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==== Lower court cases ==== A number of cases which raised the bill of attainder issue did not reach or have not reached the Supreme Court, but were considered by lower courts. In 1990, in the wake of the [[Exxon Valdez oil spill]], Congress enacted the [[Oil Pollution Act of 1990|Oil Pollution Act]] to consolidate various oil spill and oil pollution statutes into a single unified law, and to provide for a statutory regime for handling oil spill cleanup. This law was challenged as a bill of attainder by the shipping division of [[ExxonMobil]].<ref>''SeaRiver Maritime Fin. Holdings, Inc. v. Pena'', 952 F.Supp. 9, D.D.C. 199.</ref><ref>Carringan, Alison C. "The Bill of Attainder Clause: A New Weapon to Challenge the Oil Pollution Act of 1990", ''Boston College Environmental Affairs Law Review'' 28:119 (2000).</ref> In 2003, the [[United States Court of Appeals for the District of Columbia Circuit]] struck down the [[Elizabeth Morgan Act]] as a bill of attainder.<ref>''Doris R. Foretich, et al. v. United States'', 351 F.3d 1198 (D.C.App. 2003); Leonning, Carol D. "Appeals Court Rules Against Morgan Law", ''Washington Post'' 17 December 2003.</ref> After the [[United States House of Representatives]] passed a resolution in late 2009 barring the community organising group [[Association of Community Organizations for Reform Now]] (ACORN) from receiving federal funding, the group sued the U.S. government.<ref>{{cite news |last=Fahim |first=Kareem |url=https://www.nytimes.com/2009/11/13/nyregion/13acorn.html |title=Acorn Sues Over Funding Vote in House |work=The New York Times |date=12 November 2009 |access-date=14 November 2010}}</ref> Another, broader bill, the Defund ACORN Act, was enacted by Congress later that year. In March 2010, a [[United States district court|federal district court]] declared the funding ban an unconstitutional bill of attainder.<ref>Farrell, Michael B. "Funding Gone, Scandal-Plagued ACORN to Disband". ''The Christian Science Monitor'', 23 March 2010.</ref> On 13 August 2010, the [[United States Court of Appeals for the Second Circuit]] reversed and remanded on the grounds that only 10 percent of ACORN's funding was federal and that did not constitute "punishment".<ref>"Federal Court Rules Against Acorn". [[Associated Press]]: 14 August 2010.</ref><ref>{{cite journal |title=ACORN v. United States |url=http://harvardlawreview.org/2011/01/second-circuit-holds-that-law-barring-acorn-from-receiving-federal-funding-is-not-a-bill-of-attainder-ae-acorn-v-united-states-618-f-3d-125-2d-cir-2010/ |journal=Harvard Law Review |access-date = 23 July 2015 |date=20 January 2011}}</ref>
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