University of Baltimore Law Review

Will the Supreme Court’s Desire to Combat Homelessness Limit FIFA’s Human Rights Goals?

*Calista Heister

I. Introduction

The United States will be one of the host countries of the 2026 FIFA World Cup across eleven host cities.^[1] During this global soccer tournament, host cities will follow a framework to accommodate the large crowds and ensure a safe event for all.^[2] Human rights concerns repeatedly arise during the FIFA World Cup, as well as other sporting events such as the Olympics, when international laws coincide with the domestic laws of host States.^[3] The United States needs to address the potential for human displacement that has occurred at previous events, such as the Paris Olympics.^[4] For the first time, Federation International Football Association (FIFA), the soccer governing body, is implementing a human rights framework called the FWC26 Human Rights Framework that aims to combat the concerns of potential human rights violations, including the displacement of homeless people in American cities.^[5] The United States Supreme Court recently decided, in City of Grants Pass v. Johnson, that governing encampments of homeless people does not constitute “cruel and unusual punishment” under the Eighth Amendment.^[6] As the 2026 FIFA World Cup approaches, the Supreme Court’s encampment ordinances decision poses a concern for the safety and fair treatment of those experiencing homelessness who may be displaced.^[7]

Deepfakes in the Courtroom: Challenges in Authenticating Evidence and Jury Evaluation

*Colin Livingston

I. Introduction

In a UK child custody dispute, a mother presented a “heavily doctored recording” in court to portray the father as “violent and threatening” in an effort to deny him access to his children.^[1] The father’s attorney successfully challenged the recording’s authenticity and warned that “it would never occur to most judges that deepfake material could be submitted as evidence.”^[2] Advances in technology and AI have enabled the creation of “deepfake” content that convincingly portrays individuals as doing or saying things that never occurred.^[3] Courts must now assess the authenticity of evidence that may have been altered in ways that make manipulation difficult to detect.^[4] As AI technology advances and deepfakes become easier to produce,^[5] courts can expect more cases that challenge the application of traditional evidentiary rules and frameworks.^[6]

English-Speakers Only: English as the Official Language of the United States and the Potential Rise in National Origin Discrimination Claims

*Nikkie Navarro

I. Introduction

A Hispanic mother called her local police station after a Chevrolet Avalanche ran over her daughter’s foot.^[1] Neither the mother nor the father spoke English fluently, and the responding officers, who spoke no Spanish, failed to request an interpreter.^[2] The officers refused to provide the parents with the driver’s information and told the father that, if he asked for a report, the officers would show that their injured daughter was at fault.^[3] The family sued the police station on their daughter’s behalf for multiple claims, including Title VI national origin discrimination.^[4]

When the Sixth Circuit Goes Rogue: Bivens v. Zep, Inc. and Title VII Confusion

*Macy Hamlett

I. Introduction

The Sixth Circuit recently decided in Bivens v. Zep, Inc. that an employer cannot be held liable for third-party actions under Title VII of the Civil Rights Act of 1964 unless they “‘intend[ed]’ for the relevant unlawful ‘consequence.’”^[1] The Bivens decision creates a new obstacle for employees to hold their employers accountable for harassment by third parties.^[2] While the Bivens decision seems to come out of thin air, two recent Supreme Court decisions have teed up this outcome to suggest otherwise.^[3] In 2020, the Supreme Court decided Bostock v. Clayton County, which emphasized the intent of employers under Title VII.^[4] Then in 2024, the Supreme Court decided Loper Bright Enterprises v. Raimondo, which empowered Biven’s reinforcement of the Equal Employment Opportunity Commissions (“EEOC”) limited interpretive authority over Title VII.^[5] Bostock emphasized that when an employer intentionally treats an employee worse because of their membership in a protected class, Title VII is violated.^[6] Further, Loper Bright highlighted that agency interpretations of statutes, such as those by the EEOC, should no longer be treated with deference.^[7] Combined, these decisions laid the foundation for the Sixth Circuit’s rationale in Bivens.^[8]

Transgender Athletes’ Rights and Opportunities: Idaho Tests the Bounds of the Supreme Court’s Transgender and Heightened Scrutiny Decisions.

*Meaghan Slattery

I. Introduction

On July 3, 2025, the U.S. Supreme Court granted certiorari to hear Little v. Hecox to decide on the issue of “[w]hether laws that seek to protect women’s and girls’ sports by limiting participation to women and girls based on sex violate the equal protection clause of the Fourteenth Amendment.”^[1] The case may establish a definitive level of scrutiny for courts to apply to legislation affecting transgender individuals, specifically transgender athletes.^[2]