January Littlejohn has lost her appeal in the 11th Circuit in a split decision, but this is actually more divided than just 2-1. Newsom concurs w/ the outcome, but writes a pretty crazy concurrence where he shreds substantive due process. Rosenbaum writes a 75 pg response to that. Tjoflat dissents.

Scott Gerber & Ohio Northern University have settled. Gerber is reinstated to his ONU position/rank, must immediately enter his retirement letter. All parties agree to not disparage the others publicly/privately; Gerber agrees to not publish or distribute in any way his memoir titled "Cancelled."