decisions in Larson v. Domestic & Foreign Commerce Corporation, 337 U.S. 682 (1949) and Malone v. Bowdoin, 369 U.S. 643 (1962) sharply limited the impact of the Lee Court's decision. Larson and Malone specifically carved out only two areas in which an officer of the United States may be sued: 1) If the officer acts outside her or his legally prescribed scope of authority, or 2) If the officer acts in a way that is unconstitutional. At least one legal historian has concluded that Lee also laid an early foundation for the doctrine of executive immunity. In many ways, the Lee decision is also more famous for its defense of the rights of citizens than its sovereign immunity jurisprudence. Miller's defense of the rights of the individual ("No man...is above the law...") is considered "elegantly elaborated" by lawyer Lawrence Walsh. Constitutional law scholar Louise Weinberg called the language "ringing". Another legal scholar called the language "remarkable" and emphatic. Footnotes Bibliography Amar, Akhil Reed. "Of Sovereignty and Federalism." Yale Law Journal. 96:1425 (June 1987). "Arlington." Encyclopedia of the American Civil War: A Political, Social, and Military History. David Stephen Heidler, Jeanne T. Heidler, and David J. Coles, eds. New York: W.W. Norton & Co., 2000. "Arlington National Cemetery." In Encyclopedia of the Veteran in America. William Pencak, ed. Santa Barbara, Calif.: ABC-CLIO, 2009. Atkinson, Rick. Where Valor Rests: Arlington National Cemetery. Washington, D.C.: National Geographic Society, 2007. Berger, Eric. "The Collision of the Takings and State Sovereign Immunity Doctrines." Washington & Lee Law Review. 63:493 (Spring 2006). Chase, Enoch Aquila. "The Arlington Case: George Washington Custis Lee against the United States of America." Records of the Columbia Historical Society. 31/32: 1930. Durchslag, Melvyn R. State Sovereign Immunity: A Reference Guide to the United States Constitution. Westport, Conn.: Praeger, 2002. Grant, Eric. "A Revolutionary View of the Seventh Amendment and the Just Compensation Clause." Northwestern University Law Review. 91:144 (Fall 1996). Hansen, Harry. The Civil War: A History. New York: Signet, 2001. Holt, Dean W. American Military Cemeteries. Jefferson, N.C.: McFarland & Co., 2010. Jackson, Percival E. Dissent in the Supreme Court: A Chronology. Norman, Okla.: University of Oklahoma Press, 1969. Jacobs, Clyde Edward. The Eleventh Amendment and Sovereign Immunity. Westport, Conn.: Greenwood Press, 1972. Jaffee, Louis L. "Suits Against Governments and Officers: Sovereign Immunity." Harvard Law Review. 77:1 (1963). McCaslin, Richard B. Lee in the Shadow of Washington. Baton Rouge: Louisiana