Peter J. Bresson - Page 42

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          controlling.  What is dispositive is that the right that the                
          Government claims to possess against petitioner as a transferee is          
          nonexistent but for the provisions of California State law, and             
          California has decided to provide only a temporal right against             
          transferees in these instances.  Respondent and the majority may            
          regret that California did not provide a different rule than it             
          did, but it is not our province to legislate on behalf of the               
          States.  In limited circumstances, as illustrated by the Summerlin          
          doctrine, we may ignore State statutes of limitations, but that is          
          the extent of our authority.  To hold otherwise is an encroachment          
          on State sovereignty and raises problematic constitutional issues.          
               WHALEN, BEGHE, and THORNTON, JJ., agree with this dissenting           
          opinion.                                                                    























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