This paper contributes to the positive political theory of legislative delegation by modeling formally the decision calculus of a rational legislator who must choose between delegation to an agency and delegation to a court. The model focuses in particular on the legislator's interest in diversifying risk, both across time and across issues, and her interest in avoiding interpretive inconsistency. The model emphasizes an institutional difference between agencies and courts that the extant literature has generally neglected: Agency decisions tend to be ideologically consistent across issues but variable over time, while court decisions tend to be ideologically heterogeneous across issues but stable over time. For the legislator, then, delegation to agencies purchases inter-temporal risk diversification and inter-issue consistency at the price of inter-temporal inconsistency and a lack of risk diversification across issues, while delegation to courts involves the opposite trade-off. From this basic insight the model derives an array of comparative statics regarding the conditions under which rational legislators would tend to prefer delegating to agencies over courts and vice versa. These results imply hypotheses as to how real-world variation in political and policy-specific variables, as well as variation in characteristics of judicial and agency approaches to statutory interpretation, may affect legislators' preferences regarding allocation of interpretive authority.
{"title":"Legislative Allocation of Delegated Power: Uncertainty, Risk, and the Choice between Agencies and Courts","authors":"M. Stephenson","doi":"10.2139/ssrn.716863","DOIUrl":"https://doi.org/10.2139/ssrn.716863","url":null,"abstract":"This paper contributes to the positive political theory of legislative delegation by modeling formally the decision calculus of a rational legislator who must choose between delegation to an agency and delegation to a court. The model focuses in particular on the legislator's interest in diversifying risk, both across time and across issues, and her interest in avoiding interpretive inconsistency. The model emphasizes an institutional difference between agencies and courts that the extant literature has generally neglected: Agency decisions tend to be ideologically consistent across issues but variable over time, while court decisions tend to be ideologically heterogeneous across issues but stable over time. For the legislator, then, delegation to agencies purchases inter-temporal risk diversification and inter-issue consistency at the price of inter-temporal inconsistency and a lack of risk diversification across issues, while delegation to courts involves the opposite trade-off. From this basic insight the model derives an array of comparative statics regarding the conditions under which rational legislators would tend to prefer delegating to agencies over courts and vice versa. These results imply hypotheses as to how real-world variation in political and policy-specific variables, as well as variation in characteristics of judicial and agency approaches to statutory interpretation, may affect legislators' preferences regarding allocation of interpretive authority.","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"29 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2005-03-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122374565","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Should government be allowed to spend tax payers' money on public relations? If one frames the question that way, the negative answer suggests itself. Yet government communication serves more purposes. These purposes may be analysed in terms of behavioural economics and psychology. In moral suasion, government communication is the governance tool itself. Most other governance tools do not automatically reach their addressees. Appropriate communication is necessary for them to become effective. Finally, government is a legitimate player in political process, and communication to the public is a legitimate element of this process. Specifically, the normatively desirable and the normative problematic aspects can usually not be fully disentangled. Hence, the potential distortion of elections must be outweighed against the governance effect. This paper does so by interpreting governmental public relations as a bundled product. It models the people as the principal, and the political parties running government as the agent. The distortion effect is observable, the governance effect is not. This set-up of the model invites a second-best solution in terms of mechanism design. Government is free to advertise. But advertising is costly in that it generates a handicap at the next elections. This solution is taken as a benchmark for discussing politically more digestible third and fourth best.
{"title":"Governmental Public Relations","authors":"C. Engel","doi":"10.2139/ssrn.657001","DOIUrl":"https://doi.org/10.2139/ssrn.657001","url":null,"abstract":"Should government be allowed to spend tax payers' money on public relations? If one frames the question that way, the negative answer suggests itself. Yet government communication serves more purposes. These purposes may be analysed in terms of behavioural economics and psychology. In moral suasion, government communication is the governance tool itself. Most other governance tools do not automatically reach their addressees. Appropriate communication is necessary for them to become effective. Finally, government is a legitimate player in political process, and communication to the public is a legitimate element of this process. Specifically, the normatively desirable and the normative problematic aspects can usually not be fully disentangled. Hence, the potential distortion of elections must be outweighed against the governance effect. This paper does so by interpreting governmental public relations as a bundled product. It models the people as the principal, and the political parties running government as the agent. The distortion effect is observable, the governance effect is not. This set-up of the model invites a second-best solution in terms of mechanism design. Government is free to advertise. But advertising is costly in that it generates a handicap at the next elections. This solution is taken as a benchmark for discussing politically more digestible third and fourth best.","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"32 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2005-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121226507","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The filed rate doctrine is a venerable doctrine of public utility regulation. When a court applies it - and courts frequently do - the doctrine serves as a litigation shield for regulated utilities. Federal courts invoking this shield refuse to exercise jurisdiction over an alleged violation of antitrust, tort or contract claim whose resolution would require a departure from a utility's filed rate. Like many venerable legal rules, the filed rate doctrine is rarely questioned. For over a century, it has served many important purposes. However, with deregulated wholesale electric power markets at the federal level and various degrees of deregulation across the states, both the doctrine's continued applicability and usefulness are suspect. Moreover, as recent examples in the industry suggest, presumptive application of the filed rate doctrine by both firms and courts can cause affirmative harm for energy market development and policy. For example, a recent U.S. District Court decision in Texas applied the filed rate doctrine in an astonishingly broad manner, precluding antitrust claims against energy suppliers in the deregulated Texas wholesale power market and leaving those harmed by market abuses without any legal or administrative remedy. The Essay draws on examples such as this to illustrate the serious need for reassessment of the doctrine by federal courts in the energy context. It is argued that both courts and litigators have at their disposal ways of lowering the filed tariff shield to allow more efficient energy markets to develop, better furthering the goals of energy policy.
