Bernard J. Hibbitts, Associate Professor, University of Pittsburgh School of Law; B.A. (Juris.), Oxford University, 1983; LL.B. Dalhousie University, 1984; LL.M. University of Toronto, 1986; LL.M., Harvard Law School, 1988. E-mail: Hibbitts@law.pitt.edu I am very grateful to Welsh White for his comments on a previous draft of this article. William Curley made many invaluable contributions to the piece as my research assistant. Responsibility for the views contained herein - as well as for any mistakes or errors of interpretation - is, of course, mine alone.