Hannah Litvack

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Hannah Litvack

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Hannah Litvack serves as a Staff Editor for The Race to the Bottom Blog and is a second-year J.D. student.

Hannah earned her Bachelor of Arts degrees in Political Science and Public Policy from the University of Redlands, and her paralegal certificate from the University of San Diego School of Law. Before law school, she spent over four years as a litigation paralegal at firms including Duane Morris and Ogletree Deakins, where her labor and employment work introduced her to the compliance and governance challenges facing corporations.

During law school, Hannah externed with the Honorable Adam J. Espinosa of the Second Judicial District Court of Colorado in Summer 2026. She is currently a Fall 2026 extern at Empower, a global financial services and retirement plan provider, where she works on corporate transactions, employment, and litigation matters. Hannah is also a Staff Editor for the Denver Law Review and the Denver Sports and Entertainment Law Journal and is involved in OUTLaws. As a 1L, she was involved in the Student Trial Lawyers Association where she participated as prosecution and defense counsel in Denver Law’s 1L and Advocates Cup tournaments.

Outside of law school, she enjoys time at home with her cat, Pinkie, and two budgerigars, Ziggy and Stitch, along with hiking and exploring Colorado's outdoors.

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Deal or No Deal Again: What Kroger’s Failed Albertsons Merger Means for Its Giant Eagle Acquisition

On October 14, 2022, Kroger and Albertsons Companies announced a proposed $24.6 billion merger that would have combined two of the largest supermarket chains in the United States (Alina Selyukh, NPR). The Federal Trade Commission (“FTC”), joined by the District of Columbia and eight other states, filed an action in the United States District Court for the District of Oregon to block the proposed Albertsons acquisition under Section 7 of the Clayton Act, the federal antitrust statute barring mergers that may substantially lessen competition (Alina Selyukh, NPR). Colorado and Washington separately challenged the merger in their own state courts. Id. Federal and state courts halted the merger in December 2024, and the companies abandoned the transaction shortly thereafter, leaving Albertsons to pursue breach-of-contract claims in Delaware’s Court of Chancery against Kroger (Isaiah Poritz, Bloomberg Law). On July 1, 2026, Kroger announced a far smaller transaction: a $1.65 billion agreement to acquire regional grocer Giant Eagle, a deal that will add roughly 200 stores across five states to Kroger’s portfolio (The Kroger Co.). Using the Albertsons merger’s collapse as a backdrop, this post examines whether Kroger’s Giant Eagle acquisition can satisfy antitrust regulators by tracing why the Albertsons deal failed, weighing perspectives on Giant Eagle’s market impact, and forecasting how regulators will treat the new deal.

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Ninth Circuit Upholds Seattle’s App-Based Worker Deactivation Rights Ordinance

The rapid growth of the gig economy has prompted U.S. cities to consider how existing labor protections apply to app-based workers who can be removed from a platform, or “deactivated,” without notice or explanation. (Helen McFarland, Seyfarth Shaw LLP). Seattle moved to address that gap directly. Id. In August 2023, the Seattle City Council passed Ordinance 126878, the App-Based Worker Deactivation Rights Ordinance (the “Ordinance”), which took effect on January 1, 2025. (Seattle City Council, Ordinance 126878). Uber Technologies, Inc. (“Uber”) and Maplebear, Inc. d/b/a Instacart (“Instacart”), sued to block the Ordinance on First Amendment grounds, but on March 4, 2026, a divided Ninth Circuit panel rejected the companies’ appeal of a denied preliminary injunction. (Rachel Riley, Law360). This post examines what the Ordinance requires, the companies’ constitutional arguments, and the implications of this decision for Seattle and gig economy regulation nationwide.

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