Bernal-Rodriguez v. United States

How later courts describe this case

• in remittitur case can appeal issue only if "separate and distinct" claim from subject matter of remittitur
• SUNY is an integral part of the government of New York State, and when it is sued the state is the real party
• “[o]n only one occasion has the Supreme Court struck down a state statute as violative of the. foreign relations power”
• scientist employed by a firm under contract with the National Cancer Institute was a limited purpose public figure
• review of the merits is within court’s discretion
• requiring plaintiffs to establish five separate elements