Rudy Giuliani Released From Hospital After Car Crash – Above the Law

Rudy
Giuliani,
former
mayor
of
New
York
and

priest
doxxer
,
was
rear-ended
this
Saturday
on
a
highway.

The
internet
quickly
took
to
speculating
about
his
health
following
the
crash.
It
was
largely
overshadowed
by
speculation
over

Trump’s

health,
but
the
pockets
of
curiosity
were
there
nonetheless.
Despite
the
laundry
list
of
injuries
in
the
tweet,
Giuliani
seems
to
be
alright.

New
York
Times

has
coverage:

Rudolph
W.
Giuliani
was
released
from
the
hospital
on
Monday
afternoon
after
a
car
crash
in
Manchester,
N.H.,
on
Saturday
night,
according
to
his
security
chief
and
a
friend.

“A
little
car
accident
won’t
be
slowing
him
down,”
said
Michael
Ragusa,
the
security
chief
for
Mr.
Giuliani,
who
led
New
York
through
the
Sept.
11
terrorist
attacks.

The
release
is
probably
for
the
best

the
last
place
Trump
wants
to
be
seen
right
now
amidst
the

Weekend
at
Donald’s
memeing

is
at
a
hospital
when
he
awards
Giuliani
the
Medal
of
Freedom.

Most
people
just
give
their
friends
a
bouquet
or
a
get
well
card,
but
what
else
is
there
to
do
when
you
have
such
a
flair
for
gaudy
extravagance?
Speedy
recovery
or
whatever,
man.


Giuliani
Released
From
Hospital
After
Car
Crash

[NYT]


Earlier
:

Rudy
Giuliani
Embraces
Contempt
As
A
Lifestyle,
And
It
Somehow
Manages
To
Work
Out
For
Him



Chris
Williams
became
a
social
media
manager
and
assistant
editor
for
Above
the
Law
in
June
2021.
Prior
to
joining
the
staff,
he
moonlighted
as
a
minor
Memelord™
in
the
Facebook
group Law
School
Memes
for
Edgy
T14s
.
 He
endured
Missouri
long
enough
to
graduate
from
Washington
University
in
St.
Louis
School
of
Law.
He
is
a
former
boatbuilder
who
is
learning
to
swim, is
interested
in
critical
race
theory,
philosophy,
and
humor,
and
has
a
love
for
cycling
that
occasionally
annoys
his
peers.
You
can
reach
him
by
email
at [email protected]
and
by
tweet
at @WritesForRent.

Kim Kardashian Is Waiting On Her Bar Exam Results – Above the Law

(Photo
by
Chip
Somodevilla/Getty
Images)

Back
in
May,
we
learned
that
Kim
Kardashian
had

finally
graduated
from
“law
school,”

perhaps
better
known
as
the
California
legal
apprenticeship
program
she
started
about
six
years
ago
when
she
announced
that
she
was studying
to
become
a
lawyer
 without going
to
law
school.
For
most
law
students,
the
next
step
after
graduation
is
taking
the
bar
exam

but
would
Kim
be
submitting
herself
to
this
lawyerly
hazing
event
alongside
other
2025
law
school
graduates?

Yes!

In
2021,
Kardashian
let
the
world
know
that
she’d
finally passed
the
baby
bar
exam

after
three
prior
failures.
We
know
that
she
reportedly
took
the
Multistate
Professional
Responsibility
Exam
(MPRE)
in
March,
and
thanks
to

TMZ
,
it’s
now
been
confirmed
that
Kardashian
took
the
California
bar
exam
in
July.
But
how
could
a
celebrity
take
the
exam
without
being
recognized?
TMZ
has
some
thoughts
on
that:

The
test
is
administered
at
a
large
convention
center,
but
we’re
almost
certain
she
did
not
take
it
with
the
masses

otherwise,
the
word
would
be
out.
During
COVID,
provisions
were
made
for
proctors,
who
could
administer
the
exam
more
privately,
so
it
seems
that’s
what
went
down
with
Kim.

California
has
long
been
known
for
having
one
of
the
most
difficult
bar
exams
in
the
country,
so
we
wish
Kardashian
the
very
best
of
luck.
She’ll
be
playing
lawyer
this
fall
in
Hulu’s
legal
drama
All’s
Fair
,
and
hopefully,
she’ll
soon
be
able
to
play
a
lawyer
in
real
life.
Test
results
are
slated
to
be
released
on
November
7.
Cross
your
fingers
for
the
future
Kim
Kardashian,
Esq.!


Kim
Kardashian
Steppin’
Up
to
the
Bar

Anxiously
Awaiting
Results

[TMZ]


Staci Zaretsky




Staci
Zaretsky
 is
the
managing
editor
of
Above
the
Law,
where
she’s
worked
since
2011.
She’d
love
to
hear
from
you,
so
please
feel
free
to

email

her
with
any
tips,
questions,
comments,
or
critiques.
You
can
follow
her
on BlueskyX/Twitter,
and Threads, or
connect
with
her
on LinkedIn.

Posse Comitatus This, B*tch – Above the Law

LOS
ANGELES,
CA

JUNE
13:
U.S.
Marines
stand
guard
outside
of
the
Wilshire
Federal
Building
on
June
13,
2025
in
Los
Angeles,
California.
Trump
federalized
members
of
the
National
Guard
and
mobilized
Marines
last
week
to
reinforce
immigration
raids
in
the
nation’s
second-largest
city,
saying
the
troops
will
protect
federal
property
and
assist
agents.
(Photo
by
Zhang
Shuo/China
News
Service/VCG
via
Getty
Images)

Today,
Judge
Charles
Breyer
issued
an
injunction
barring
Donald
Trump
from
his
takeover
of
Los
Angles,
holding
the
deployment
of
troops
violated
the
Posse
Comitatus
Act.
And
the
senior
judge
from
the
Northern
District
of
California
pulled
exactly
zero
punches
calling
out
the
administration
for
its
illegal
activities.

Congress
spoke
clearly
in
1878
when
it
passed
the
Posse
Comitatus
Act,
prohibiting
the
use
of
the
U.S.
military
to
execute
domestic
law.
Nearly
140
years
later,
Defendants—
President
Trump,
Secretary
of
Defense
Hegseth,
and
the
Department
of
Defense—
deployed
the
National
Guard
and
Marines
to
Los
Angeles,
ostensibly
to
quell
a
rebellion
and
ensure
that
federal
immigration
law
was
enforced.
There
were
indeed
protests
in
Los
Angeles,
and
some
individuals
engaged
in
violence.
Yet
there
was
no
rebellion,
nor
was
civilian
law
enforcement
unable
to
respond
to
the
protests
and
enforce
the
law.

Nevertheless,
at
Defendants’
orders
and
contrary
to
Congress’s
explicit
instruction,
federal
troops
executed
the
laws.
The
evidence
at
trial
established
that
Defendants
systematically
used
armed
soldiers
(whose
identity
was
often
obscured
by
protective
armor)
and
military
vehicles
to
set
up
protective
perimeters
and
traffic
blockades,
engage
in
crowd
control,
and
otherwise
demonstrate
a
military
presence
in
and
around
Los
Angeles.
In
short,
Defendants
violated
the
Posse
Comitatus
Act.

The
52-page
decision
also
noted
that
the
L.A.
takeover
was
but
the
first
step
for
the
administration

Washington,
D.C.
(and
maybe
Chicago,
we’ll
see
what
Trump
says
at
2
p.m.
today)
faced
similar
military
encroachments.
“President
Trump
and
Secretary
Hegseth
have
stated
their
intention
to
call
National
Guard
troops
into
service
in
other
cities
across
the
country,”
Breyer
wrote,
“…
thus
creating
a
national
police
force
with
the
President
as
its
chief.”

Breyer
stayed
his
own
order
for
10
days,
in
order
to
afford
the
federal
government
the
opportunity
to
appeal,
which
they
almost
certainly
will.

Score
one
for
the
rule
of
law.
Now
let’s
see
if
the
administration
actually
listens
to
the
courts.

Read
the
full
decision
below.




Kathryn
Rubino
is
a
Senior
Editor
at
Above
the
Law,
host
of

The
Jabot
podcast
,
and
co-host
of

Thinking
Like
A
Lawyer
.
AtL
tipsters
are
the
best,
so
please
connect
with
her.
Feel
free
to
email

her

with
any
tips,
questions,
or
comments
and
follow
her
on
Twitter

@Kathryn1
 or
Mastodon

@[email protected].

Morning Docket: 09.02.25 – Above the Law

*
To
bolster
death
penalty
bid
in
Luigi
Mangione
case,
prosecutors
are
arguing
that
the
United
Healthcare
shooting,
normalized
gun
violence.
Instead
of,
say,
the
mass
school
shootings
that
the
administration
refuses
to
do
anything
about.
[New
York
Law
Journal
]

*
Rudy
Giuliani
injured
in
car
crash.
[CBS
News
]

*
Federal
judge
and
staff
work
through
the
middle
of
the
night
on
a
holiday
weekend
after
Trump
administration
attempts
to
deport
a
planeload
of
children
in
the
night
to
avoid
legal
oversight.
[Reuters]

*
Happy
Labor
Day!
Littler
Mendelson
reportedly
told
clients
on
call
that
“if
you
are
a
bit
more
risk
tolerant”
they
can
go
ahead
and
start
ignoring
some
state
labor
laws.
[American
Prospect
]

*
MIT
warns
that
ChatGPT
may
outperform
more
expensive
products
specifically
tailored
to
the
legal
market.
Somehow
the
word
“hallucination”
isn’t
in
this
article
or
the
underlying
report.
[Bloomberg
Law
News
]

*
Federal
Circuit
puts
brakes
on
Trump’s
tariff
powers.
[Law360]

*
Former
senior
Disney
lawyer
sues
company
for
discrimination.
[Deadline]

Molotov Hoagie Avoids Indictment – See Generally – Above the Law

Not
All
Heroes
Wear
Capes…
Not
All
Grinders
Or
Subs
Either:
Department
of
Justice
fails
to
secure
indictment
for
sandwich
vigilante.
Baby’s
First
Hostage
Negotiation:
Lawyers
use
newborn
for
leverage
in
scheduling
spat,
proving
once
again
that
bar
associations
should
require
basic
humanity
CLEs.
Biglaw
Divorce
Gets
Messy:
Former
partner
and
firm
battle
over
$1.5
million
fee.
Amy
Wax’s
Flies
Too
Close
To
The
Dumb:
Wax’s
latest
litigation
stunt
disintegrates
mid-air,
which
is
the
most
graceful
exit
she’s
managed
in
years.
Alina
Habba
Breaks
New
Jersey
Court
System
To
Own
The
Libs:
Trump’s
personal
chaos
engine
managing
to
jam
up
criminal
cases
like
a
toddler
shoving
LEGOs
in
a
blender.
ABA
Wants
More
Schools
To
Look
Outside
The
LSAT:
Effort
to
collect
data
on
efficacy
of
tests
kicked
up
a
notch.
America’s
Thirstiest
Law
Professor
Tries
To
Get
In
On
Calvinball:
Jonathan
Turley
tries
to
bash
Justice
Jackson,
by
making
up
his
own
completely
nonsensical
rules.

Alina Habba Breaks New Jersey Court System – Above the Law

(Photo
by
SAUL
LOEB/AFP
via
Getty
Images)

Alina
Habba
cares
deeply
about
the
rule
of
law.
She
just
cares
about
her
career
more.

Yesterday,
the
New
York
Times
ran
a

three-byline
piece

detailing
the
chaos
in
New
Jersey
thanks
to
President
Trump’s
insistence
that
his
personal
lawyer
serve
as
the
top
prosecutor
in
the
Garden
State.
The
shenanigans
have
been
extensive,
but
briefly

In
March,
Trump
installed
Matthew
Giordano,
an
experienced
prosecutor
and
campaign
donor,
as
US
Attorney
for
the
District
of
New
Jersey.
Three
weeks
later,
he
shoved
Giordano
aside,
mumbling
that
he
was
honoring
him
with
an
appointment
as
ambassador
to
Namibia.
Instead
Trump

installed

his
personal
lawyer
Alina
Habba,
a
loyalist
with
zero
prosecutorial
experience.
Trump
nominated
Habba
for
a
full
term,
but
the
Senate
never
took
up
her
appointment

and
indeed
she
appears
never
to
have
even
bothered
to

fill
out
the
paperwork
.
On
the
eve
of
(what
we
all
assumed
was)
the

expiration
of
her
term
,
federal
judges
in
New
Jersey
exercised
their
statutory
right
to
appoint
someone
to
the
vacant
office,
tapping
Habba’s
deputy
Desiree
Grace.
This
so
enraged
Attorney
General
Pam
Bondi
that
she
attempted
to

jujitsu
her
protégé
back

into
place
by
firing
Grace,
appointing
Habba
as
her
own
deputy
and
then
allowing
her
to
succeed
herself
in
office.
For
good
measure,
Bondi
appointed
Habba
as
a
special
counsel,
too.

Multiple
criminal
defendants
sued,
alleging
that
Habba
was
not
legally
serving
as
acting
US
Attorney,
and
thus
her
actions
were
all
ultra
vires.
And
on
August
21,
Judge
Matthew
Brann,
a
Pennsylvania
judge
sitting
by
special
designation
over
the
New
Jersey
case,
agreed.
Indeed,
he

found

that
Bondi’s
appointment
clock
started
with
Giordano,
not
Habba,
and
thus
her
actions
for
much
of
July
were
unauthorized.

Knowing
that
the
administration
would
appeal,
which
it
did,
the
judge
stayed
his
order
pending
review
by
the
Third
Circuit.
And
so
Habba
remains
in
office,
but
in
a
liminal
purgatory
where
no
one
knows
if
she
was
legally
appointed.

Welcome
to
hot
mess
summer!

As
detailed
in
the

Times
,
“courts
are
bracing
for
the
possibility
that
any
proceedings
Ms.
Habba
has
touched,
or
those
involving
prosecutors
she
supervises,
could
be
challenged
by
defense
lawyers.”
Cases
are
being
stayed
and
trials
postponed.
Defendants
remain
inside
or
outside
of
jail
indefinitely.
The
system
has
effectively
ground
to
a
halt.

Does
Habba
feel
a
twinge
of
guilt
at
occasioning
paralysis
across
an
entire
state’s
criminal
justice
system?

Ms.
Habba
could
reduce
the
risk
to
current
and
future
cases
by
recusing
herself
until
the
appeals
court
makes
a
decision,
but
has
thus
far
declined
to
do
so. 

Let’s
go
with

NO
.
She
will
make
New
Jersey
great
again,
if
she
has
to
let
hundreds
of
criminal
cases
die
for
violating
the
speedy
trial
requirement
to
do
it.
That’s
on
the
Sixth
Amendment,
not
her!
Or
probably
it’s
on
those
dastardly
judges,
for
failing
to
recognize
her
authority
as
Trump’s
own
anointed
one.

It’s
not
clear
why
the
administration
is
digging
in
so
aggressively
on
this
issue.
Even
under
the
DOJ’s
cockeyed
interpretation
of
the
Federal
Vacancies
Reform
Act,
Habba
would
be
limited
to
210
days
in
office
,
not
a
full
term.
But
perhaps
the
DOJ
views
Habba
as
a
test
case,
since
it
has
at
least
a
dozen
acting
US
Attorneys
who
are
staring
down
the
end
of
their
120-day
appointments
with
no
possibility
of
Senate
confirmation
or
renomination
by
the
district
judges.
They’ve
also
tried
a
similar


I’m
my
own
first
assistant!

maneuver
in
the
Northern
District
of
New
York.

Tapping
out
on
Habba
risks
conceding
that
none
of
the
hacks
they’ve
loosed
on
prosecutors’
offices
are
legit.
And
so
New
Jersey’s
limbo
looks
likely
to
drag
on
into
fall.
Because
nothing
says
“tough
on
crime”
like
making
sure
that
you
can’t
fight
it
at
all.


Inside
the
Crisis
Gripping
New
Jersey’s
Federal
CourtsInside
the
Crisis
Gripping
New
Jersey’s
Federal
Courts

[NYT]





Liz
Dye
 lives
in
Baltimore
where
she
produces
the
Law
and
Chaos substack and podcast.

How Appealing Weekly Roundup – Above the Law




Ed.
Note
:

A
weekly
roundup
of
just
a
few
items
from
Howard
Bashman’s

How
Appealing
blog
,
the
Web’s
first
blog
devoted
to
appellate
litigation.
Check
out
these
stories
and
more
at
How
Appealing.


“With
Louisiana
Essentially
Flipping
Sides
in
Callais
Case
Before
Supreme
Court
and
Arguing
Section
2
of
the
Voting
Rights
Act
is
Unconstitutional,
Full
Defense
Shifts
to
Voting
Rights
Groups”:
 Rick
Hasen
has this
post
 at
his
“Election
Law
Blog.”


“What
*are*
the
legal
questions
at
issue
in
Trump’s
purported
removal
of
Lisa
Cook
from
the
Federal
Reserve
Board?”
 Marty
Lederman
has this
post
 at
the
“Balkinization”
blog.


“Judicial
Backlash
Grows
Over
‘Smear’
Campaign
by
Trump
Officials”:
 Zoe
Tillman
of
Bloomberg
News
has this
report
.


“Yelp
reviews
and
Adelson
TV
talk:
Inside
what
prosecutors
say
is
Dan
Markel
murder
‘code.’”
 Jeff
Burlew
and
Elena
Barrera
of
The
Tallahassee
Democrat
have this
report
.


“Abrego
Garcia
Requests
Asylum
in
the
United
States;
The
request
is
another
possible
path
for
the
Salvadoran
man,
who
has
already
been
deported
and
returned
by
the
Trump
administration,
to
remain
in
the
country”:
 Alan
Feuer
of
The
New
York
Times
has this
report
.


“Supreme
Court
declines
to
revive
Hunter
Biden,
computer
repairman’s
dueling
lawsuits”:
 Xerxes
Wilson
of
The
Delaware
News
Journal
has this
report
.