
UCLA Undergraduate Law Journal
VOLUME 24
2024–2025


Meet the Executive Board
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Catherine Hamilton
Editor in Chief | Class of ‘25
Catherine graduated this past Spring from UCLA where she double-majored in Gender Studies and Political Science. She served as an editor for Volume 21 of the Journal, an executive article editor for Volume 22, the managing editor for Volume 23, and finally the editor-in-chief for Volume 24. While at UCLA, she was the News editor for the Daily Bruin. She is interested in abolition of the death penalty, and upon graduation will be interning for the Georgia Resource Center, a death penalty appeals nonprofit, post-graduation.
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Nate Catlin
Managing Editor | Class of ‘25
Nate graduated this past Spring from UCLA as a Psychology major and plans on attending law school to become a public interest attorney. In previous years, he has contributed as a writer for Volume 22 of the Journal and as a senior editor for Volume 23. He is also involved in the Bruin Political Review as a Lead Copy Editor and the APS Undergraduate Law Journal as Editor-in Chief. He would like to thank the editors, writers, and other editorial board members for their dedication and enthusiasm throughout Volume 24’s editorial process.
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Japji Singh
Managing Editor | Class of ‘25
Japji graduated this past December from UCLA with a degree in Economics and a minor in Mathematics and International Migration. While at UCLA, she was the president of Bruin Bhangra and a member of the JusticeCorps internship program. Japji has thoroughly enjoyed her past four years on the Undergraduate Law Journal. She was a writer for Volume 21, an editor for Volume 22, senior editor for Volume 23, and finally a managing editor for this year’s Volume 24. This fall, Japji will be beginning law school at the University of Chicago, where she hopes to pursue a career in appellate litigation.
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Alexander Azilazian
Senior Editor | Class of ‘25
Alexander graduated this past Spring from UCLA as a Political Science major and Entrepreneurship minor at UCLA. He plans on attending law school after graduation to pursue a career as a trial attorney. With experiences at the Los Angeles District Attorney’s Office, United States District Court, and serving the greater Los Angeles community as a legal volunteer for JusticeCorps, Alex has solidified his passion for helping others through the law. He currently works as a legal assistant at a boutique real estate firm in Beverly Hills and serves as the Political Affairs Chair for the UCLA Armenian Students’ Association.
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Kalani Castillo
Senior Editor | Class of ‘26
Kalani is a rising fourth-year student at UCLA majoring in Political Science and Chicana/o Studies with a minor in Labor Studies. She has worked as a Legal Administrative Assistant at the UCLA Undocumented Student Center and completed a legal internship in the summer of 2024 at Taraneh Khorrami’s immigration law firm. Previously, Kalani was an editor for Volume 23 of the Journal and was involved in the UCLA Law Fellowship Program, where she engaged with attorneys, law school professors, and current law students. She is a resident of the Central Valley and is interested in protecting the rights of the Latino community. Upon graduation, Kalani plans to attend law school to pursue a legal career in immigration law.
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Samantha Parr
Senior Editor | Class of ‘26
Samantha is a rising fourth-year student at UCLA majoring in Political Science and minoring in Community Engagement and Social Change. She has previously interned at The White House and the U.S. House of Representatives, and her career interests include public interest law and social entrepreneurship.

Meet the Contributors
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Christian Choi
Writer | Class of ‘25
Christian graduated this past Spring from UCLA where he studied Public Affairs with a background in child welfare. He has previously served as an AmeriCorps volunteer and a research assistant for a university program supporting foster youth. He is currently interning at the Children’s Law Center of California, and hopes to pursue a legal career advocating for the rights of children and families in dependency court. Outside of the classroom, he enjoys long-distance running, discovering new music, and spending time with his four beloved critters back at home.
