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https://scholarlycommons.law.hofstra.edu/hlr/vol37/iss1/5/ "Shared Sovereign Immunity as an Alternative to Federal Preemption: An " by Martin A. Kotler Beginning with the Supreme Court's 1992 decision in Cipollone, courts have engaged in the practice of parsing the preemption language of federal legislation... shared sovereignalternative tofederal preemptionimmunitymartin