Anthony Comstock, and Conflict over Sex in the United States in the 1870s, 87 J. Am. Hist. 403, 420 (2000); see Sohn, supra note 18, at 66-75. For the

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REV. 229, 240-43 (2008). VITARELLI_PDF.DOC 2/26/2010 5:47:20 PM constitutional avoidance step zero 841 Washington v. Glucksberg,18 as a

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Publick and Permanent Nature: Coming Down to, and Including, the Year 1824, at 217, 217-18 (William Slade, Jr. ed., Windsor, Simeon Ide 1825); Act of

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COLONIAL LAWS OF NEW YORK FROM THE YEAR 1664 TO THE REVOLUTION 18 (Albany, N.Y., James B. Lyon 1896) (containing a nearly identical perambulation law to

ownership.18 And still others, including Colorado, Minnesota, and Oregon, have created special certification programs to permit some licensed nonlawyers to

ownership.18 And still others, including Colorado, Minnesota, and Oregon, have created special certification programs to permit some licensed nonlawyers

208.Shelfer.252

Special Jury?, 31 MINN. L. REV. 232 (1947). 11. See infra text accompanying notes 15-18; James Oldham, The History of the Special (Struck) Jury in

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265-71 (1981) (discussing Dodge v. Woolsey, 59 U.S. (18 How.) 331 (1855)). See Comment, The Case-Concept and Some Recent Indirect Procedures for

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extensions by private act between 1808 and 1847). § 18, 5 Stat. at 124. From 1848, the power to grant extensions was vested in the Commissioner of