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Sacha Franjola
Editor | Class of ‘26
Sacha is a rising fourth-year at Kenyon College, where she majors in Art History, minors in Classics, and has a concentration in Legal Studies. Her academic research focuses on the looting, collecting, and sale of ancient art and the legal issues therein, and she will be working on an honors thesis in that subject area during the 2025-26 school year. Following her graduation from Kenyon, she plans to attend law school and pursue a career practicing law in the international context. Outside of academics, Sacha is an incoming Editor-in-Chief of the Kenyon Collegian Newspaper, a Senior Admissions Fellow in Kenyon's Office of Admissions, and the competition coordinator for Kenyon's ballroom dance club.
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Brianna Gonzalez Ulloa
Writer | Class of ‘26
Brianna is a third-year undergraduate at UCLA pursuing a double major in English and Psychology. She intends to pursue law and specialize in public interest law, focusing on impact litigation that advances protections for children and structurally marginalized populations. Her academic and professional interests center on the nexus of legal advocacy, trauma-informed policy, and educational equity. She is committed to leveraging the law both as a tool for direct redress through litigation and as a mechanism for systemic reform through durable policy interventions.
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Hillah Greenberg
Editor | Class of ‘26
Hillah is a first-generation rising fourth-year Philosophy pre-law student at UCLA. She is interested in AI governance, regulation, and policy. She focuses on the intersection of law, philosophy, and technology, with emphasis on algorithmic accountability, data ethics, and the legal shaping of technological development. Before law school, she plans to further explore opportunities in journalism and policy work, then pursue a legal career in intellectual property or privacy law.
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Matthew Inui
Writer | Class of ‘28
Matthew is a rising second-year student at UCLA double-majoring in Political Science and Economics. Besides writing for the UCLA Undergraduate Law Journal, Matthew is also a writer and editor with the Bruin Political Review, The Generation, and the AAPI Undergraduate Law Journal. He is also the treasurer of the AAPI Pre-Law Society and a volunteer with the Volunteer Income Tax Assistance (VITA) program. Matthew plans to attend law school after graduation and hopes to specialize in international law, with a focus on East Asia.
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Alyssandra Lachica
Writer | Class of ‘26
Alyssandra is a rising fourth-year Political Science major at UCLA with a strong commitment to social justice and equality for all. After graduating, she plans to attend law school and pursue a career as a civil rights attorney to advocate for the protection of LGBTQ+ and women’s rights. On campus, Alyssandra serves as an Associate Justice for USAC's Judicial Board and plays cymbals for the UCLA Bruin Marching Band. She also interns at the Office of Congresswoman Judy Chu, where she has deepened her dedication to defending underserved communities. In her free time, she competes in marching competitions with Pulse Percussion and the Santa Clara Vanguard.
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Isabella Marasco
Editor | Class of ‘26
Isabella is a rising fourth-year student at UCLA majoring in Political Science, with minors in Film, Television, and Digital Media and English. She has further explored her interests in law, literature, and political theory through study abroad programs at the University of Cambridge and the London School of Economics. This summer, she looks forward to gaining legal experience with the Los Angeles District Attorney’s Office. After graduation, Isabella plans to attend law school and specialize in Entertainment and Media Law.
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Kaiyi Pan
Editor | Class of ‘27
Kaiyi is a rising third-year student at UCLA, majoring in Political Science and Economics with a minor in Music Industry. Beyond her work with the Journal, she serves as an editor for the Business Law Review within the Business Law/Investing Society, Director of Research at the Vanguard Think Tank, and Lead Developmental Editor for Aleph, UCLA’s Undergraduate Research Journal for the Humanities and Social Sciences. Kaiyi plans to attend law school after graduation and is particularly interested in pursuing a legal career in entertainment or immigration law.
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Robert Paronyan
Writer | Class of ‘25
Robert is a Spring 2025 graduate from CSUN where he majored in Computer. He has with professional experience as a Software Engineer in both industrial and large-scale consumer tech environments. His research interests lie at the intersection of corporate governance, securities regulation, and the economic implications of legal frameworks. His recent work explores board oversight liability in the context of ESG compliance and greenwashing litigation.
