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Although Justice Scalia agreed with the plurality that the term "State law" in 5(b) of the 1969 Act "reaches beyond [positive] enactments" to also encompass state common law, he advocated for a test of "practical compulsion" or "proximate application" to determine whether state law claims were preempted by the FCLAA

In Jerusalem, smoke filled the air as some religious Jews burned the last of their bread crumbs while others dunked their plates in large vats of hot water set up around the city, so their dishes would be completely free of bread products

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