Andrea Kwon's essay on People v. Hall (1854) is sloppy at best and unprofessional at worse. Her essay cites as a source a very short article from the California Supreme Court Historical Society by Michael Traynor, when Traynor was clear in his own citation notes that the source was another writer (me). I wrote an essay on People v. Hall for ABC-Clio in 2016, and Kwon knew of my essay, certainly read my essay, and skirted around her responsibility as a Berkeley-trained, Ph.D. historian to credit my work.