Bora Ndregjoni Recipient of the 2020 Illinois Judges Foundation Harold Sullivan Scholarship

Bora Ndregjoni ’21 is the recipient of the 2020 Illinois Judges Foundation Harold Sullivan Scholarship.

“I feel incredibly honored to receive the Judge Harold Sullivan Scholarship. It’s amazing how the Illinois Judges Foundation gives back to law students in their community, and I am so lucky to be one of the recognized students,” she says.

The scholarship is named for Judge Harold W. Sullivan, one of the founders and a long-time supporter of the Illinois Judges Association, and was established to help pass on ethical values to new generations of law students. Ndregjoni received the $5,000 scholarship and was honored at this year’s virtual Illinois Judges Foundation Annual Reception on September 24.

As part of the application process, Ndregjoni had to write an essay on a Fifth Amendment question regarding police warrants and biometrics. Police were seeking a warrant that would require a suspect to use his fingerprint to unlock his cell phone. The suspect argued that compelling the use of his biometric information through a fingerprint scan would be a violation of his Fifth Amendment right against self-incrimination.

In her essay, Ndregjoni argued that a police officer cannot force a suspect to unlock their phone with their fingerprint because the action would reveal the contents of the suspect’s mind, which would be considered testimonial. An individual’s communication must be compelled, testimonial, and incriminating to qualify for Fifth Amendment protection. Courts have found that the Fifth Amendment prohibits law enforcement officers from compelling individuals to speak or write down passwords to their phones, and a fingerprint scan is essentially a password.

Legal issues involving biometrics and the Fifth Amendment form the core of one of Ndregjoni’s research interests. Earlier this year, she received a cash prize and an honorable mention in the Marshall Schulman Criminal Law Journal Writing Competition for her article Unlocking Fifth Amendment Protection: How California Law Prevents Compelled Biometric Features. The article was published in the California Lawyers Association’s Criminal Law Journal spring/summer 2020 edition. 

Ndregjoni earned her bachelor’s degree in criminology from Florida State University. She is president of the Moot Court Honor Society, and social media and website coordinator for the Chicago-Kent Law Review. Ndregjoni is a research assistant for Chicago-Kent Professor of Law Emerita Lori Andrews and a teaching assistant for Assistant Professor Emily Aleisa. She has accepted an associate position with Katten Muchin Rosenman LLP upon graduation and bar passage.

Ndregjoni, whose parents are Albanian immigrants, is fluent in Albanian. She frequently visits extended family in Albania and says she is proud of her Albanian-American heritage.

“I thank my parents every single day for taking the step to leave everything they knew, and everyone they loved, to move to America,” she says. “I wouldn’t be here without their courage and perseverance.”