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Sam Rafizad
Editor | Class of ‘24
Sam majored in political science with an international relations concentration and history minor. He is interested in the nexus between the law and international security. In addition to serving as an editor at the Journal, Sam is currently a Herbert Scoville Jr. Peace Fellow working at the James Martin Center for Nonproliferation Studies in Washington, DC. Sam enjoys reading, playing the guitar, and hammocking.
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Shivanshi Sharma
Editor | Class of ‘27
Shivanshi is rising third-year at UCLA studying Neuroscience. She is interested in exploring how an understanding of Neuroscience can enhance our justice system. She is from San Diego, California and enjoys spending time with her family and beagle, drinking coffee, and being active. Upon graduation, she hopes to attend law school.
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Anton Stover
Writer | Class of ‘26
Anton is a rising fourth-year History Major and American Indian Studies, Global Studies, and Public Affairs triple minor at UCLA interested in tribal and constitutional law. He is interested in the connections between history, law, an policy, especially as it relates to Indigenous groups in the United States. Outside of the ULJ, he is on the board of Model United Nations at UCLA, the History Honors Society, and the History Undergraduate Advisory Board, as well as a writer for the Bruin Review.
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Adrian Tam
Writer | Class of ‘26
Adrian is a rising fourth-year Economics major and History minor at UCLA. He is interested in international law, particularly how the interplay between global economic systems and historical precedents shapes legal institutions. He aims to contribute to the development of frameworks that promote justice, stability, and equitable governance in an increasingly interconnected world.
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Kira Tran
Editor | Class of ‘28
Kira is a rising second-year Mathematics and Economics major at UCLA. Outside of the Journal, she is a consultant at Net Impact at UCLA, where she contributes to social impact consulting projects focused on sustainable and ethical change. Her academic and professional interests lie in the intersection of data, sustainability, law, and business. She eventually plans to attend law school and pursue a career that bridges public interest and corporate responsibility.
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Isabelle Verduzco
Editor | Class of ‘26
Isabelle is a rising fourth-year Political Science and English major at UCLA. She plans to attend law school in hopes of becoming a litigator for cases related to immigration, family law, or technology. Beyond serving as an editor for the Journal, Isabelle has experience working with nonprofits such as the League of United Latin American Citizens (LULAC) on advocacy and lobbying, has been a Social Justice writer for Davis Vanguard, and is the current Art Director for The Writer’s Den at UCLA. In her free time, Isabelle is a freelance illustrator and enjoys hiking, reading science-fiction, and writing creatively.

Browse Articles
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The Uncertain Future of Title IV-E Litigation in a Post-Chevron Era
Writer: Christian Choi | Editor: Isabelle Verduzco
Abstract: Chevron U.S.A., Inc. v. Natural Resources Defense Council (1984) was a cornerstone of administrative law, governing the United States executive branch’s role in resolving statutory ambiguities where courts could not. This framework allowed federal agencies to apply their subject-matter expertise in administering complex regulatory schemes set out by Congressional statutes. The Supreme Court’s decision in Loper Bright Enterprises v. Raimondo (2024) overruled Chevron, no longer giving agencies special deference and holding that federal courts must now exercise sole authority in interpreting the meaning of statutes. Loper Bright is sure to disrupt the landscape of administrative law, and has already been speculated to leave agency regulations vulnerable to legal challenges and weaken the authority of agency guidance. As one of the most cited Supreme Court decisions of all time, the death of Chevron will fundamentally reshape administrative law jurisprudence. This article situates Loper Bright within the broader debate over agency deference and examines its effects on child welfare governance, specifically on the Department of Health and Human Services’ (HHS) enforcement of Title IV-E regulations outlined in the Social Security Act. Loper Bright and the recent winds of curtailing agency power leaves the HHS vulnerable to rogue litigation, ultimately threatening the efficacy of Title IV-E enforcement, a crucial regulatory tool for ensuring best child welfare practices.
