particularly dangerous ground on which to rest an interpretation of a prior statute when it concerns ... a proposal that does not become law.” Pension Benefit Guar. Corp. v. LTV Corp., 496 U.S. 633, 650, 110 S.Ct. 2668, 110 L.Ed.2d 579 (1990). 7 . We do not read Wyndham's briefing as raising a meaningful argument under the "discriminatory enforcement” prong. A few sentences in a reply brief are not enough. See Wyndham Reply Br. at 26 ("To provide the notice required by due process, a statement must in some sense declare what conduct the law proscribes and thereby constrain enforcement discretion.... Here, the consent decrees at issue ... do not limit the Commission's enforcement authority in any way.” (citation omitted)). 8 . See Ortiz v. N.Y.S. Parole, 586 F.3d 149, 159 (2d Cir.2009) (<HOLDING>); In re Surrick, 338 F.3d at 234 ("[We] reject
holding that the offense requires that the return be false as to a material matter holding that a defendant must have notice that the trial court might sentence him to death holding that even though the issue is not framed according to what might be referred to as standard lawschool format preston only requires that a certified question clearly identify the scope and limits of the legal issues reserved holding that the inquiry into whether an employee was acting within the scope of his employment depends on the respondeat superior law of the state in which the tort occurred holding that the unexpected and indefensible standard requires only that the law  not lull the potential defendant into a false sense of security giving him no reason even to suspect that his conduct might be within its scope emphases added