Bernal-Rodriguez v. United States

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 | in remittitur case can appeal issue only if “separate and distinct” claim from subject matter of remittitur | “[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