial reliance by Baker such that it would be inequitable for Able to deny the contract\u2019s validity.\n\nAdditionally, recording the written agreement lends further credence to its enforceability, fulfilling statutory requirements even if no earnest money was made. General contract rules of consideration dictate that the promise to buy and the promise to sell constitute legal consideration, sufficient to uphold a real estate contract without the necessity of an earnest money down payment.\n\nThus, a court may find that Baker's actions amount to part performance of the contract, supporting Able\u2019s claim for specific performance due to the inadequacy of legal damages in real estate transactions. This ensures the enforceability of the contract despite the lack of initial down payment.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"\u201a\u00c4\u00faConversion is an intentional exercise of dominion or control over a chattel which so seriously interferes with the right of another to control it that the actor may justly be required to pay the other the full value of the chattel.\u201a\u00c4\u00f9 To establish a claim for conversion, the plaintiff must prove (1) that she had a possessory interest in the property; (2) that the defendant interfered with the plaintiff's right to possess the property; (3) that the defendant intended to interfere with plaintiff's possession; and (4) that the defendant's act was the legal cause of the plaintiff's loss of the property.30 Where the plaintiff voluntarily places her property with the defendant, the \u201a\u00c4\u00fadefendant ordinarily is not required to do more than permit the plaintiff to come and get the chattel.\u201a\u00c4\u00f9",
+		"gold_passage":"\"Conversion is an intentional exercise of dominion or control over a chattel which so seriously interferes with the right of another to control it that the actor may justly be required to pay the other the full value of the chattel.\" To establish a claim for conversion, the plaintiff must prove (1) that she had a possessory interest in the property; (2) that the defendant interfered with the plaintiff's right to possess the property; (3) that the defendant intended to interfere with plaintiff's possession; and (4) that the defendant's act was the legal cause of the plaintiff's loss of the property.30 Where the plaintiff voluntarily places her property with the defendant, the \"defendant ordinarily is not required to do more than permit the plaintiff to come and get the chattel.\"",
 		"gold_passage_generation":"The passage provided discusses the legal concept of conversion, which is the intentional exercise of dominion or control over someone else's chattel that severely interferes with their rights and can result in the requirement to pay the full value of the chattel to its owner. To establish conversion, a plaintiff must show possessory interest in the property, interference by the defendant, the defendant's intent to interfere, and causation of loss. It also notes that if the plaintiff voluntarily placed the chattel with the defendant, the defendant typically only needs to allow the plaintiff to retrieve it.\n\nThis passage, however, is not relevant to the legal issue in the question concerning whether Baker can refuse to close on the sale of Blackacre and be free of liability. The key issue revolves around real estate contract principles, not the tort of conversion regarding chattels."
 	},
 	"mbe_826":{
@@ -457,8 +457,8 @@
 			"\u00ac\u00df 9-203. ATTACHMENT AND ENFORCEABILITY OF SECURITY INTEREST; PROCEEDS; SUPPORTING OBLIGATIONS; FORMAL REQUISITES. (a) [Attachment.] A security interest attaches to collateral when it becomes enforceable against the debtor with respect to the collateral, unless an agreement expressly postpones the time of attachment. (b) [Enforceability.] Except as otherwise provided in subsections (c) through (i), a security interest is enforceable against the debtor and third parties with respect to the collateral only if : (1) value has been given; (2) the debtor has rights in the collateral or the power to transfer rights in the collateral to a secured party; and (3) one of the following conditions is met: (A) the debtor has authenticated a security agreement that provides a description of the collateral and, if the security interest covers timber to be cut, a description of the land concerned; (B) the collateral is not a certificated security and is in the possession of the secured party under Section 9-313 pursuant to the debtor's security agreement; (C) the collateral is a certificated security in registered form and the security certificate has been delivered to the secured party under Section 8-301 pursuant to the debtor's security agreement; or (D) the collateral is deposit accounts, electronic chattel paper, investment property, or letter-of-credit rights, and the secured party has control under Section 9-104, 9-105, 9-106, or 9-107 pursuant to the debtor's security agreement. (c) [Other UCC provisions.] Subsection (b) is subject to Section 4-210 on the security interest of a collecting bank, Section 5-118 on the security interest of a letter-of-credit issuer or nominated person, Section 9-110 on a security interest arising under Article 2 or 2A, and Section 9-206 on security interests in investment property. (d) [When person becomes bound by another person's security agreement.] A person becomes bound as debtor by a security agreement entered into by another person if, by operation of law other than this article or by contract: (1) the security agreement becomes effective to create a security interest in the person's property; or (2) the person becomes generally obligated for the obligations of the other person, including the obligation secured under the security agreement, and acquires or succeeds to all or substantially all of the assets of the other person. (e) [Effect of new debtor becoming bound.] If a new debtor becomes bound as debtor by a security agreement entered into by another person: (1) the agreement satisfies subsection (b)(3) with respect to existing or after-acquired property of the new debtor to the extent the property is described in the agreement; and (2) another agreement is not necessary to make a security interest in the property enforceable. (f) [Proceeds and supporting obligations.] The attachment of a security interest in collateral gives the secured party the rights to proceeds provided by Section 9-315 and is also attachment of a security interest in a supporting obligation for the collateral. (g) [Lien securing right to payment.] The attachment of a security interest in a right to payment or performance secured by a security interest or other lien on personal or real property is also attachment of a security interest in the security interest, mortgage, or other lien. (h) [Security entitlement carried in securities account.] The attachment of a security interest in a securities account is also attachment of a security interest in the security entitlements carried in the securities account. (i) [Commodity contracts carried in commodity account.] The attachment of a security interest in a commodity account is also attachment of a security interest in the commodity contracts carried in the commodity account.",
 			"\u00ac\u00df 9-109. SCOPE. (a) [General scope of article.] Except as otherwise provided in subsections (c) and (d), this article applies to: (1) a transaction, regardless of its form, that creates a security interest in personal property or fixtures by contract; (2) an agricultural lien; (3) a sale of accounts, chattel paper, payment intangibles, or promissory notes; (4) a consignment; (5) a security interest arising under Section 2-401, 2-505, 2-711(3), or 2A-508(5), as provided in Section 9-110; and (6) a security interest arising under Section 4-210 or 5-118. (b) [Security interest in secured obligation.] The application of this article to a security interest in a secured obligation is not affected by the fact that the obligation is itself secured by a transaction or interest to which this article does not apply. (c) [Extent to which article does not apply.] This article does not apply to the extent that: (1) a statute, regulation, or treaty of the United States preempts this article; (2) another statute of this State expressly governs the creation, perfection, priority, or enforcement of a security interest created by this State or a governmental unit of this State; (3) a statute of another State, a foreign country, or a governmental unit of another State or a foreign country, other than a statute generally applicable to security interests, expressly governs creation, perfection, priority, or enforcement of a security interest created by the State, country, or governmental unit; or (4) the rights of a transferee beneficiary or nominated person under a letter of credit are independent and superior under Section 5-114. (d) [Inapplicability of article.] This article does not apply to: (1) a landlord's lien, other than an agricultural lien; (2) a lien, other than an agricultural lien, given by statute or other rule of law for services or materials, but Section 9-333 applies with respect to priority of the lien; (3) an assignment of a claim for wages, salary, or other compensation of an employee; (4) a sale of accounts, chattel paper, payment intangibles, or promissory notes as part of a sale of the business out of which they arose; (5) an assignment of accounts, chattel paper, payment intangibles, or promissory notes which is for the purpose of collection only; (6) an assignment of a right to payment under a contract to an assignee that is also obligated to perform under the contract; (7) an assignment of a single account, payment intangible, or promissory note to an assignee in full or partial satisfaction of a preexisting indebtedness; (8) a transfer of an interest in or an assignment of a claim under a policy of insurance, other than an assignment by or to a health-care provider of a health-care-insurance receivable and any subsequent assignment of the right to payment, but Sections 9-315 and 9-322 apply with respect to proceeds and priorities in proceeds; (9) an assignment of a right represented by a judgment, other than a judgment taken on a right to payment that was collateral; (10) a right of recoupment or set-off, but: (A) Section 9-340 applies with respect to the effectiveness of rights of recoupment or set-off against deposit accounts; and (B) Section 9-404 applies with respect to defenses or claims of an account debtor; (11) the creation or transfer of an interest in or lien on real property, including a lease or rents thereunder, except to the extent that provision is made for: (A) liens on real property in Sections 9-203 and 9-308; (B) fixtures in Section 9-334; (C) fixture filings in Sections 9-501, 9-502, 9-512, 9-516, and 9-519; and (D) security agreements covering personal and real property in Section 9-604; (12) an assignment of a claim arising in tort, other than a commercial tort claim, but Sections 9-315 and 9-322 apply with respect to proceeds and priorities in proceeds; or (13) an assignment of a deposit account in a consumer transaction, but Sections 9-315 and 9-322 apply with respect to proceeds and priorities in proceeds.",
 			"\u00ac\u00df 9-502. CONTENTS OF FINANCING STATEMENT; RECORD OF MORTGAGE AS FINANCING STATEMENT; TIME OF FILING FINANCING STATEMENT. (a) [Sufficiency of financing statement.] Subject to subsection (b), a financing statement is sufficient only if it: (1) provides the name of the debtor; (2) provides the name of the secured party or a representative of the secured party; and (3) indicates the collateral covered by the financing statement. (b) [Real-property-related financing statements.] Except as otherwise provided in Section 9-501(b), to be sufficient, a financing statement that covers as-extracted collateral or timber to be cut, or which is filed as a fixture filing and covers goods that are or are to become fixtures, must satisfy subsection (a) and also: (1) indicate that it covers this type of collateral; (2) indicate that it is to be filed [for record] in the real property records; (3) provide a description of the real property to which the collateral is related [sufficient to give constructive notice of a mortgage under the law of this State if the description were contained in a record of the mortgage of the real property]; and (4) if the debtor does not have an interest of record in the real property, provide the name of a record owner. (c) [Record of mortgage as financing statement.] A record of a mortgage is effective, from the date of recording, as a financing statement filed as a fixture filing or as a financing statement covering as-extracted collateral or timber to be cut only if: (1) the record indicates the goods or accounts that it covers; (2) the goods are or are to become fixtures related to the real property described in the record or the collateral is related to the real property described in the record and is as-extracted collateral or timber to be cut; (3) the record satisfies the requirements for a financing statement in this section, but (A) the record need not indicate that it is to be filed in the real property records; and (B) the record sufficiently provides the name of a debtor who is an individual if it provides the individual name of the debtor or the surname and first personal name of the debtor, even if the debtor is an individual to whom Section 9-503(a)(4) applies; and (4) the record is [duly] recorded. (d) [Filing before security agreement or attachment.] A financing statement may be filed before a security agreement is made or a security interest otherwise attaches. Legislative Note: Language in brackets is optional. Where the State has any special recording system for real property other than the usual grantor-grantee index (as, for instance, a tract system or a title registration or Torrens system) local adaptations of subsection (b) and Section 9-519(d) and (e) may be necessary. See, e.g., Mass. Gen. Laws Chapter 106, Section 9-410. A State should enact the 2010 amendments to Section 9-502 only if the State enacts Alternative A of the 2010 amendments to Section 9-503.",
