In the securities context, Lynn Katzler of American University's Washington College of Law later described Byrd as continuing "the slow destruction of the Wilko doctrine" that began with Scherk and culminated in Rodriguez de Quijas.
Subsequently, he obtained a grant to study an LLM in Law and Government at the Washington College of Law, in Washington, DC, USA, specializing in Finance.
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The neighborhood houses the main campus of American University at 4400 Massachusetts Avenue, the Wesley Theological Seminary at 4500 Massachusetts Avenue, and Washington College of Law at 4801 Massachusetts Avenue and 4910 Massachusetts Avenue.
Several distinguished members of the bar clerked for Duhé, including Washington College of Law (American University) professor David Snyder, and Ernest Metzger, the Douglas Professor of Civil Law at the University of Glasgow in Scotland.