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Posts by Alan Chen

Great comeback!!

8 hours ago 1 0 0 0

Congratulations!! 👏👏👏

4 days ago 0 0 0 0
A group of Denver hockey team players wearing white uniforms and hats with "Champions" written on them celebrate on the ice. They are smiling and pointing, with excitement and camaraderie evident.

A group of Denver hockey team players wearing white uniforms and hats with "Champions" written on them celebrate on the ice. They are smiling and pointing, with excitement and camaraderie evident.

Raising the standard. 🏆 https://bit.ly/4c4BM2W

#DUHockey has claimed its 11th national championship—the most in NCAA men’s hockey history. Relive the unforgettable moments and discover upcoming community celebrations at the link above.

📸: NCAA Photos
#C11ampions x #UniversityofDenver

1 week ago 3 3 0 0

Let's go @uofdenver.bsky.social men's hockey!!!

1 week ago 1 0 0 0

Fanatics?

1 week ago 1 0 0 0

Fake news?!?

1 week ago 1 0 0 0

The Twins got saves from 4 different pitchers over the last 4 days-Laweryson, Topa, Funderburk, and Orze. Has that ever happened before @slangsonsports.bsky.social ?

1 week ago 0 0 1 0

Don’t know if anyone has already posted this, but the Twins got saves from 4 different pitchers over the last 4 days-Laweryson, Topa, Funderburk, and Orze (which are clearly made up names😂)! @dvr.bsky.social @enosarris.bsky.social

1 week ago 3 0 0 0

Thx!

1 week ago 0 0 0 0

In my home league, I spent a lot for Tatis & Chisholm. Tatis is hitting ball hard (xwOBA .345) but has .276 BABIP, so maybe some bad luck. Chisholm's more worrying w/ xwOBA of .221 & a .296 BABIP. Small samp sizes but any thoughts? @enosarris.bsky.social @dvr.bsky.social @chadyoung.bsky.social

1 week ago 0 0 2 0
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Congratulations to Jose Ramirez, who now holds the record for the most games played by a Cleveland baseball player in franchise history!! 🐐👏👏👏⚾️ #Guardians

2 weeks ago 4 0 0 0

Consecutive series wins against the Dodgers and Cubs. Go Guards!! #Guardians

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2 weeks ago 1 0 0 0

You realize these people have such a limited career window that an injury for a couple of months would be the equivalent of the rest of us losing a several years in the workplace.

2 weeks ago 0 0 0 0

Chase DeLauter with his 5th HR on the young season puts the Guardians up 4-1 on the Cubs!! #Guardians

2 weeks ago 4 0 0 0

Congrats on the article, Bailey!!

2 weeks ago 1 0 0 0
FACTUAL IMMUNITY

Bailey D. Barnes

111 MINNESOTA LAW REVIEW — (forthcoming 2026)

ABSTRACT

Qualified immunity protects government agents from suit and liability unless they deprive another of a clearly established right. This Article argues that constitutional tort litigation is also affected by a supplemental barrier for plaintiffs seeking relief: factual immunity. By making inherent credibility determinations and subtly weighing evidence in favor of government defendants on summary judgment, courts are protecting officials from trial despite the presence of genuine disputes of material fact in the record.

Relying on close analysis of recent appellate decisions, this Article shows how some judges credit officers' testimony, discount plaintiffs' evidence, and regard evidentiary ambiguities as reasons to grant, rather than deny, qualified immunity on summary judgment. Unlike qualified immunity, factual immunity is not grounded in the common law. It is a distortion of the summary judgment standard that reallocates fact-finding responsibility from juries to judges, depriving plaintiffs of accountability and weakening the constitutional tort system.

This Article makes three core contributions. First, it names and theorizes factual immunity, identifying how courts convert factual doubt into deference to defendants. Second, it acknowledges the institutional pressures that incentivize its use, including the Supreme Court's one-sided qualified immunity signaling and misapplications of Scott u.
Harris's blatant contradiction exception. Lastly, it describes how factual immunity magnifies the harms of qualified immunity by stunting constitutional development, undermining deterrence, and denying injured plaintiffs their constitutional right to a jury.

This Article concludes with proposals to restore the boundary between law and fact in constitutional tort litigation. Qualified immunity may be here to stay; factual immunity should not.

FACTUAL IMMUNITY Bailey D. Barnes 111 MINNESOTA LAW REVIEW — (forthcoming 2026) ABSTRACT Qualified immunity protects government agents from suit and liability unless they deprive another of a clearly established right. This Article argues that constitutional tort litigation is also affected by a supplemental barrier for plaintiffs seeking relief: factual immunity. By making inherent credibility determinations and subtly weighing evidence in favor of government defendants on summary judgment, courts are protecting officials from trial despite the presence of genuine disputes of material fact in the record. Relying on close analysis of recent appellate decisions, this Article shows how some judges credit officers' testimony, discount plaintiffs' evidence, and regard evidentiary ambiguities as reasons to grant, rather than deny, qualified immunity on summary judgment. Unlike qualified immunity, factual immunity is not grounded in the common law. It is a distortion of the summary judgment standard that reallocates fact-finding responsibility from juries to judges, depriving plaintiffs of accountability and weakening the constitutional tort system. This Article makes three core contributions. First, it names and theorizes factual immunity, identifying how courts convert factual doubt into deference to defendants. Second, it acknowledges the institutional pressures that incentivize its use, including the Supreme Court's one-sided qualified immunity signaling and misapplications of Scott u. Harris's blatant contradiction exception. Lastly, it describes how factual immunity magnifies the harms of qualified immunity by stunting constitutional development, undermining deterrence, and denying injured plaintiffs their constitutional right to a jury. This Article concludes with proposals to restore the boundary between law and fact in constitutional tort litigation. Qualified immunity may be here to stay; factual immunity should not.

My article, Factual Immunity, is forthcoming in the Minnesota Law Review. I argue that, alongside qualified immunity, some courts in constitutional tort suits employ what I call factual immunity by crediting officer testimony & discounting plaintiffs’ stories at summary judgment when QI is raised.

2 weeks ago 25 13 2 0

No credit to Gavin Williams??

2 weeks ago 0 0 0 0

Huge early season series win for the Guardians on the road against the Dodgers!!

2 weeks ago 6 0 0 1

Beginning to regret getting hyped by @enosarris.bsky.social and making Caleb Durbin by starting 3B...

2 weeks ago 0 0 0 0
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Sandy Alcantara throws the first Maddux of the 2026 season!!! Not an April Fool's joke. @jasonlukehart.bsky.social

2 weeks ago 1 0 0 0

🙏🙏🙏

2 weeks ago 0 0 0 0

👆👆👆

2 weeks ago 0 0 0 0

On the platform and without Mel Allen, hard pass. Plenty of alternatives these days.

2 weeks ago 0 0 0 0

Evergreen

2 weeks ago 1 0 0 0

My daughter and I are going to the last show on the tour in DC!

2 weeks ago 1 0 0 0

Great write-up by @jayjaffe.bsky.social on Chase DeLauter's phenomenal debut for the Guardians!! Catch the Fever!!!

3 weeks ago 2 1 0 0

Chase DeLauter fever!!

3 weeks ago 6 0 0 0

Most games played, Cleveland history:

Terry Turner: 1,619
José Ramírez: 1,614
Nap Lajoie: 1,614

When he plays his 1,620th game, Ramírez will become the only active player to currently lead a franchise in games played

3 weeks ago 121 25 6 13

Runs!!!

3 weeks ago 1 0 0 0
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