-			"\u00ac\u00df 9-102. DEFINITIONS AND INDEX OF DEFINITIONS. (a) [Article 9 definitions.] In this article: (1) \"Accession\" means goods that are physically united with other goods in such a manner that the identity of the original goods is not lost. (2) \"Account\", except as used in \"account for\", means a right to payment of a monetary obligation, whether or not earned by performance, (i) for property that has been or is to be sold, leased, licensed, assigned, or otherwise disposed of, (ii) for services rendered or to be rendered, (iii) for a policy of insurance issued or to be issued, (iv) for a secondary obligation incurred or to be incurred, (v) for energy provided or to be provided, (vi) for the use or hire of a vessel under a charter or other contract, (vii) arising out of the use of a credit or charge card or information contained on or for use with the card, or (viii) as winnings in a lottery or other game of chance operated or sponsored by a State, governmental unit of a State, or person licensed or authorized to operate the game by a State or governmental unit of a State. The term includes health-care-insurance receivables. The term does not include (i) rights to payment evidenced by chattel paper or an instrument, (ii) commercial tort claims, (iii) deposit accounts, (iv) investment property, (v) letter-of-credit rights or letters of credit, or (vi) rights to payment for money or funds advanced or sold, other than rights arising out of the use of a credit or charge card or information contained on or for use with the card. (3) \"Account debtor\" means a person obligated on an account, chattel paper, or general intangible. The term does not include persons obligated to pay a negotiable instrument, even if the instrument constitutes part of chattel paper. (4) \"Accounting\", except as used in \"accounting for\", means a record: (A) authenticated by a secured party; (B) indicating the aggregate unpaid secured obligations as of a date not more than 35 days earlier or 35 days later than the date of the record; and (C) identifying the components of the obligations in reasonable detail. (5) \"Agricultural lien\" means an interest in farm products: (A) which secures payment or performance of an obligation for: (i) goods or services furnished in connection with a debtor's farming operation; or (ii) rent on real property leased by a debtor in connection with its farming operation; (B) which is created by statute in favor of a person that: (i) in the ordinary course of its business furnished goods or services to a debtor in connection with a debtor's farming operation; or (ii) leased real property to a debtor in connection with the debtor's farming operation; and (C) whose effectiveness does not depend on the person's possession of the personal property. (6) \"As-extracted collateral\" means: (A) oil, gas, or other minerals that are subject to a security interest that: (i) is created by a debtor having an interest in the minerals before extraction; and (ii) attaches to the minerals as extracted; or (B) accounts arising out of the sale at the wellhead or minehead of oil, gas, or other minerals in which the debtor had an interest before extraction. (7) \"Authenticate\" means: (A) to sign; or (B) with present intent to adopt or accept a record, to attach to or logically associate with the record an electronic sound, symbol, or process. (8) \"Bank\" means an organization that is engaged in the business of banking. The term includes savings banks, savings and loan associations, credit unions, and trust companies. (9) \"Cash proceeds\" means proceeds that are money, checks, deposit accounts, or the like. (10) \"Certificate of title\" means a certificate of title with respect to which a statute provides for the security interest in question to be indicated on the certificate as a condition or result of the security interest's obtaining priority over the rights of a lien creditor with respect to the collateral. The term includes another record maintained as an alternative to a certificate of title by the governmental unit that issues certificates of title if a statute permits the security interest in question to be indicated on the record as a condition or result of the security interest\u201a\u00c4\u00f4s obtaining priority over the rights of a lien creditor with respect to the collateral. (11) \"Chattel paper\" means a record or records that evidence both a monetary obligation and a security interest in specific goods, a security interest in specific goods and software used in the goods, a security interest in specific goods and license of software used in the goods, a lease of specific goods, or a lease of specific goods and license of software used in the goods. In this paragraph, \"monetary obligation\" means a monetary obligation secured by the goods or owed under a lease of the goods and includes a monetary obligation with respect to software used in the goods. The term does not include (i) charters or other contracts involving the use or hire of a vessel or (ii) records that evidence a right to payment arising out of the use of a credit or charge card or information contained on or for use with the card. If a transaction is evidenced by records that include an instrument or series of instruments, the group of records taken together constitutes chattel paper. (12) \"Collateral\" means the property subject to a security interest or agricultural lien. The term includes: (A) proceeds to which a security interest attaches; (B) accounts, chattel paper, payment intangibles, and promissory notes that have been sold; and (C) goods that are the subject of a consignment. (13) \"Commercial tort claim\" means a claim arising in tort with respect to which: (A) the claimant is an organization; or (B) the claimant is an individual and the claim: (i) arose in the course of the claimant's business or profession; and (ii) does not include damages arising out of personal injury to or the death of an individual. (14) \"Commodity account\" means an account maintained by a commodity intermediary in which a commodity contract is carried for a commodity customer. (15) \"Commodity contract\" means a commodity futures contract, an option on a commodity futures contract, a commodity option, or another contract if the contract or option is: (A) traded on or subject to the rules of a board of trade that has been designated as a contract market for such a contract pursuant to federal commodities laws; or (B) traded on a foreign commodity board of trade, exchange, or market, and is carried on the books of a commodity intermediary for a commodity customer. (16) \"Commodity customer\" means a person for which a commodity intermediary carries a commodity contract on its books. (17) \"Commodity intermediary\" means a person that: (A) is registered as a futures commission merchant under federal commodities law; or (B) in the ordinary course of its business provides clearance or settlement services for a board of trade that has been designated as a contract market pursuant to federal commodities law. (18) \"Communicate\" means: (A) to send a written or other tangible record; (B) to transmit a record by any means agreed upon by the persons sending and receiving the record; or (C) in the case of transmission of a record to or by a filing office, to transmit a record by any means prescribed by filing-office rule. (19) \"Consignee\" means a merchant to which goods are delivered in a consignment. (20) \"Consignment\" means a transaction, regardless of its form, in which a person delivers goods to a merchant for the purpose of sale and: (A) the merchant: (i) deals in goods of that kind under a name other than the name of the person making delivery; (ii) is not an auctioneer; and (iii) is not generally known by its creditors to be substantially engaged in selling the goods of others; (B) with respect to each delivery, the aggregate value of the goods is $1,000 or more at the time of delivery; (C) the goods are not consumer goods immediately before delivery; and (D) the transaction does not create a security interest that secures an obligation. (21) \"Consignor\" means a person that delivers goods to a consignee in a consignment. (22) \"Consumer debtor\" means a debtor in a consumer transaction. (23) \"Consumer goods\" means goods that are used or bought for use primarily for personal, family, or household purposes. (24) \"Consumer-goods transaction\" means a consumer transaction in which: (A) an individual incurs an obligation primarily for personal, family, or household purposes; and (B) a security interest in consumer goods secures the obligation. (25) \"Consumer obligor\" means an obligor who is an individual and who incurred the obligation as part of a transaction entered into primarily for personal, family, or household purposes. (26) \"Consumer transaction\" means a transaction in which (i) an individual incurs an obligation primarily for personal, family, or household purposes, (ii) a security interest secures the obligation, and (iii) the collateral is held or acquired primarily for personal, family, or household purposes. The term includes consumer-goods transactions. (27) \"Continuation statement\" means an amendment of a financing statement which: (A) identifies, by its file number, the initial financing statement to which it relates; and (B) indicates that it is a continuation statement for, or that it is filed to continue the effectiveness of, the identified financing statement. (28) \"Debtor\" means: (A) a person having an interest, other than a security interest or other lien, in the collateral, whether or not the person is an obligor; (B) a seller of accounts, chattel paper, payment intangibles, or promissory notes; or (C) a consignee. (29) \"Deposit account\" means a demand, time, savings, passbook, or similar account maintained with a bank. The term does not include investment property or accounts evidenced by an instrument. (30) \"Document\" means a document of title or a receipt of the type described in Section 7-201(2). (31) \"Electronic chattel paper\" means chattel paper evidenced by a record or records consisting of information stored in an electronic medium. (32) \"Encumbrance\" means a right, other than an ownership interest, in real property. The term includes mortgages and other liens on real property. (33) \"Equipment\" means goods other than inventory, farm products, or consumer goods. (34) \"Farm products\" means goods, other than standing timber, with respect to which the debtor is engaged in a farming operation and which are: (A) crops grown, growing, or to be grown, including: (i) crops produced on trees, vines, and bushes; and (ii) aquatic goods produced in aquacultural operations; (B) livestock, born or unborn, including aquatic goods produced in aquacultural operations; (C) supplies used or produced in a farming operation; or (D) products of crops or livestock in their unmanufactured states. (35) \"Farming operation\" means raising, cultivating, propagating, fattening, grazing, or any other farming, livestock, or aquacultural operation. (36) \"File number\" means the number assigned to an initial financing statement pursuant to Section 9-519(a). (37) \"Filing office\" means an office designated in Section 9-501 as the place to file a financing statement. (38) \"Filing-office rule\" means a rule adopted pursuant to Section 9-526. (39) \"Financing statement\" means a record or records composed of an initial financing statement and any filed record relating to the initial financing statement. (40) \"Fixture filing\" means the filing of a financing statement covering goods that are or are to become fixtures and satisfying Section 9-502(a) and (b). The term includes the filing of a financing statement covering goods of a transmitting utility which are or are to become fixtures. (41) \"Fixtures\" means goods that have become so related to particular real property that an interest in them arises under real property law. (42) \"General intangible\" means any personal property, including things in action, other than accounts, chattel paper, commercial tort claims, deposit accounts, documents, goods, instruments, investment property, letter-of-credit rights, letters of credit, money, and oil, gas, or other minerals before extraction. The term includes payment intangibles and software. (43) \"Good faith\" means honesty in fact and the observance of reasonable commercial standards of fair dealing. (44) \"Goods\" means all things that are movable when a security interest attaches. The term includes (i) fixtures, (ii) standing timber that is to be cut and removed under a conveyance or contract for sale, (iii) the unborn young of animals, (iv) crops grown, growing, or to be grown, even if the crops are produced on trees, vines, or bushes, and (v) manufactured homes. The term also includes a computer program embedded in goods and any supporting information provided in connection with a transaction relating to the program if (i) the program is associated with the goods in such a manner that it customarily is considered part of the goods, or (ii) by becoming the owner of the goods, a person acquires a right to use the program in connection with the goods. The term does not include a computer program embedded in goods that consist