A Covington & Burling associate was surprised to learn last week that U.S. Supreme Court Justice Sonia Sotomayor cited an article he wrote 14 years ago in her lengthy dissent in the Michigan affirmative action case.

It was surprising because Jeff Kosseff’s article had not been mentioned in any brief in the case, and the piece hadn’t been published in a law review. Kosseff wrote the article—about the debate over affirmative action—for a Detroit business publication while he was a student journalist at the University of Michigan.