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Deepfakes, Digital Consent, and Non- Consensual Harm: Redefining Sexual Exploitation in the Age of Artificial Intelligence
Writer: Brianna Gonzalez Ulloa | Editor: Kaiyi Pan
Abstract: Deepfake technology has revolutionized how sexual images can be generated and distributed online, raising critical questions about consent, privacy, and legal accountability. This article examines how courts have traditionally treated sexually exploitative imagery—particularly through child pornography jurisprudence and revenge pornography statutes—and argues that existing legal frameworks are ill-suited to address the unique harms posed by non-consensual deepfake pornography. By synthesizing principles from New York v. Ferber and its progeny, as well as recent state and federal efforts to combat image-based sexual abuse, the article posits that deepfake pornography should be classified as a distinct form of sexual exploitation. A modified Miller v. California standard is proposed to regulate such content to be more centered on consent, identifiable harm to real victims, and the wide-ranging consequences of digital circulation. Miller, which established the current legal test for obscenity, is reexamined here through the lens of technological evolution and victim-centered harm. In doing so, the article offers a path toward safeguarding individual autonomy in the age of artificial intelligence and ensuring that the law keeps pace with rapidly evolving technological threats.
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Immunity on Trial: Rethinking a Jus Cogens Exception for the Korean Comfort Women Cases
Writer: Matthew Inui | Editor: Sacha Franjola
Abstract: Although sovereign immunity is a well-established principle of international law, recent developments have challenged its application in cases involving gross human rights violations—especially those that breach jus cogens norms. One of the most visible modern examples is a civil case brought by Korean comfort women against Japan for the forced sexual slavery they endured during World War II. In a move that was perhaps ahead of its time, the Korean court sided with the plaintiffs, ruling that sovereign immunity does not apply to gross human rights abuses. While this diverges from a longstanding precedent set by the International Court of Justice (ICJ), the Korean court’s decision reflects a growing trend in international legal thinking—one that rejects sovereign immunity for violations of jus cogens human rights norms. This article argues that in light of recent developments in state practice and evolving understandings of customary law, the Korean courts were justified in recognizing the validity of the comfort women’s case. Although far from establishing any universal legal principle, the decision by the Korean courts made an essential contribution to a new component of international customary law: a jus cogens exception to the law of sovereign immunity.
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When Executive Criminal Activity Meets Presidential Immunity: A Legal Positivist Approach to Trump v. United States
Writer: Alyssandra Lachica | Editor: Isabella Marasco
Abstract: In the aftermath of the January 6th attack on the United States Capitol, questions of presidential accountability and executive authority have come to define a pivotal moment in American legal and constitutional history. Such a reckoning became subject to legal scrutiny in the landmark case Trump v. United States (2024), where the Supreme Court ruled that official actions that fall under the president’s “conclusive and preclusive authority” are immune from criminal prosecution. This decision, aimed at preserving the autonomy of the executive branch, has faced widespread criticism for its lack of constitutional grounding and utter disregard for historical precedent. The ruling’s ability to undermine the principle of accountability has already been tested during Donald Trump’s second presidential term, where scholars are defining his series of executive orders as a “constitutional crisis.” This article aims to critique the Supreme Court’s ruling in Trump by applying legal positivist H.L.A. Hart’s framework of primary and secondary rules. Hart’s theory—which defines primary rules as imposing societal obligations and secondary rules as establishing the structure for creating, amending, and adjudicating those obligations—provides a lens to critically examine the Court’s flawed reasoning. Building on this critique, this article proposes a new framework for assessing presidential immunity that incorporates intent. This approach distinguishes between lawful and unlawful actions within the executive branch’s constitutional authority and draws a line between official and unofficial actions of the president. Using this framework, the article revisits the Trump decision, arguing for its reversal to restore the balance of power among the branches of government and to uphold the principle that all public officials should be subject to the rule of law. -