solely of the medium in which the program is embedded. The term also does not include accounts, chattel paper, commercial tort claims, deposit accounts, documents, general intangibles, instruments, investment property, letter-of-credit rights, letters of credit, money, or oil, gas, or other minerals before extraction. (45) \"Governmental unit\" means a subdivision, agency, department, county, parish, municipality, or other unit of the government of the United States, a State, or a foreign country. The term includes an organization having a separate corporate existence if the organization is eligible to issue debt on which interest is exempt from income taxation under the laws of the United States. (46) \"Health-care-insurance receivable\" means an interest in or claim under a policy of insurance which is a right to payment of a monetary obligation for health-care goods or services provided. (47) \"Instrument\" means a negotiable instrument or any other writing that evidences a right to the payment of a monetary obligation, is not itself a security agreement or lease, and is of a type that in ordinary course of business is transferred by delivery with any necessary indorsement or assignment. The term does not include (i) investment property, (ii) letters of credit, or (iii) writings that evidence a right to payment arising out of the use of a credit or charge card or information contained on or for use with the card. (48) \"Inventory\" means goods, other than farm products, which: (A) are leased by a person as lessor; (B) are held by a person for sale or lease or to be furnished under a contract of service; (C) are furnished by a person under a contract of service; or (D) consist of raw materials, work in process, or materials used or consumed in a business. (49) \"Investment property\" means a security, whether certificated or uncertificated, security entitlement, securities account, commodity contract, or commodity account. (50) \"Jurisdiction of organization\", with respect to a registered organization, means the jurisdiction under whose law the organization is formed or organized. (51) \"Letter-of-credit right\" means a right to payment or performance under a letter of credit, whether or not the beneficiary has demanded or is at the time entitled to demand payment or performance. The term does not include the right of a beneficiary to demand payment or performance under a letter of credit. (52) \"Lien creditor\" means: (A) a creditor that has acquired a lien on the property involved by attachment, levy, or the like; (B) an assignee for benefit of creditors from the time of assignment; (C) a trustee in bankruptcy from the date of the filing of the petition; or (D) a receiver in equity from the time of appointment. (53) \"Manufactured home\" means a structure, transportable in one or more sections, which, in the traveling mode, is eight body feet or more in width or 40 body feet or more in length, or, when erected on site, is 320 or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained therein. The term includes any structure that meets all of the requirements of this paragraph except the size requirements and with respect to which the manufacturer voluntarily files a certification required by the United States Secretary of Housing and Urban Development and complies with the standards established under Title 42 of the United States Code. (54) \"Manufactured-home transaction\" means a secured transaction: (A) that creates a purchase-money security interest in a manufactured home, other than a manufactured home held as inventory; or (B) in which a manufactured home, other than a manufactured home held as inventory, is the primary collateral. (55) \"Mortgage\" means a consensual interest in real property, including fixtures, which secures payment or performance of an obligation. (56) \"New debtor\" means a person that becomes bound as debtor under Section 9-203(d) by a security agreement previously entered into by another person. (57) \"New value\" means (i) money, (ii) money's worth in property, services, or new credit, or (iii) release by a transferee of an interest in property previously transferred to the transferee. The term does not include an obligation substituted for another obligation. (58) \"Noncash proceeds\" means proceeds other than cash proceeds. (59) \"Obligor\" means a person that, with respect to an obligation secured by a security interest in or an agricultural lien on the collateral, (i) owes payment or other performance of the obligation, (ii) has provided property other than the collateral to secure payment or other performance of the obligation, or (iii) is otherwise accountable in whole or in part for payment or other performance of the obligation. The term does not include issuers or nominated persons under a letter of credit. (60) \"Original debtor\", except as used in Section 9-310(c), means a person that, as debtor, entered into a security agreement to which a new debtor has become bound under Section 9-203(d). (61) \"Payment intangible\" means a general intangible under which the account debtor's principal obligation is a monetary obligation. (62) \"Person related to\", with respect to an individual, means: (A) the spouse of the individual; (B) a brother, brother-in-law, sister, or sister-in-law of the individual; (C) an ancestor or lineal descendant of the individual or the individual's spouse; or (D) any other relative, by blood or marriage, of the individual or the individual's spouse who shares the same home with the individual. (63) \"Person related to\", with respect to an organization, means: (A) a person directly or indirectly controlling, controlled by, or under common control with the organization; (B) an officer or director of, or a person performing similar functions with respect to, the organization; (C) an officer or director of, or a person performing similar functions with respect to, a person described in subparagraph (A); (D) the spouse of an individual described in subparagraph (A), (B), or (C); or (E) an individual who is related by blood or marriage to an individual described in subparagraph (A), (B), (C), or (D) and shares the same home with the individual. (64) \"Proceeds\", except as used in Section 9-609(b), means the following property: (A) whatever is acquired upon the sale, lease, license, exchange, or other disposition of collateral; (B) whatever is collected on, or distributed on account of, collateral; (C) rights arising out of collateral; (D) to the extent of the value of collateral, claims arising out of the loss, nonconformity, or interference with the use of, defects or infringement of rights in, or damage to, the collateral; or (E) to the extent of the value of collateral and to the extent payable to the debtor or the secured party, insurance payable by reason of the loss or nonconformity of, defects or infringement of rights in, or damage to, the collateral. (65) \"Promissory note\" means an instrument that evidences a promise to pay a monetary obligation, does not evidence an order to pay, and does not contain an acknowledgment by a bank that the bank has received for deposit a sum of money or funds. (66) \"Proposal\" means a record authenticated by a secured party which includes the terms on which the secured party is willing to accept collateral in full or partial satisfaction of the obligation it secures pursuant to Sections 9-620, 9-621, and 9-622. (67) \"Public-finance transaction\" means a secured transaction in connection with which: (A) debt securities are issued; (B) all or a portion of the securities issued have an initial stated maturity of at least 20 years; and (C) the debtor, obligor, secured party, account debtor or other person obligated on collateral, assignor or assignee of a secured obligation, or assignor or assignee of a security interest is a State or a governmental unit of a State. (68) \"Public organic record\" means a record that is available to the public for inspection and is: (A) a record consisting of the record initially filed with or issued by a State or the United States to form or organize an organization and any record filed with or issued by the State or the United States which amends or restates the initial record; (B) an organic record of a business trust consisting of the record initially filed with a State and any record filed with the State which amends or restates the initial record, if a statute of the State governing business trusts requires that the record be filed with the State; or (C) a record consisting of legislation enacted by the legislature of a State or the Congress of the United States which forms or organizes an organization, any record amending the legislation, and any record filed with or issued by the State or the United States which amends or restates the name of the organization. (69) \"Pursuant to commitment\", with respect to an advance made or other value given by a secured party, means pursuant to the secured party's obligation, whether or not a subsequent event of default or other event not within the secured party's control has relieved or may relieve the secured party from its obligation. (70) \"Record\", except as used in \"for record\", \"of record\", \"record or legal title\", and \"record owner\", means information that is inscribed on a tangible medium or which is stored in an electronic or other medium and is retrievable in perceivable form. (71) \"Registered organization\" means an organization organized solely under the law of a single State or the United States by the filing of a public organic record with, the issuance of a public organic record by, or the enactment of legislation by the State or the United States. The term includes a business trust that is formed or organized under the law of a single State if a statute of the State governing business trusts requires that the business trust\u201a\u00c4\u00f4s organic record be filed with the State. (72) \"Secondary obligor\" means an obligor to the extent that: (A) the obligor's obligation is secondary; or (B) the obligor has a right of recourse with respect to an obligation secured by collateral against the debtor, another obligor, or property of either. (73) \"Secured party\" means: (A) a person in whose favor a security interest is created or provided for under a security agreement, whether or not any obligation to be secured is outstanding; (B) a person that holds an agricultural lien; (C) a consignor; (D) a person to which accounts, chattel paper, payment intangibles, or promissory notes have been sold; (E) a trustee, indenture trustee, agent, collateral agent, or other representative in whose favor a security interest or agricultural lien is created or provided for; or (F) a person that holds a security interest arising under Section 2-401, 2-505, 2-711(3), 2A-508(5), 4-210, or 5-118. (74) \"Security agreement\" means an agreement that creates or provides for a security interest. (75) \"Send\", in connection with a record or notification, means: (A) to deposit in the mail, deliver for transmission, or transmit by any other usual means of communication, with postage or cost of transmission provided for, addressed to any address reasonable under the circumstances; or (B) to cause the record or notification to be received within the time that it would have been received if properly sent under subparagraph (A). (76) \"Software\" means a computer program and any supporting information provided in connection with a transaction relating to the program. The term does not include a computer program that is included in the definition of goods. (77) \"State\" means a State of the United States, the District of Columbia, Puerto Rico, the United States Virgin Islands, or any territory or insular possession subject to the jurisdiction of the United States. (78) \"Supporting obligation\" means a letter-of-credit right or secondary obligation that supports the payment or performance of an account, chattel paper, a document, a general intangible, an instrument, or investment property. (79) \"Tangible chattel paper\" means chattel paper evidenced by a record or records consisting of information that is inscribed on a tangible medium. (80) \"Termination statement\" means an amendment of a financing statement which: (A) identifies, by its file number, the initial financing statement to which it relates; and (B) indicates either that it is a termination statement or that the identified financing statement is no longer effective. (81) \"Transmitting utility\" means a person primarily engaged in the business of: (A) operating a railroad, subway, street railway, or trolley bus; (B) transmitting communications electrically, electromagnetically, or by light; (C) transmitting goods by pipeline or sewer; or (D) transmitting or producing and transmitting electricity, steam, gas, or water. (b) [Definitions in other articles.] The following definitions in other articles apply to this article: \"Applicant\" Section 5-102. \"Beneficiary\" Section 5-102. \"Broker\" Section 8-102. \"Certificated security\" Section 8-102. \"Check\" Section 3-104. \"Clearing corporation\" Section 8-102. \"Contract for sale\" Section 2-106. \"Customer\" Section 4-104. \"Entitlement holder\" Section 8-102. \"Financial asset\" Section 8-102. \"Holder in due course\" Section 3-302. \"Issuer\" (with respect to a letter of credit or letter-of-credit right) Section 5-102. \"Issuer\" (with respect to a security) Section 8-201. \"Issuer\" (with respect to documents of title) Section 7-102. \"Lease\" Section 2A-103. \"Lease agreement\" Section 2A-103. \"Lease contract\" Section 2A-103. \"Leasehold interest\" Section 2A-103. \"Lessee\" Section 2A-103. \"Lessee in ordinary course of business\" Section 2A-103. \"Lessor\" Section 2A-103. \"Lessor's residual interest\" Section 2A-103. \"Letter of credit\" Section 5-102. \"Merchant\" Section 2-104. \"Negotiable instrument\" Section 3-104. \"Nominated person\" Section 5-102. \"Note\" Section 3-104. \"Proceeds of a letter of credit\" Section 5-114. \"Prove\" Section 3-103. \"Sale\" Section 2-106. \"Securities account\" Section 8-501. \"Securities intermediary\" Section 8-102. \"Security\" Section 8-102. \"Security certificate\" Section 8-102. \"Security entitlement\" Section 8-102. \"Uncertificated security\" Section 8-102. (c) [Article 1 definitions and principles.] Article 1 contains general definitions and principles of construction and interpretation applicable throughout this article.",
