An article in stated that on November 21st, the American Bar Association filed an amicus brief with the U.S. Supreme Court, “urging it to find that private lawyers representing public agencies are entitled to increased immunity from lawsuits.” Professor Rotunda commented on the complexity of the issue regarding immunity for private sector employees; “So much of immunity is common law. Congress could take care of it by statute, […] But the court has been reluctant to extend qualified immunity to private firms of individuals acting on behalf of the government. For example, the courts have not wanted to grant qualified immunity to prison guards operating in a private prison.” Read more about the amicus brief and what Professor Rotunda had to say.