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Since this feat, only six other actors have managed it: Peter O'Toole for playing Henry II

Vehicles: Cars present unique challenges due to their enclosed nature and abundance of absorbent materials

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The basic rule is that state action exists if the dispute is tort-related or if the rights arise from a state statute, but does not exist if the dispute arises from a contractual relationship or involves common-law property rights, unless a non-judicial state actor is involved or if racial discrimination is implicated. [If you want a way to make Shelley seem less weird, Carol Rose has a great explanation of why enforcing some contracts implicates the state in unconstitutional positions, e.g., that racial discrimination is acceptable

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