-			"\u00ac\u00df 9-315. SECURED PARTY\u201a\u00c4\u00f4S RIGHTS ON DISPOSITION OF COLLATERAL AND IN PROCEEDS. (a) [Disposition of collateral: continuation of security interest or agricultural lien; proceeds.] Except as otherwise provided in this article and in Section 2-403(2): (1) a security interest or agricultural lien continues in collateral notwithstanding sale, lease, license, exchange, or other disposition thereof unless the secured party authorized the disposition free of the security interest or agricultural lien; and (2) a security interest attaches to any identifiable proceeds of collateral. (b) [When commingled proceeds identifiable.] Proceeds that are commingled with other property are identifiable proceeds: (1) if the proceeds are goods, to the extent provided by Section 9-336; and (2) if the proceeds are not goods, to the extent that the secured party identifies the proceeds by a method of tracing, including application of equitable principles, that is permitted under law other than this article with respect to commingled property of the type involved. (c) [Perfection of security interest in proceeds.] A security interest in proceeds is a perfected security interest if the security interest in the original collateral was perfected. (d) [Continuation of perfection.] A perfected security interest in proceeds becomes unperfected on the 21st day after the security interest attaches to the proceeds unless: (1) the following conditions are satisfied: (A) a filed financing statement covers the original collateral; (B) the proceeds are collateral in which a security interest may be perfected by filing in the office in which the financing statement has been filed; and (C) the proceeds are not acquired with cash proceeds; (2) the proceeds are identifiable cash proceeds; or (3) the security interest in the proceeds is perfected other than under subsection (c) when the security interest attaches to the proceeds or within 20 days thereafter. (e) [When perfected security interest in proceeds becomes unperfected.] If a filed financing statement covers the original collateral, a security interest in proceeds which remains perfected under subsection (d)(1) becomes unperfected at the later of: (1) when the effectiveness of the filed financing statement lapses under Section 9-515 or is terminated under Section 9-513; or (2) the 21st day after the security interest attaches to the proceeds.",
+			"\u00ac\u00df 9-102. DEFINITIONS AND INDEX OF DEFINITIONS. (a) [Article 9 definitions.] In this article: (1) \"Accession\" means goods that are physically united with other goods in such a manner that the identity of the original goods is not lost. (2) \"Account\", except as used in \"account for\", means a right to payment of a monetary obligation, whether or not earned by performance, (i) for property that has been or is to be sold, leased, licensed, assigned, or otherwise disposed of, (ii) for services rendered or to be rendered, (iii) for a policy of insurance issued or to be issued, (iv) for a secondary obligation incurred or to be incurred, (v) for energy provided or to be provided, (vi) for the use or hire of a vessel under a charter or other contract, (vii) arising out of the use of a credit or charge card or information contained on or for use with the card, or (viii) as winnings in a lottery or other game of chance operated or sponsored by a State, governmental unit of a State, or person licensed or authorized to operate the game by a State or governmental unit of a State. The term includes health-care-insurance receivables. The term does not include (i) rights to payment evidenced by chattel paper or an instrument, (ii) commercial tort claims, (iii) deposit accounts, (iv) investment property, (v) letter-of-credit rights or letters of credit, or (vi) rights to payment for money or funds advanced or sold, other than rights arising out of the use of a credit or charge card or information contained on or for use with the card. (3) \"Account debtor\" means a person obligated on an account, chattel paper, or general intangible. The term does not include persons obligated to pay a negotiable instrument, even if the instrument constitutes part of chattel paper. (4) \"Accounting\", except as used in \"accounting for\", means a record: (A) authenticated by a secured party; (B) indicating the aggregate unpaid secured obligations as of a date not more than 35 days earlier or 35 days later than the date of the record; and (C) identifying the components of the obligations in reasonable detail. (5) \"Agricultural lien\" means an interest in farm products: (A) which secures payment or performance of an obligation for: (i) goods or services furnished in connection with a debtor's farming operation; or (ii) rent on real property leased by a debtor in connection with its farming operation; (B) which is created by statute in favor of a person that: (i) in the ordinary course of its business furnished goods or services to a debtor in connection with a debtor's farming operation; or (ii) leased real property to a debtor in connection with the debtor's farming operation; and (C) whose effectiveness does not depend on the person's possession of the personal property. (6) \"As-extracted collateral\" means: (A) oil, gas, or other minerals that are subject to a security interest that: (i) is created by a debtor having an interest in the minerals before extraction; and (ii) attaches to the minerals as extracted; or (B) accounts arising out of the sale at the wellhead or minehead of oil, gas, or other minerals in which the debtor had an interest before extraction. (7) \"Authenticate\" means: (A) to sign; or (B) with present intent to adopt or accept a record, to attach to or logically associate with the record an electronic sound, symbol, or process. (8) \"Bank\" means an organization that is engaged in the business of banking. The term includes savings banks, savings and loan associations, credit unions, and trust companies. (9) \"Cash proceeds\" means proceeds that are money, checks, deposit accounts, or the like. (10) \"Certificate of title\" means a certificate of title with respect to which a statute provides for the security interest in question to be indicated on the certificate as a condition or result of the security interest's obtaining priority over the rights of a lien creditor with respect to the collateral. The term includes another record maintained as an alternative to a certificate of title by the governmental unit that issues certificates of title if a statute permits the security interest in question to be indicated on the record as a condition or result of the security interest's obtaining priority over the rights of a lien creditor with respect to the collateral. (11) \"Chattel paper\" means a record or records that evidence both a monetary obligation and a security interest in specific goods, a security interest in specific goods and software used in the goods, a security interest in specific goods and license of software used in the goods, a lease of specific goods, or a lease of specific goods and license of software used in the goods. In this paragraph, \"monetary obligation\" means a monetary obligation secured by the goods or owed under a lease of the goods and includes a monetary obligation with respect to software used in the goods. The term does not include (i) charters or other contracts involving the use or hire of a vessel or (ii) records that evidence a right to payment arising out of the use of a credit or charge card or information contained on or for use with the card. If a transaction is evidenced by records that include an instrument or series of instruments, the group of records taken together constitutes chattel paper. (12) \"Collateral\" means the property subject to a security interest or agricultural lien. The term includes: (A) proceeds to which a security interest attaches; (B) accounts, chattel paper, payment intangibles, and promissory notes that have been sold; and (C) goods that are the subject of a consignment. (13) \"Commercial tort claim\" means a claim arising in tort with respect to which: (A) the claimant is an organization; or (B) the claimant is an individual and the claim: (i) arose in the course of the claimant's business or profession; and (ii) does not include damages arising out of personal injury to or the death of an individual. (14) \"Commodity account\" means an account maintained by a commodity intermediary in which a commodity contract is carried for a commodity customer. (15) \"Commodity contract\" means a commodity futures contract, an option on a commodity futures contract, a commodity option, or another contract if the contract or option is: (A) traded on or subject to the rules of a board of trade that has been designated as a contract market for such a contract pursuant to federal commodities laws; or (B) traded on a foreign commodity board of trade, exchange, or market, and is carried on the books of a commodity intermediary for a commodity customer. (16) \"Commodity customer\" means a person for which a commodity intermediary carries a commodity contract on its books. (17) \"Commodity intermediary\" means a person that: (A) is registered as a futures commission merchant under federal commodities law; or (B) in the ordinary course of its business provides clearance or settlement services for a board of trade that has been designated as a contract market pursuant to federal commodities law. (18) \"Communicate\" means: (A) to send a written or other tangible record; (B) to transmit a record by any means agreed upon by the persons sending and receiving the record; or (C) in the case of transmission of a record to or by a filing office, to transmit a record by any means prescribed by filing-office rule. (19) \"Consignee\" means a merchant to which goods are delivered in a consignment. (20) \"Consignment\" means a transaction, regardless of its form, in which a person delivers goods to a merchant for the purpose of sale and: (A) the merchant: (i) deals in goods of that kind under a name other than the name of the person making delivery; (ii) is not an auctioneer; and (iii) is not generally known by its creditors to be substantially engaged in selling the goods of others; (B) with respect to each delivery, the aggregate value of the goods is $1,000 or more at the time of delivery; (C) the goods are not consumer goods immediately before delivery; and (D) the transaction does not create a security interest that secures an obligation. (21) \"Consignor\" means a person that delivers goods to a consignee in a consignment. (22) \"Consumer debtor\" means a debtor in a consumer transaction. (23) \"Consumer goods\" means goods that are used or bought for use primarily for personal, family, or household purposes. (24) \"Consumer-goods transaction\" means a consumer transaction in which: (A) an individual incurs an obligation primarily for personal, family, or household purposes; and (B) a security interest in consumer goods secures the obligation. (25) \"Consumer obligor\" means an obligor who is an individual and who incurred the obligation as part of a transaction entered into primarily for personal, family, or household purposes. (26) \"Consumer transaction\" means a transaction in which (i) an individual incurs an obligation primarily for personal, family, or household purposes, (ii) a security interest secures the obligation, and (iii) the collateral is held or acquired primarily for personal, family, or household purposes. The term includes consumer-goods transactions. (27) \"Continuation statement\" means an amendment of a financing statement which: (A) identifies, by its file number, the initial financing statement to which it relates; and (B) indicates that it is a continuation statement for, or that it is filed to continue the effectiveness of, the identified financing statement. (28) \"Debtor\" means: (A) a person having an interest, other than a security interest or other lien, in the collateral, whether or not the person is an obligor; (B) a seller of accounts, chattel paper, payment intangibles, or promissory notes; or (C) a consignee. (29) \"Deposit account\" means a demand, time, savings, passbook, or similar account maintained with a bank. The term does not include investment property or accounts evidenced by an instrument. (30) \"Document\" means a document of title or a receipt of the type described in Section 7-201(2). (31) \"Electronic chattel paper\" means chattel paper evidenced by a record or records consisting of information stored in an electronic medium. (32) \"Encumbrance\" means a right, other than an ownership interest, in real property. The term includes mortgages and other liens on real property. (33) \"Equipment\" means goods other than inventory, farm products, or consumer goods. (34) \"Farm products\" means goods, other than standing timber, with respect to which the debtor is engaged in a farming operation and which are: (A) crops grown, growing, or to be grown, including: (i) crops produced on trees, vines, and bushes; and (ii) aquatic goods produced in aquacultural operations; (B) livestock, born or unborn, including aquatic goods produced in aquacultural operations; (C) supplies used or produced in a farming operation; or (D) products of crops or livestock in their unmanufactured states. (35) \"Farming operation\" means raising, cultivating, propagating, fattening, grazing, or any other farming, livestock, or aquacultural operation. (36) \"File number\" means the number assigned to an initial financing statement pursuant to Section 9-519(a). (37) \"Filing office\" means an office designated in Section 9-501 as the place to file a financing statement. (38) \"Filing-office rule\" means a rule adopted pursuant to Section 9-526. (39) \"Financing statement\" means a record or records composed of an initial financing statement and any filed record relating to the initial financing statement. (40) \"Fixture filing\" means the filing of a financing statement covering goods that are or are to become fixtures and satisfying Section 9-502(a) and (b). The term includes the filing of a financing statement covering goods of a transmitting utility which are or are to become fixtures. (41) \"Fixtures\" means goods that have become so related to particular real property that an interest in them arises under real property law. (42) \"General intangible\" means any personal property, including things in action, other than accounts, chattel paper, commercial tort claims, deposit accounts, documents, goods, instruments, investment property, letter-of-credit rights, letters of credit, money, and oil, gas, or other minerals before extraction. The term includes payment intangibles and software. (43) \"Good faith\" means honesty in fact and the observance of reasonable commercial standards of fair dealing. (44) \"Goods\" means all things that are movable when a security interest attaches. The term includes (i) fixtures, (ii) standing timber that is to be cut and removed under a conveyance or contract for sale, (iii) the unborn young of animals, (iv) crops grown, growing, or to be grown, even if the crops are produced on trees, vines, or bushes, and (v) manufactured homes. The term also includes a computer program embedded in goods and any supporting information provided in connection with a transaction relating to the program if (i) the program is associated with the goods in such a manner that it customarily is considered part of the goods, or (ii) by becoming the owner of the goods, a person acquires a right to use the program in connection with the goods. The term does not include a computer program embedded in goods that consist solely of the medium in which the program is embedded. The term also does not include accounts, chattel paper, commercial tort claims, deposit accounts, documents, general intangibles, instruments, investment property, letter-of-credit rights, letters of credit, money, or oil, gas, or other minerals before extraction. (45) \"Governmental unit\" means a subdivision, agency, department, county, parish, municipality, or other unit of the government of the United States, a State, or a foreign country. The term includes an organization having a separate corporate existence if the organization is eligible to issue debt on which interest is exempt from income taxation under the laws of the United States. (46) \"Health-care-insurance receivable\" means an interest in or claim under a policy of insurance which is a right to payment of a monetary obligation for health-care goods or services provided. (47) \"Instrument\" means a negotiable instrument or any other writing that evidences a right to the payment of a monetary obligation, is not itself a security agreement or lease, and is of a type that in ordinary course of business is transferred by delivery with any necessary indorsement or assignment. The term does not include (i) investment property, (ii) letters of credit, or (iii) writings that evidence a right to payment arising out of the use of a credit or charge card or information contained on or for use with the card. (48) \"Inventory\" means goods, other than farm products, which: (A) are leased by a person as lessor; (B) are held by a person for sale or lease or to be furnished under a contract of service; (C) are furnished by a person under a contract of service; or (D) consist of raw materials, work in process, or materials used or consumed in a business. (49) \"Investment property\" means a security, whether certificated or uncertificated, security entitlement, securities account, commodity contract, or commodity account. (50) \"Jurisdiction of organization\", with respect to a registered organization, means the jurisdiction under whose law the organization is formed or organized. (51) \"Letter-of-credit right\" means a right to payment or performance under a letter of credit, whether or not the beneficiary has demanded or is at the time entitled to demand payment or performance. The term does not include the right of a beneficiary to demand payment or performance under a letter of credit. (52) \"Lien creditor\" means: (A) a creditor that has acquired a lien on the property involved by attachment, levy, or the like; (B) an assignee for benefit of creditors from the time of assignment; (C) a trustee in bankruptcy from the date of the filing of the petition; or (D) a receiver in equity from the time of appointment. (53) \"Manufactured home\" means a structure, transportable in one or more sections, which, in the traveling mode, is eight body feet or more in width or 40 body feet or more in length, or, when erected on site, is 320 or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained therein. The term includes any structure that meets all of the requirements of this paragraph except the size requirements and with respect to which the manufacturer voluntarily files a certification required by the United States Secretary of Housing and Urban Development and complies with the standards established under Title 42 of the United States Code. (54) \"Manufactured-home transaction\" means a secured transaction: (A) that creates a purchase-money security interest in a manufactured home, other than a manufactured home held as inventory; or (B) in which a manufactured home, other than a manufactured home held as inventory, is the primary collateral. (55) \"Mortgage\" means a consensual interest in real property, including fixtures, which secures payment or performance of an obligation. (56) \"New debtor\" means a person that becomes bound as debtor under Section 9-203(d) by a security agreement previously entered into by another person. (57) \"New value\" means (i) money, (ii) money's worth in property, services, or new credit, or (iii) release by a transferee of an interest in property previously transferred to the transferee. The term does not include an obligation substituted for another obligation. (58) \"Noncash proceeds\" means proceeds other than cash proceeds. (59) \"Obligor\" means a person that, with respect to an obligation secured by a security interest in or an agricultural lien on the collateral, (i) owes payment or other performance of the obligation, (ii) has provided property other than the collateral to secure payment or other performance of the obligation, or (iii) is otherwise accountable in whole or in part for payment or other performance of the obligation. The term does not include issuers or nominated persons under a letter of credit. (60) \"Original debtor\", except as used in Section 9-310(c), means a person that, as debtor, entered into a security agreement to which a new debtor has become bound under Section 9-203(d). (61) \"Payment intangible\" means a general intangible under which the account debtor's principal obligation is a monetary obligation. (62) \"Person related to\", with respect to an individual, means: (A) the spouse of the individual; (B) a brother, brother-in-law, sister, or sister-in-law of the individual; (C) an ancestor or lineal descendant of the individual or the individual's spouse; or (D) any other relative, by blood or marriage, of the individual or the individual's spouse who shares the same home with the individual. (63) \"Person related to\", with respect to an organization, means: (A) a person directly or indirectly controlling, controlled by, or under common control with the organization; (B) an officer or director of, or a person performing similar functions with respect to, the organization; (C) an officer or director of, or a person performing similar functions with respect to, a person described in subparagraph (A); (D) the spouse of an individual described in subparagraph (A), (B), or (C); or (E) an individual who is related by blood or marriage to an individual described in subparagraph (A), (B), (C), or (D) and shares the same home with the individual. (64) \"Proceeds\", except as used in Section 9-609(b), means the following property: (A) whatever is acquired upon the sale, lease, license, exchange, or other disposition of collateral; (B) whatever is collected on, or distributed on account of, collateral; (C) rights arising out of collateral; (D) to the extent of the value of collateral, claims arising out of the loss, nonconformity, or interference with the use of, defects or infringement of rights in, or damage to, the collateral; or (E) to the extent of the value of collateral and to the extent payable to the debtor or the secured party, insurance payable by reason of the loss or nonconformity of, defects or infringement of rights in, or damage to, the collateral. (65) \"Promissory note\" means an instrument that evidences a promise to pay a monetary obligation, does not evidence an order to pay, and does not contain an acknowledgment by a bank that the bank has received for deposit a sum of money or funds. (66) \"Proposal\" means a record authenticated by a secured party which includes the terms on which the secured party is willing to accept collateral in full or partial satisfaction of the obligation it secures pursuant to Sections 9-620, 9-621, and 9-622. (67) \"Public-finance transaction\" means a secured transaction in connection with which: (A) debt securities are issued; (B) all or a portion of the securities issued have an initial stated maturity of at least 20 years; and (C) the debtor, obligor, secured party, account debtor or other person obligated on collateral, assignor or assignee of a secured obligation, or assignor or assignee of a security interest is a State or a governmental unit of a State. (68) \"Public organic record\" means a record that is available to the public for inspection and is: (A) a record consisting of the record initially filed with or issued by a State or the United States to form or organize an organization and any record filed with or issued by the State or the United States which amends or restates the initial record; (B) an organic record of a business trust consisting of the record initially filed with a State and any record filed with the State which amends or restates the initial record, if a statute of the State governing business trusts requires that the record be filed with the State; or (C) a record consisting of legislation enacted by the legislature of a State or the Congress of the United States which forms or organizes an organization, any record amending the legislation, and any record filed with or issued by the State or the United States which amends or restates the name of the organization. (69) \"Pursuant to commitment\", with respect to an advance made or other value given by a secured party, means pursuant to the secured party's obligation, whether or not a subsequent event of default or other event not within the secured party's control has relieved or may relieve the secured party from its obligation. (70) \"Record\", except as used in \"for record\", \"of record\", \"record or legal title\", and \"record owner\", means information that is inscribed on a tangible medium or which is stored in an electronic or other medium and is retrievable in perceivable form. (71) \"Registered organization\" means an organization organized solely under the law of a single State or the United States by the filing of a public organic record with, the issuance of a public organic record by, or the enactment of legislation by the State or the United States. The term includes a business trust that is formed or organized under the law of a single State if a statute of the State governing business trusts requires that the business trust's organic record be filed with the State. (72) \"Secondary obligor\" means an obligor to the extent that: (A) the obligor's obligation is secondary; or (B) the obligor has a right of recourse with respect to an obligation secured by collateral against the debtor, another obligor, or property of either. (73) \"Secured party\" means: (A) a person in whose favor a security interest is created or provided for under a security agreement, whether or not any obligation to be secured is outstanding; (B) a person that holds an agricultural lien; (C) a consignor; (D) a person to which accounts, chattel paper, payment intangibles, or promissory notes have been sold; (E) a trustee, indenture trustee, agent, collateral agent, or other representative in whose favor a security interest or agricultural lien is created or provided for; or (F) a person that holds a security interest arising under Section 2-401, 2-505, 2-711(3), 2A-508(5), 4-210, or 5-118. (74) \"Security agreement\" means an agreement that creates or provides for a security interest. (75) \"Send\", in connection with a record or notification, means: (A) to deposit in the mail, deliver for transmission, or transmit by any other usual means of communication, with postage or cost of transmission provided for, addressed to any address reasonable under the circumstances; or (B) to cause the record or notification to be received within the time that it would have been received if properly sent under subparagraph (A). (76) \"Software\" means a computer program and any supporting information provided in connection with a transaction relating to the program. The term does not include a computer program that is included in the definition of goods. (77) \"State\" means a State of the United States, the District of Columbia, Puerto Rico, the United States Virgin Islands, or any territory or insular possession subject to the jurisdiction of the United States. (78) \"Supporting obligation\" means a letter-of-credit right or secondary obligation that supports the payment or performance of an account, chattel paper, a document, a general intangible, an instrument, or investment property. (79) \"Tangible chattel paper\" means chattel paper evidenced by a record or records consisting of information that is inscribed on a tangible medium. (80) \"Termination statement\" means an amendment of a financing statement which: (A) identifies, by its file number, the initial financing statement to which it relates; and (B) indicates either that it is a termination statement or that the identified financing statement is no longer effective. (81) \"Transmitting utility\" means a person primarily engaged in the business of: (A) operating a railroad, subway, street railway, or trolley bus; (B) transmitting communications electrically, electromagnetically, or by light; (C) transmitting goods by pipeline or sewer; or (D) transmitting or producing and transmitting electricity, steam, gas, or water. (b) [Definitions in other articles.] The following definitions in other articles apply to this article: \"Applicant\" Section 5-102. \"Beneficiary\" Section 5-102. \"Broker\" Section 8-102. \"Certificated security\" Section 8-102. \"Check\" Section 3-104. \"Clearing corporation\" Section 8-102. \"Contract for sale\" Section 2-106. \"Customer\" Section 4-104. \"Entitlement holder\" Section 8-102. \"Financial asset\" Section 8-102. \"Holder in due course\" Section 3-302. \"Issuer\" (with respect to a letter of credit or letter-of-credit right) Section 5-102. \"Issuer\" (with respect to a security) Section 8-201. \"Issuer\" (with respect to documents of title) Section 7-102. \"Lease\" Section 2A-103. \"Lease agreement\" Section 2A-103. \"Lease contract\" Section 2A-103. \"Leasehold interest\" Section 2A-103. \"Lessee\" Section 2A-103. \"Lessee in ordinary course of business\" Section 2A-103. \"Lessor\" Section 2A-103. \"Lessor's residual interest\" Section 2A-103. \"Letter of credit\" Section 5-102. \"Merchant\" Section 2-104. \"Negotiable instrument\" Section 3-104. \"Nominated person\" Section 5-102. \"Note\" Section 3-104. \"Proceeds of a letter of credit\" Section 5-114. \"Prove\" Section 3-103. \"Sale\" Section 2-106. \"Securities account\" Section 8-501. \"Securities intermediary\" Section 8-102. \"Security\" Section 8-102. \"Security certificate\" Section 8-102. \"Security entitlement\" Section 8-102. \"Uncertificated security\" Section 8-102. (c) [Article 1 definitions and principles.] Article 1 contains general definitions and principles of construction and interpretation applicable throughout this article.",
+			"\u00ac\u00df 9-315. SECURED PARTY'S RIGHTS ON DISPOSITION OF COLLATERAL AND IN PROCEEDS. (a) [Disposition of collateral: continuation of security interest or agricultural lien; proceeds.] Except as otherwise provided in this article and in Section 2-403(2): (1) a security interest or agricultural lien continues in collateral notwithstanding sale, lease, license, exchange, or other disposition thereof unless the secured party authorized the disposition free of the security interest or agricultural lien; and (2) a security interest attaches to any identifiable proceeds of collateral. (b) [When commingled proceeds identifiable.] Proceeds that are commingled with other property are identifiable proceeds: (1) if the proceeds are goods, to the extent provided by Section 9-336; and (2) if the proceeds are not goods, to the extent that the secured party identifies the proceeds by a method of tracing, including application of equitable principles, that is permitted under law other than this article with respect to commingled property of the type involved. (c) [Perfection of security interest in proceeds.] A security interest in proceeds is a perfected security interest if the security interest in the original collateral was perfected. (d) [Continuation of perfection.] A perfected security interest in proceeds becomes unperfected on the 21st day after the security interest attaches to the proceeds unless: (1) the following conditions are satisfied: (A) a filed financing statement covers the original collateral; (B) the proceeds are collateral in which a security interest may be perfected by filing in the office in which the financing statement has been filed; and (C) the proceeds are not acquired with cash proceeds; (2) the proceeds are identifiable cash proceeds; or (3) the security interest in the proceeds is perfected other than under subsection (c) when the security interest attaches to the proceeds or within 20 days thereafter. (e) [When perfected security interest in proceeds becomes unperfected.] If a filed financing statement covers the original collateral, a security interest in proceeds which remains perfected under subsection (d)(1) becomes unperfected at the later of: (1) when the effectiveness of the filed financing statement lapses under Section 9-515 or is terminated under Section 9-513; or (2) the 21st day after the security interest attaches to the proceeds.",
 			"\u00ac\u00df 9-311. PERFECTION OF SECURITY INTERESTS IN PROPERTY SUBJECT TO CERTAIN STATUTES, REGULATIONS, AND TREATIES. (a) [Security interest subject to other law.] Except as otherwise provided in subsection (d), the filing of a financing statement is not necessary or effective to perfect a security interest in property subject to: (1) a statute, regulation, or treaty of the United States whose requirements for a security interest's obtaining priority over the rights of a lien creditor with respect to the property preempt Section 9-310(a); (2) [list any statute covering automobiles, trailers, mobile homes, boats, farm tractors, or the like, which provides for a security interest to be indicated on a certificate of title as a condition or result of perfection, and any non-Uniform Commercial Code central filing statute]; or (3) a statute of another jurisdiction which provides for a security interest to be indicated on a certificate of title as a condition or result of the security interest's obtaining priority over the rights of a lien creditor with respect to the property. (b) [Compliance with other law.] Compliance with the requirements of a statute, regulation, or treaty described in subsection (a) for obtaining priority over the rights of a lien creditor is equivalent to the filing of a financing statement under this article. Except as otherwise provided in subsection (d) and Sections 9-313 and 9-316(d) and (e) for goods covered by a certificate of title, a security interest in property subject to a statute, regulation, or treaty described in subsection (a) may be perfected only by compliance with those requirements, and a security interest so perfected remains perfected notwithstanding a change in the use or transfer of possession of the collateral. (c) [Duration and renewal of perfection.] Except as otherwise provided in subsection (d) and Section 9-316(d) and (e), duration and renewal of perfection of a security interest perfected by compliance with the requirements prescribed by a statute, regulation, or treaty described in subsection (a) are governed by the statute, regulation, or treaty. In other respects, the security interest is subject to this article. (d) [Inapplicability to certain inventory.] During any period in which collateral subject to a statute specified in subsection (a)(2) is inventory held for sale or lease by a person or leased by that person as lessor and that person is in the business of selling goods of that kind, this section does not apply to a security interest in that collateral created by that person. Legislative Note: This Article contemplates that perfection of a security interest in goods covered by a certificate of title occurs upon receipt by appropriate State officials of a properly tendered application for a certificate of title on which the security interest is to be indicated, without a relation back to an earlier time. States whose certificate-of-title statutes provide for perfection at a different time or contain a relation-back provision should amend the statutes accordingly.",
 			"\u00ac\u00df 9-324. PRIORITY OF PURCHASE-MONEY SECURITY INTERESTS. (a) [General rule: purchase-money priority.] Except as otherwise provided in subsection (g), a perfected purchase-money security interest in goods other than inventory or livestock has priority over a conflicting security interest in the same goods, and, except as otherwise provided in Section 9-327, a perfected security interest in its identifiable proceeds also has priority, if the purchase-money security interest is perfected when the debtor receives possession of the collateral or within 20 days thereafter. (b) [Inventory purchase-money priority.] Subject to subsection (c) and except as otherwise provided in subsection (g), a perfected purchase-money security interest in inventory has priority over a conflicting security interest in the same inventory, has priority over a conflicting security interest in chattel paper or an instrument constituting proceeds of the inventory and in proceeds of the chattel paper, if so provided in Section 9-330, and, except as otherwise provided in Section 9-327, also has priority in identifiable cash proceeds of the inventory to the extent the identifiable cash proceeds are received on or before the delivery of the inventory to a buyer, if: (1) the purchase-money security interest is perfected when the debtor receives possession of the inventory; (2) the purchase-money secured party sends an authenticated notification to the holder of the conflicting security interest; (3) the holder of the conflicting security interest receives the notification within five years before the debtor receives possession of the inventory; and (4) the notification states that the person sending the notification has or expects to acquire a purchase-money security interest in inventory of the debtor and describes the inventory. (c) [Holders of conflicting inventory security interests to be notified.] Subsections (b)(2) through (4) apply only if the holder of the conflicting security interest had filed a financing statement covering the same types of inventory: (1) if the purchase-money security interest is perfected by filing, before the date of the filing; or (2) if the purchase-money security interest is temporarily perfected without filing or possession under Section 9-312(f), before the beginning of the 20-day period thereunder. (d) [Livestock purchase-money priority.] Subject to subsection (e) and except as otherwise provided in subsection (g), a perfected purchase-money security interest in livestock that are farm products has priority over a conflicting security interest in the same livestock, and, except as otherwise provided in Section 9-327, a perfected security interest in their identifiable proceeds and identifiable products in their unmanufactured states also has priority, if: (1) the purchase-money security interest is perfected when the debtor receives possession of the livestock; (2) the purchase-money secured party sends an authenticated notification to the holder of the conflicting security interest; (3) the holder of the conflicting security interest receives the notification within six months before the debtor receives possession of the livestock; and (4) the notification states that the person sending the notification has or expects to acquire a purchase-money security interest in livestock of the debtor and describes the livestock. (e) [Holders of conflicting livestock security interests to be notified.] Subsections (d)(2) through (4) apply only if the holder of the conflicting security interest had filed a financing statement covering the same types of livestock: (1) if the purchase-money security interest is perfected by filing, before the date of the filing; or (2) if the purchase-money security interest is temporarily perfected without filing or possession under Section 9-312(f), before the beginning of the 20-day period thereunder. (f) [Software purchase-money priority.] Except as otherwise provided in subsection (g), a perfected purchase-money security interest in software has priority over a conflicting security interest in the same collateral, and, except as otherwise provided in Section 9-327, a perfected security interest in its identifiable proceeds also has priority, to the extent that the purchase-money security interest in the goods in which the software was acquired for use has priority in the goods and proceeds of the goods under this section. (g) [Conflicting purchase-money security interests.] If more than one security interest qualifies for priority in the same collateral under subsection (a), (b), (d), or (f): (1) a security interest securing an obligation incurred as all or part of the price of the collateral has priority over a security interest securing an obligation incurred for value given to enable the debtor to acquire rights in or the use of collateral; and (2) in all other cases, Section 9-322(a) applies to the qualifying security interests."
