For circuit splits, identify an area of law or issue where courts have ruled differently and analyze an aspect of the issue or rulings.
Ideas for a note topic can come from almost anywhere: newspapers, magazines, blogs, other journal articles or circuit splits. The next step is to propose a solution to that problem - your proposed solution then becomes your claim. The first step to coming up with a claim is to identify a problem - new legal developments, conflicts in the law, gaps or errors in current scholarly understanding, or any other flaw or hole that you identify within the legal world as it stands. A good note topic will make a claim that is novel, nonobvious, useful, and sound, for both the writer and the potential readers.