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I posted "Vertical Stare Decisis and Three-Judge District Courts," forthcoming in @georgetownlj. Tracing the evolution of such courts over a century, it shows they're bound by court of appeals precedent even when their rulings aren't reviewable there. papers.ssrn.com/sol3/papers.cf…
This piece also offers a new theory of vertical stare decisis, discussing the source & extent of lower courts' obligation to follow other courts' precedents - a theory that usefully applies in any situation involving unusual appellate structures outside the traditional hierarchy
I owe a huge debt of gratitude to the @FSULawRC for all my articles this past year, but especially this one! They helped me compile and review voluminous legislative history in tracing Congress' intent concerning direct Supreme Court review and three-judge trial courts
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