diff --git a/08-courts/08-03-judicial-review.md b/08-courts/08-03-judicial-review.md
index a9da694..5a8a321 100644
--- a/08-courts/08-03-judicial-review.md
+++ b/08-courts/08-03-judicial-review.md
@@ -4,9 +4,7 @@
 
 ## Process:
 
-## Justices:
-
-As in a court of record, Justices of the court conduct the process of the court. 
+> [Apologia]: There may be a need for special process modifications since determining the facts will ultimately consist of determining "the original understanding of the constitution at the time it was adopted".
 
 ## Jury: