This Comment considers fragrance products’ eligibility for copyright protection and argues that U.S. copyright law, as it currently stands, is capable of being extended to protect perfume as a copyrightable creative expression in a way not yet addressed by the U.S. Copyright Office or federal courts. Further, this Comment will explore the necessity of having copyright protection expanded to fragrances in light of the current challenges facing the perfume industry.

Margaret M. Donnelly *

* J.D., 2024, University of Richmond School of Law; B.S., 2021, Duquesne University.

The United States Senate must rapidly appoint Eastern District of California Judge Ana de Alba to the Ninth Circuit. This appellate tribunal is a preeminent regional circuit, which faces substantial appeals, has the largest complement of jurists, and clearly includes a massive geographic expanse. The nominee, whom President Joe Biden designated in spring 2023, would offer remarkable gender, experiential, ideological, and ethnic diversity realized primarily from serving productively with the California federal district, and state trial, courts after rigorously litigating for one decade in a highly regarded private law firm. For over fifteen years, she deftly excelled in law’s upper echelon. The post which the judge could fill has been vacant for months. Thus, the Senate needs to promptly approve the well qualified, mainstream nominee.

Carl Tobias *

* Williams Chair in Law, University of Richmond School of Law

Now that the United States Senate is convening after the July Fourth holiday, the upper chamber must promptly appoint Rachel Bloomekatz to the U.S. Court of Appeals for the Sixth Circuit. The nominee, whom President Joe Biden selected in May 2022, provides remarkable experiential, gender, and ideological expertise that she deftly realized in litigating high-profile gun control, environmental, and other significant cases in federal appellate courts and district courts. Over fifteen years, the nominee has reached law’s pantheon across a broad spectrum from extremely prestigious clerkships with Justice Stephen Breyer and particularly distinguished federal court and state court jurists to robustly participating in many suits for the powerful global law firm Jones Day. The opening that the nominee would fill has been vacant for months. Thus, the Senate needs to rapidly approve the exceptionally competent, mainstream nominee.

Carl Tobias *

* Williams Chair in Law, University of Richmond School of Law

Now that the United States Senate has reconvened after pauses for holidays, the upper chamber must expeditiously appoint designee Julie Rikelman to the U.S. Court of Appeals for the First Circuit, which is the smallest, albeit critical, appellate court. The nominee, whom President Joe Biden tapped during late July 2022, would supply remarkable experiential, gender, and ideological diversity gleaned from pursuing much cutting-edge reproductive freedom litigation, which included arguing Dobbs before the Supreme Court that overturned Roe v. Wade. The nominee has definitely excelled in law’s highest echelon over twenty-plus years, most recently as the U.S. Litigation Director in the Center for Reproductive Rights at which she has worked over a decade. The vacancy that the nominee would fill has been empty for plentiful months. Thus, the Senate needs to promptly confirm the well qualified, mainstream nominee.

Carl Tobias *

* Williams Chair in Law, University of Richmond School of Law

Lawyer and University of Richmond Law graduate Robert C. Smith—the great-great-grandson of T.C. Williams, Sr.—has recently claimed that his family is owed a refund of $3.6 billion from the University of Richmond, stemming from donations that Williams, for whom the University of Richmond School of Law was officially named from 1920 until September 2022, made to establish and sustain the school. Though the law school had not referred to itself as the T.C. Williams School of Law for some two decades, the University formally changed the law school’s name because Mr. Williams “owned and managed slaves in both his professional and personal capacity.”

Smith is likely aware that he would have no standing before a court of law, or an actionable claim, for the recovery of the money his great-great-grandfather donated to the University of Richmond, much less a sum greater than the entire University endowment. Smith’s demands appeal more to Smith’s view of morality than the law of contracts. By demanding not only the money that Williams donated, but a sum that is greater than the University’s endowment, Smith essentially suggests that unless the Law School bears Williams’s name, it should not exist. On this point, and several others, he is mistaken.

By publishing his letters, and the stunning defenses of slavery contained therein, Smith is waging a battle that is not so much legal as it is rhetorical—and he does so with a particular audience in mind. Through this battle, Smith is attempting not to redeem a financial debt, but rather, to redeem his family’s honor vis-à-vis America’s present culture wars.

Where Smith fails to articulate a compelling claim for contractual breach, he does make an excellent case for reparatory justice. Unlike Smith’s far-fetched demands for the return of Williams’s gift, reparative justice to those exploited and otherwise harmed by enslavement does have a basis in law.

Marissa Jackson Sow *

* Assistant Professor, University of Richmond School of Law