The Yale Law Journal

Eric Citron

Forum

Police Pretext as a Democracy Problem

Eric Citron

Democracy, at the very least, requires that the dangerous branches of government—like the executive and law enforcement—be accountable to the people or their representatives. Ignoring claims of police pretext, as our Fourth Amendment jurisprudence currently does, creates a barrier to that accoun…

Forum

Sentencing Review: Judgment, Justice, and the Judiciary

Eric Citron

Since United States v. Booker, the main task of sentencing academics and appellate judges has been to solve the riddles of its mandated “reasonableness” review. This is a crucial task because the answers reached will largely determine whether Booker’s promise of fresh discretion in federal sen…

Comment

United States v. Pho: Reasons and Reasonableness in Post-Booker Appellate Review

Eric Citron

115 Yale L.J. 2183 (2006)

This Comment argues that a proper understanding of Booker's reasonableness review validates the appellate court's rejection of these reduced-ratio sentences in Pho, and should do so despite the fact that the sentences issued by Judge Torres were eminently "reasonable" in any…