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Other : * Clarify the sentence "This case outlines some limitations on the "fruit-and-tree" metaphor established in Lucas v. Earl, 281 U.S. 111 (1930) and further developed in Helvering v. Horst, 311 U.S. 112 (1940)."
The "Other Relevant Cases" section does not really show why those cases are relevant. At best it implies they are related. This section needs some cleanup.
