Alison Frankel reports:
Law professor Adam Pritchard of the University of Michigan has done Judge Rakoff one better. In a draft version of a paper to be published later this year in the SMU Law Review, Pritchard delved into the papers of Justice Lewis Powell, author of the Supreme Court’s Dirks opinion, to conclude that the 2nd Circuit’s interpretation of what constitutes a personal benefit for tipsters “is consistent with, if not compelled by, the rule laid down in Dirks.”
Kindly go read the whole thing and then follow the link to Pritchard's paper.