Guarding Against Greenwashing: ESG Oversight and Board Accountability Under Caremark
Writer: Robert Paronyan | Editor: Shivanshi Sharma
Abstract: Environmental, social, and governance (ESG) factors have become central to corporate strategy, resulting in the rise of greenwashing—misleading or exaggerated ESG claims. This raises concerns about corporate accountability. While the Securities and Exchange Commission (SEC) has brought enforcement actions against greenwashing under Rule 10b-5, which outlaws securities fraud, these regulatory violations also open a board of directors up to Caremark oversight failures. This article argues that greenwashing constitutes a mission critical risk under Caremark and courts should recognize greenwashing related oversight failures as a basis for director liability. Building on the Caremark framework established in Marchand v. Barnhill and In re Clovis Oncology, Inc., this article presents two paths for shareholders to hold corporate boards accountable for greenwashing. First, the regulatory piggyback theory demonstrates how SEC enforcement actions can bolster the validity of Caremark claims, as courts increasingly recognize regulatory scrutiny as an indicator of mission critical oversight failures. Second, even in the absence of enforcement, greenwashing can independently qualify as mission critical when it directly impacts a company’s core business operations. This article applies Caremark’s two-pronged test to three forms of greenwashing—unverifiable ESG claims, unmet sustainability pledges, and misuse of certified labels—to show how each can lead to Caremark liability.
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Native American Treaties: The Necessity of Historically-Informed Fiduciary Duty
Writer: Anton Stover | Editor: Sam Razifad
Abstract: The over 200 treaties created between the United States and various Indigenous nations between 1776 and 1871 provide the basis for modern-day Indigenous land holdings and the protection of the resources on tribal lands, but they remain insufficient. Native American treaties have a long history with the Supreme Court, resulting in requirements of redress that create high barriers for Indigenous nations. Currently, treaties form the basis of several suits, including the recent Arizona v. Navajo Nation (2023). These build off of principles of “fiduciary duty” between the United States and Indigenous groups and dispute whether the United States has adequately provided for the materials in treaties. This article will discuss treaties to piece together both the ways in which treaty law creates a confusing system, and the difficulties that Indigenous groups have in modern times to get adequate redress through enforcement of treaty rights. This article will advocate for the application of common law principles to these decisions, as well as a more historically and culturally-informed understanding of Indigenous concepts of treaties.
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The Coup De Grâce to Hong Kong’s Rule of Law: Article 23 and its Civil Ramifications
Writer: Adrian Tam | Editor: Hillah Greenberg
Abstract: Since Hong Kong’s return to Chinese sovereignty, the Central People’s Government (CPG) has persistently encroached upon the city’s promised autonomy. Article 23 of the Basic Law, which ostensibly grants Hong Kong the authority to enact national security legislation of its own accord, has paradoxically enabled direct CPG intervention. Its vague and expansive provisions have facilitated legal overreach by undermining the city’s political and legal independence. The government’s response to the 2019 Anti-Extradition protests—the 2020 National Security Law and the 2024 Safeguarding National Security Ordinance—reflects a growing reliance on legislative ambiguity. These laws, laden with redundant and obscure provisions, escalate penalties for offenses already criminalized under colonial-era statutes and significantly expand state authority over dissent. The article argues that the enactment of these laws raises concerns regarding their constitutionality, necessity, and compliance with human rights obligations. Compounding these concerns is the judiciary’s inconsistent approach to national security cases, which has weakened public confidence in its neutrality and raised fears of selective enforcement. This article concludes that preserving Hong Kong’s autonomy and its human rights obligations under the One Country, Two Systems framework is essential to maintaining the city’s global standing. As Hong Kong grapples with a deepening crisis of confidence in its legal and political institutions—exacerbated by the government’s aggressive enforcement of national security laws—it must resist further erosion of its legal independence and prevent further unchecked expansion of national security legislation.