David Kinnaird is a Research Fellow at the Georgetown Center for the Constitution. His current research focuses on the effect of fraud on the validity of a judgment in civil and criminal cases and the due process implications of such fraud. He has also written an article on the historic scope of inquiry on a writ of habeas corpus, which is forthcoming in the Notre Dame Law Review. He holds a J.D. from the University of Virginia School of Law and a B.A. in Classical Studies from the University of Pennsylvania.