 		],
@@ -503,7 +503,7 @@
 		],
 		"generation_e5":"The primary high-level legal principle relevant here is the \"presumption in favor of judicial review,\" which the passages emphasize extensively. The principle establishes that courts should maintain the authority to review legislative and executive actions unless there is clear and convincing evidence that Congress intended to remove such judicial oversight. This presumption helps ensure that constitutional issues can be addressed by the judiciary, safeguarding the separation of powers and constitutional protections. Specifically, statutes intending to limit or eliminate judicial review, especially of constitutional claims, must clearly articulate this intent to avoid serious constitutional questions. This principle stems from multiple cases such as *Cuozzo Speed Techs., LLC v. Lee*, *Webster v. Doe*, and *Abbott Labs. v. Gardner*. Therefore, a statute that broadly removes the Supreme Court's appellate jurisdiction over significant constitutional issues would likely face substantial scrutiny under this presumption, necessitating a clear legislative intent to do so while being mindful of constitutional boundaries.",
 		"top10_contains_gold_passage":false,
-		"gold_passage":"The Constitution provides that the judicial power of the United States shall be vested in one Supreme Court and such inferior courts as the Congress shall from time to time ordain and establish. The same instrument, in the last clause of the same article, provides that in all cases other than those of original jurisdiction, \u201a\u00c4\u00f2the Supreme Court shall have appellate jurisdiction both as to law and fact, with such exceptions and under such regulations as the Congress shall make.\u201a\u00c4\u00f4",
+		"gold_passage":"The Constitution provides that the judicial power of the United States shall be vested in one Supreme Court and such inferior courts as the Congress shall from time to time ordain and establish. The same instrument, in the last clause of the same article, provides that in all cases other than those of original jurisdiction, 'the Supreme Court shall have appellate jurisdiction both as to law and fact, with such exceptions and under such regulations as the Congress shall make.'",
 		"gold_passage_generation":"The passage explains that the Constitution vests judicial power in the Supreme Court and other courts established by Congress. It highlights that the Supreme Court has appellate jurisdiction in all cases not covered by original jurisdiction, but this appellate jurisdiction is subject to exceptions and regulations determined by Congress. This indicates that Congress has the authority to set limits on the Supreme Court\u2019s appellate jurisdiction, but it does not address the broader implications of how such limitations may affect the uniformity and supremacy of federal constitutional law."
 	},
 	"mbe_1042":{
@@ -530,14 +530,14 @@
 		"generation_colbert":"The key legal principles related to Nora's case focus on the constitutional protections against racially discriminatory practices in jury selection. Specifically, racially based peremptory challenges violate the Equal Protection Clause of the Fourteenth Amendment, which ensures that individuals are not subject to discrimination based on race. As discussed, even if an individual is not a member of the directly discriminated class, racially motivated actions impacting jury composition are prohibited and can compromise the fairness of judicial proceedings. Similarly, the idea of a fair cross-section of the community being necessary for jury impartiality stems from ensuring diversity and preventing racial exclusion in jury selection processes (Whren, Gladstone, Village of Arlington Heights). These principles underscore the importance of an impartial jury and adherence to equal protection standards, regardless of the specific racial composition or the person\u2019s direct racial affiliation.",
 		"top10_e5":[
 			"The Equal Protection Clause of the Fourteenth Amendment to the Constitution of the United States \"prohibits all forms of purposeful racial discrimination in selection of jurors.\" Batson , 476 U.S. at 88, 106 S.Ct. 1712. Purposeful discrimination not only violates the rights of criminal defendants, it deprives prospective jurors of \"a significant opportunity to participate in civic life.\" Powers v. Ohio , 499 U.S. 400, 409, 111 S.Ct. 1364, 113 L.Ed.2d 411 (1991). \"[T]he selection of a petit jury from a representative cross section of the community is an essential component of the Sixth Amendment right to a jury trial.\" Taylor v. Louisiana , 419 U.S. 522, 528, 95 S.Ct. 692, 42 L.Ed.2d 690 (1975). Therefore, the \"Constitution forbids striking even a single prospective juror for a discriminatory purpose.\" Foster v. Chatman , --- U.S. ----, 136 S. Ct. 1737, 1747, 195 L.Ed.2d 1 (2016) (internal citation omitted). And \"[w]hen an uncorrected Batson violation is properly preserved for appeal by objection, the trial court's error in permitting a discriminatory strike cannot be harmless.\" Wayne R. LaFave et al. 6 Criminal Procedure \u00ac\u00df 22.3(d) Peremptory Challenges (4th ed.) (Nov. 2018 update) (collecting cases) (footnotes omitted).",
-			"Shelley v. Kraemer (1948): Shelley v. Kraemer (1948) is a U.S. Supreme Court case that held that restrictive covenants in real property deeds which prohibited the sale of property to non-Caucasians unconstitutionally violate the equal protection provision of the Fourteenth Amendment. Find the full opinion here. In 1911, a majority of property owners in a neighborhood signed an agreement which created a condition precedent to the sale of property\u201a\u00c4\u00eei.e. a restrictive covenant\u201a\u00c4\u00eethat provided that \u201a\u00c4\u00fano part of said property or any portion thereof shall be, for said term of Fifty-years, occupied by any person not of the Caucasian race. . .\u201a\u00c4\u00f9 In 1945, an African American family, the Shelleys, purchased one of the properties without knowledge of the restrictive covenant. The Kraemers, along with other white neighbors, sought to enforce the covenant and enjoin the Shelleys from taking possession of the property because of the restrictive covenant. The Missouri Supreme Court upheld the racially restrictive covenant and enjoined the Shelleys from taking ownership. The U.S. Supreme Court granted certiorari on the Shelleys\u201a\u00c4\u00f4 case to determine whether enforcement of racially restrictive covenants violated the Fourteenth Amendment, which stated, in part, that \u201a\u00c4\u00fano state. . . [shall] deny to any person within its jurisdiction the equal protection of the laws.\u201a\u00c4\u00f9 The Supreme Court, in an opinion by Chief Justice Vinson, held that enforcement of such covenants violates the Equal Protection Clause of the Fourteenth Amendment. While obvious that, had a state created a law barring property ownership solely on the basis of race, that law would violate the Fourteenth Amendment, the issue here was that private owners created a covenant and the Fourteenth Amendment applies to state action. However, the Court reasoned that the Fourteenth Amendment applies to judicial enforcement of such covenants, as that is state action. Thus, the Court concluded that the state is taking action, through judicial enforcement of the racially restrictive covenants, and by doing so denies to African Americans solely on the basis of their race their constitutionally protected right to purchase property. The Court\u201a\u00c4\u00f4s ruling in Shelley v. Kraemer had a significant impact on expanding African American rights in a time when they still suffered under Jim Crow laws. As the D.C. Policy Center explains, in the early 20th century, whites across the country created racially restrictive covenants to prevent blacks from living in traditionally white neighbors, thus segregating white and black neighborhoods. Shelley v. Kraemer not only eliminated this common method of promoting racial residential segregation, but also provided ammunition for future Supreme Court Justices looking to enforce the Equal Protection Clause. For example, in Edmonson v. Leesville Concrete Co., Justice Kennedy, in citing Shelley v. Kraemer alone, emphasized that \u201a\u00c4\u00fathe injury caused by the discrimination is made more severe because the government permits it to occur within the courthouse itself.\u201a\u00c4\u00f9 Thus, while Shelley did not produce the immediate and sweeping change in jurisprudence the other important civil rights cases may have brought, such as Brown v. Board of Education, it was nevertheless an important precedent that courts could use in strengthening the Equal Protection Clause. [Last updated in April of 2021 by the Wex Definitions Team]",
+			"Shelley v. Kraemer (1948): Shelley v. Kraemer (1948) is a U.S. Supreme Court case that held that restrictive covenants in real property deeds which prohibited the sale of property to non-Caucasians unconstitutionally violate the equal protection provision of the Fourteenth Amendment. Find the full opinion here. In 1911, a majority of property owners in a neighborhood signed an agreement which created a condition precedent to the sale of property—i.e. a restrictive covenant—that provided that \"no part of said property or any portion thereof shall be, for said term of Fifty-years, occupied by any person not of the Caucasian race. . .\" In 1945, an African American family, the Shelleys, purchased one of the properties without knowledge of the restrictive covenant. The Kraemers, along with other white neighbors, sought to enforce the covenant and enjoin the Shelleys from taking possession of the property because of the restrictive covenant. The Missouri Supreme Court upheld the racially restrictive covenant and enjoined the Shelleys from taking ownership. The U.S. Supreme Court granted certiorari on the Shelleys' case to determine whether enforcement of racially restrictive covenants violated the Fourteenth Amendment, which stated, in part, that \"no state. . . [shall] deny to any person within its jurisdiction the equal protection of the laws.\" The Supreme Court, in an opinion by Chief Justice Vinson, held that enforcement of such covenants violates the Equal Protection Clause of the Fourteenth Amendment. While obvious that, had a state created a law barring property ownership solely on the basis of race, that law would violate the Fourteenth Amendment, the issue here was that private owners created a covenant and the Fourteenth Amendment applies to state action. However, the Court reasoned that the Fourteenth Amendment applies to judicial enforcement of such covenants, as that is state action. Thus, the Court concluded that the state is taking action, through judicial enforcement of the racially restrictive covenants, and by doing so denies to African Americans solely on the basis of their race their constitutionally protected right to purchase property. The Court's ruling in Shelley v. Kraemer had a significant impact on expanding African American rights in a time when they still suffered under Jim Crow laws. As the D.C. Policy Center explains, in the early 20th century, whites across the country created racially restrictive covenants to prevent blacks from living in traditionally white neighbors, thus segregating white and black neighborhoods. Shelley v. Kraemer not only eliminated this common method of promoting racial residential segregation, but also provided ammunition for future Supreme Court Justices looking to enforce the Equal Protection Clause. For example, in Edmonson v. Leesville Concrete Co., Justice Kennedy, in citing Shelley v. Kraemer alone, emphasized that \"the injury caused by the discrimination is made more severe because the government permits it to occur within the courthouse itself.\" Thus, while Shelley did not produce the immediate and sweeping change in jurisprudence the other important civil rights cases may have brought, such as Brown v. Board of Education, it was nevertheless an important precedent that courts could use in strengthening the Equal Protection Clause. [Last updated in April of 2021 by the Wex Definitions Team]",
