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On April 7, 1996, a New Jersey police officer chanced upon Vladimir Zelenin dumping body the chopped-up body of his former boss, Yakov Gluzman, into the Passaic River. Disposing of human remains in a river is against the law, even in New Jersey, and Zelenin was promptly arrested. His subsequent confession led to the arrest and conviction of Yakov’s wife, Rita Gluzman, under the Violence Against Women Act of 1994. Rita, it seemed, had enlisted Zelenin, her cousin, in the murderous plot. She has challenged her conviction, and the outcome of that challenge may determine the direction of federalism in the new century.

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