The Louisiana Supreme Court recently cited Ashley M. Kearns’s student Note, South Carolina's Evolving Standards of Decency: Capital Child Rape Statute Provides a Reminder that Societal Progression Continues Through Action, Not Idleness. Ashley’s article appears in the Survey of South Carolina Law, Volume 58. The court refers to Ashley’s Note in State v. Kennedy, 957 So. 2d 757, 785–86 (2007). Ashley serves as an Associate Student Works Editor on the Volume 59 Editorial Board and will graduate in May 2008.