 			"IV. Equal Protection Under the Fourteenth Amendment to the United States Constitution",
 			"Faced with criminal charges, defendant, who is black, opted to exercise his state and federal constitutional rights to a jury trial. Among those summoned as potential jurors for defendant's case were three college students home for the summer. Each was passed for cause-that is, determined to be capable of deciding this case fairly and impartially in accordance with the law. Robert and Sarah, who are white, were empaneled as jurors. Fitsum, who is black-and the sole African-American in the jury pool that day-was not empaneled after the prosecutor exercised a peremptory strike against him and the trial court overruled defendant's objection under Batson v. Kentucky , 476 U.S. 79, 85, 106 S. Ct. 1712, 90 L.Ed. 2d 69 (1986). The question before U.S. is whether, under the \"comparative juror\" analysis adopted by the Supreme Court in Miller-El v. Dretke , 545 U.S. 231, 241, 125 S. Ct. 2317, 162 L.Ed. 2d 196 (2005), and applied in Snyder v. Louisiana , 552 U.S. 472, 128 S. Ct. 1203, 170 L.Ed. 2d 175 (2008), and Flowers v. Mississippi , --- U.S. ----, 139 S.Ct. 2228, 204 L.Ed. 2d 638 (2019), the court erred in overruling defendant's Batson objection. Although Snyder and Miller-El have both been on the books for more than a decade, this case appears to present the first opportunity for our court to consider a trial court's ruling on a Batson challenge under the comparative juror analysis. We conclude that, under that analysis, the trial court erred when it overruled defendant's Batson objection and, further, that the error is one that requires reversal. We therefore reverse and remand.",
 			"See U.S. Const. amend. XIV, \u00ac\u00df 1 (providing that no state shall \"deny to any person within its jurisdiction the equal protection of the laws\").",
 			"The Equal Protection Clause of the Fourteenth Amendment provides that no State shall \"deny to any person within its jurisdiction the equal protection of the laws.\" U.S. Const. amend. XIV, \u00ac\u00df 1. It is \"essentially a direction that all persons similarly situated should be treated alike,\" A.M. ex rel. F.M. v. Holmes , 830 F.3d 1123, 1166 (10th Cir. 2016) (internal quotation marks omitted), and is intended \"to secure every person within the State's jurisdiction against intentional and arbitrary discrimination, whether occasioned by express terms of a statute or by its improper execution through duly constituted agents,\" Vill. of Willowbrook v. Olech , 528 U.S. 562, 564, 120 S.Ct. 1073, 145 L.Ed.2d 1060 (2000) (per curiam) (internal quotation marks omitted). An equal protection claim may be asserted with respect to a group or a \"class of one.\" Holmes , 830 F.3d at 1166. A plaintiff who \"alleges that she has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment\" states a claim for violation of her right to equal protection. Olech , 528 U.S. at 564, 120 S.Ct. 1073.",
 			"VII. Deference to Prosecutorial Discretion is Unwarranted When Such Discretion Results in an Equal Protection Violation",
 			"Mr. Sampedro responds that dismissal is nonetheless inappropriate because it is clearly established that officers cannot selectively enforce the law based on racial or ethnic considerations and therefore any reasonable officer would have known that he could not discriminate on the basis of race. Mr. Sampedro has failed to identify an applicable clearly established right, however. Mr. Sampedro is correct that racial profiling in certain settings has been held to violate the Fourteenth Amendment's equal protection clause. E.g., Batson v. Kentucky , 476 U.S. 79, 84, 106 S.Ct. 1712, 90 L.Ed.2d 69 (1986) (holding use of peremptory challenges to exclude jurors based on race violated equal protection clause). But, for purposes of qualified immunity, the inquiry is not whether such general principles of constitutional law might be applied to a particular circumstance, but whether such principles have been applied in the same or similar circumstances. See Allah, 876 F.3d at 59 (holding defendants were entitled to qualified immunity where relevant precedent did not clearly establish that a substantive due process would result from disputed conduct and plaintiff failed to \"identify any other case law that would have placed Defendants on notice that their conduct violated substantive due process\"). As noted above, \"[r]ights must be clearly established in a 'particularized' sense, rather than at a high level of generality; and such rights are only clearly established if a court can 'identify a case where an officer acting under similar circumstances' was held to have acted unconstitutionally.\" Grice , 873 F.3d at 166 (quoting White , 137 S. Ct. at 552 ). Mr. Sampedro has not identified any controlling authority that establishes that Trooper Kores could not lawfully arrest, investigate, and detain Mr. Sampedro as alleged without violating the Fourteenth Amendment.",
-			"Regents of the University of California v. Bakke (1978): Regents of the University of California v. Bakke is a 1978 Supreme Court case which held that a university\u201a\u00c4\u00f4s admissions criteria which used race as a definite and exclusive basis for an admission decision violated the Equal Protection Clause of the Fourteenth Amendment and Title VI of the Civil Rights Act of 1964. Find full opinion here. In the case, Bakke was a white male who applied to medical school at the University California at Davis. Although his admissions score was well above that of the average admittee and the school had open slots when he applied, his application was rejected because of the school\u201a\u00c4\u00f4s racial quota system. Previously, the school implemented a quota system where white applicants could only compete for 84 out of 100 spots, and the remaining 16 were reserved for racial minorities. Bakke sued the school, arguing that the clear-cut racial quota system was unconstitutional and a violation of the Civil Rights Act of 1964. The Court held that these admission criteria violated the Equal Protection Clause and the Civil Rights Act of 1964. The Court blended the analysis of the two, finding that a violation of the Equal Protection Clause is discrimination, which the Civil Rights Act of 1964 prohibits. In this case, the court applied strict scrutiny, reasoning that the Equal Protection Clause requires that a government have a compelling interest with narrowly tailored means to blatantly base their actions on race alone, as was the case here. In so reasoning, the court extends the heightened scrutiny on race discrimination to all races and does not limit it to the protection of racial minorities. The medical school argued that their racial quota system served a compelling government interest by remedying the traditional underrepresentation of minorities in the medical profession and that the diversity in the classroom enhances the free exchange of ideas. The Court rejected the University\u201a\u00c4\u00f4s arguments though, finding that there are other ways to achieve representation of traditionally underrepresented groups and classroom diversity without a blatant racial quota system. That is, the Court left the door open for race as a consideration among many in admissions. But the Court ruled that a quota system which excludes candidates because of their race alone is racial discrimination and that the University did not have a compelling reason with reasonably tailored means to overcome the constitutional standard of strict scrutiny. [Last updated in December of 2020 by the Wex Definitions Team]",
+			"Regents of the University of California v. Bakke (1978): Regents of the University of California v. Bakke is a 1978 Supreme Court case which held that a university's admissions criteria which used race as a definite and exclusive basis for an admission decision violated the Equal Protection Clause of the Fourteenth Amendment and Title VI of the Civil Rights Act of 1964. Find full opinion here. In the case, Bakke was a white male who applied to medical school at the University California at Davis. Although his admissions score was well above that of the average admittee and the school had open slots when he applied, his application was rejected because of the school's racial quota system. Previously, the school implemented a quota system where white applicants could only compete for 84 out of 100 spots, and the remaining 16 were reserved for racial minorities. Bakke sued the school, arguing that the clear-cut racial quota system was unconstitutional and a violation of the Civil Rights Act of 1964. The Court held that these admission criteria violated the Equal Protection Clause and the Civil Rights Act of 1964. The Court blended the analysis of the two, finding that a violation of the Equal Protection Clause is discrimination, which the Civil Rights Act of 1964 prohibits. In this case, the court applied strict scrutiny, reasoning that the Equal Protection Clause requires that a government have a compelling interest with narrowly tailored means to blatantly base their actions on race alone, as was the case here. In so reasoning, the court extends the heightened scrutiny on race discrimination to all races and does not limit it to the protection of racial minorities. The medical school argued that their racial quota system served a compelling government interest by remedying the traditional underrepresentation of minorities in the medical profession and that the diversity in the classroom enhances the free exchange of ideas. The Court rejected the University's arguments though, finding that there are other ways to achieve representation of traditionally underrepresented groups and classroom diversity without a blatant racial quota system. That is, the Court left the door open for race as a consideration among many in admissions. But the Court ruled that a quota system which excludes candidates because of their race alone is racial discrimination and that the University did not have a compelling reason with reasonably tailored means to overcome the constitutional standard of strict scrutiny. [Last updated in December of 2020 by the Wex Definitions Team]",
 			"Pro Se Assignment of Error 2: State's Peremptory Challenge Based on Race Violates the Constitutions of the United States and Louisiana"
 		],
 		"generation_e5":"The passages collectively emphasize the constitutional prohibition against racial discrimination in jury selection. The Equal Protection Clause of the Fourteenth Amendment and relevant case law, such as *Batson v. Kentucky* and *Foster v. Chatman*, assert that any purposeful exclusion of jurors based on race violates constitutional rights. This principle applies regardless of the defendant's race, underscoring that racial discrimination in jury selection infringes on both the rights of the defendant and the excluded jurors. Specifically, racially motivated peremptory challenges are impermissible, and errors arising from such practices are not considered harmless if preserved and appealed. Further, cases like *Shelley v. Kraemer* and an array of other precedents reinforce that the Equal Protection Clause aims to prevent both overt and subtle forms of racial discrimination by state actors, including those actions within the judicial process.",