UNITED HEALTHCARE INS. CO. VS. FREMONT EMERGENCY SERVS., 141 Nev. Adv. Op. 29 (Jun. 12, 2025)

NEVADA SUPREME COURT RULES EMERGENCY PROVIDER CAN RECOVER FOR UNJUST ENRICHMENT AGAINST INSURER BUT NOT IMPLIED CONTRACT OR INSURANCE STATUTES

eCarrots: Prison Control and Profits from Correctional Tablets

In recent years, tablets have gained tremendous popularity behind bars for their ability to expand access to educational and rehabilitative services for people in prison. However, there are downsides to tablet implementation, including high costs at the expense of a captive population and shifting power dynamics resulting in possible volatility. This Article examines the use of correctional tablets in jails and prisons as mechanisms for administrative control and profit-making in an era of beleaguered correctional budgets. It also considers legal and policy implications related to the disproportionately negative impact of the introduction of tablets on people in poverty, increased dependency on third-party contractors through the elimination of existing service structures, and the dangers of screentime addiction for people in prison. Ultimately, tablet suppliers are likely to continue working their way into prison systems, and there are many benefits to the incarcerated population from this expansion. However, it must be done thoughtfully and under careful oversight of interested parties to ensure the worst impacts are mitigated

Walker v. Walker, 141 Nev. Adv. Op. 2 (Jan. 9, 2025)

The Nevada Supreme Court concluded that more than one Option 2 beneficiary can be designated on a JRS when accounting for a former spouse divorce decree and a current spouse. The Nevada Supreme Court also held that when a former spouse has an interest in a member’s PERS retirement benefits, a member’s transfer to a JRS account does not extinguish those benefits

The Current Development of U.S. Copyright Law in Light of the Current Political Situation and of the Interests of Major Stakeholders

Professor Trimble delivered a presentation at the Law Faculty of Charles University in Prague, the Czech Republic

Build, Buy, or Both?: On the Antitrust Laws\u27 Supposed Preference for Internal Growth over Acquisitions

This Article challenges recent claims by antitrust enforcers that the U.S. antitrust laws embody a preference for “internal” or “organic” growth over external expansion through acquisition. It begins by examining the modern use of this claim in speeches, enforcement actions, and the 2023 Merger Guidelines issued by the Federal Trade Commission and Department of Justice. It then considers the legislative history of the 1950 Celler-Kefauver and 1976 Hart-Scott-Rodino Acts, which are frequently cited as showing congressional support for internal growth. Careful reading of these Acts, however, shows that Congress’s central goal was to close a loophole regarding asset acquisitions, and evinced only passing (and disputed) concern about “organic” expansion. Further, the Federal Trade Commission’s own reports at the time, which purportedly justified a hostility toward “buying” rather than “building,” were shown to be flawed and later quietly disavowed by their authors. Turning to modern economics, the Article highlights the ways in which acquisitions can promote competition through efficiencies, innovation, and dynamic resource reallocation—sometimes spurring more internal investment rather than crowding it out. It concludes that current hostility toward mergers is at odds with both the legislative record and mainstream economic understanding, and that there is no statutory or scholarly basis for an antitrust preference for firms to grow by “building” instead of “buying.