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The following references may be useful when improving this article in the future:
Erwin Chemerinsky & Ned Miltenberg, The Need to Clarify the Meaning of U.S. Supreme Court Remands: The Lessons of Punitive Damages’ Cases, 36 Arizona Law Journal 513-526 (2004)
J. M. Armbruster, Deciding Not to Decide: The Supreme Court's Expanding Use of the GVR Power Continued in Thomas v. American Home Products, Inc. and Department of the Interior v. South Dakota, 76 N.C. L. Rev. 1387 (1998).
Aaron-Andrew P. Bruhl, The Supreme Court's Controversial GVRs - And an Alternative, 107 Mich. L. Rev. 711 (2009).
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