
Samuel A.A. Levine
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Sep 22, 2026
059 Samuel Levine: bottom-up lawyering
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40:45KhurramHOST
How do you think about allocating resources across groups that have maybe materially different circumstances and resources?

Samuel LevineGUEST
I want to help the most vulnerable people because I think that's where we can do the most good.

Samuel LevineGUEST
If a millionaire gets their $10 back, that's sort of a moral victory for them.

Samuel LevineGUEST
Perhaps if someone's struggling to get $10 back, that means they can fill their cart.

Samuel LevineGUEST
I think, well, with grocery prices, what they are these days, I'm not sure how much you can do with $10, but it's a lot more meaningful to them.

Samuel LevineGUEST
And I think if you look at our work, there's a big focus on who are the most vulnerable workers, who are the most vulnerable consumers.

Samuel LevineGUEST
So to take a few examples, there's been a big focus historically at this agency and certainly under my leadership on immigrants, making clear that immigrants who face exploitation, retaliation, we've had, I've had, Folks tell me and organizations tell me that immigrants who want to report violations to us, but their bosses will threaten to take them to ICE.
10 MINS LATER
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51:56KhurramHOST
Can you talk some more about a comparison of FTC and the role that you had there in working with lawmakers or rulemakers and how you're approaching that today in your practice at the city?
Episode 37: Rescuing Privacy and Consumer Protection w/ Samuel Levine
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Alan ChapellHOST
But I'm curious, how were you able to move past talking about ethereal harms to actually enforcing against those types of harms?

Samuel LevineGUEST
Here again, and we could talk about whether the harms are really ethereal, but the way I would put it is non-financial harms, harms that are not consumers directly losing money.

Samuel LevineGUEST
And here again, I want to do a little bit of history here because in that same policy statement where the FTC said that markets were self-correcting, it said that even though Congress simply said, go after unfair practices, the FTC on its own without any statutory basis said, we're really only going to focus on financial harms.

Samuel LevineGUEST
Non-financial harms, they gave an example of emotional distress, are not going to be actionable.

Samuel LevineGUEST
I can't emphasize enough, this was a agency veto of congressional directive, right? This was not in the FTC Act.

Samuel LevineGUEST
In the early 2000s, the chairman of the FTC, Tim Uris, he was the chairman of the FTC, He would take the position that unfairness simply can't reach information sharing, data sharing practices because of the limits self-imposed in the 1980 policy statement.