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Richard B. Saphire is a Professor of Law, University of Dayton School of Law. The author is cocounsel for the plaintiff in Secora v. Peterson, Civ. Action No. C-3-83-799 (S.D. Ohio), a pending case raising, inter alia, constitutional claims closely analogous to those asserted in Dronenburg v. Zech, 741 F.2d 1388 (D.C. Cir. 1984).

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