I came across the title page for a paper I wrote about Certificates-of-Need(“CON”) during 3L. Certificate-of-Need (“CON”) laws are used by the states to control the entry into the market of new health care providers, with the purpose of keeping health care prices low, preventing an overabundance of supply, and ensuring that sufficient funds exist to care for poor patients. Critics of CON laws argue that these laws create barriers to entry, raise costs of health care, limit the supply of health care services, and inhibit the development of new and innovative ways to treat patients.

I chuckled at the title page, which is, of course, a pun on the famous quote from the DaVinci Code (“So Dark the Con of Man”). I wrote this paper for an FTC seminar my 3L year with Professor Tim Muris (who happened to be the former Commissioner of the FTC).