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CLR Diversity Editor Sean Darling-Hammond analyzes the Ninth Circuit's decision in Renee v. Duncan-the latest in a series of cases challenging Department of Education regulations that disproportionately affect low-income students by allowing teachers enrolled in alternative certification programs to engage in instruction. Darling-Hammond ultimately advocates a novel solution to allow states to champion the rights of their most vulnerable citizens in light of restrictive standards of review of regulations in federal court.

This case note is one of seven written by California Law Review members for Circuit's first case note program.



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