The case was superseded by Scheidler v. National Organization for Women in 2003.
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He argued on behalf of the Securities Investor Protection Corporation in what became Holmes v. SIPC (1992); he argued on behalf of pro-life activist Joseph Scheidler in what became Scheidler v. National Organization for Women (2006), and he argued on behalf of the beneficiaries of insurance policies in what became Humana, Inc. v. Forsyth (1999).