{"title":"How the Filed Rate Doctrine Wreaks Havoc with Energy Market Development and Policy ... And What Courts Can Do About it","authors":"Jim Rossi","doi":"10.2139/ssrn.587141","DOIUrl":"https://doi.org/10.2139/ssrn.587141","url":null,"abstract":"The filed rate doctrine is a venerable doctrine of public utility regulation. When a court applies it - and courts frequently do - the doctrine serves as a litigation shield for regulated utilities. Federal courts invoking this shield refuse to exercise jurisdiction over an alleged violation of antitrust, tort or contract claim whose resolution would require a departure from a utility's filed rate. Like many venerable legal rules, the filed rate doctrine is rarely questioned. For over a century, it has served many important purposes. However, with deregulated wholesale electric power markets at the federal level and various degrees of deregulation across the states, both the doctrine's continued applicability and usefulness are suspect. Moreover, as recent examples in the industry suggest, presumptive application of the filed rate doctrine by both firms and courts can cause affirmative harm for energy market development and policy. For example, a recent U.S. District Court decision in Texas applied the filed rate doctrine in an astonishingly broad manner, precluding antitrust claims against energy suppliers in the deregulated Texas wholesale power market and leaving those harmed by market abuses without any legal or administrative remedy. The Essay draws on examples such as this to illustrate the serious need for reassessment of the doctrine by federal courts in the energy context. It is argued that both courts and litigators have at their disposal ways of lowering the filed tariff shield to allow more efficient energy markets to develop, better furthering the goals of energy policy.","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"22 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2004-09-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"126480971","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The minority party is rarely featured in empirical research on parties in legislatures, and recent theories of parties in legislatures are rarely neutral and balanced in their treatment of the two parties. This paper makes a case for redressing this imbalance. We identify four characteristics of bipartisanship and evaluate their descriptive merits in a purposely hostile testing ground: during the rise and fall of Speaker Joseph G. Cannon, a.k.a., the Tyrant from Illinois. Drawing on century-old recently discovered records now available in the National Archives, we find that Cannon was anything but a majority-party tyrant during the important committee assignment phase of legislative organization. The findings underscore the need for future, more explicitly theoretical research on parties-in-legislatures.
{"title":"Joe Cannon and the Minority Party: Tyranny or Bipartisanship","authors":"Keith. Krehbiel, Alan E. Wiseman","doi":"10.2139/ssrn.577861","DOIUrl":"https://doi.org/10.2139/ssrn.577861","url":null,"abstract":"The minority party is rarely featured in empirical research on parties in legislatures, and recent theories of parties in legislatures are rarely neutral and balanced in their treatment of the two parties. This paper makes a case for redressing this imbalance. We identify four characteristics of bipartisanship and evaluate their descriptive merits in a purposely hostile testing ground: during the rise and fall of Speaker Joseph G. Cannon, a.k.a., the Tyrant from Illinois. Drawing on century-old recently discovered records now available in the National Archives, we find that Cannon was anything but a majority-party tyrant during the important committee assignment phase of legislative organization. The findings underscore the need for future, more explicitly theoretical research on parties-in-legislatures.","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"86 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2004-07-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"117164010","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Several prominent scholars use results from social choice theory to conclude that legislative intent is meaningless. We disagree. We support our argument by showing that the conclusions in question are based on misapplications of the theory. Some of the conclusions in question are based on Kenneth Arrow's famous possibility theorem. We identify a substantial chasm between what Arrow proves and what others claim in his name. Other conclusions come from a failure to realize that applying social choice theory to questions of legislative intent entails accepting assumptions such as legislators are omniscient and legislators have infinite resources for changing law and policy. We demonstrate that adding more realistic assumptions to models of social choice theory yields very different theoretical results - including ones that allow meaningful inferences about legislative intent. In all of the cases we describe, important aspects of social choice theory were lost in the translation from abstract formalisms to real political and legal domains. When properly understood, social choice theory is insufficient to negate legislative intent.
{"title":"Lost in Translation: Social Choice Theory is Misapplied Against Legislative Intent","authors":"A. Lupia, Mathew D. McCubbins","doi":"10.2139/ssrn.529742","DOIUrl":"https://doi.org/10.2139/ssrn.529742","url":null,"abstract":"Several prominent scholars use results from social choice theory to conclude that legislative intent is meaningless. We disagree. We support our argument by showing that the conclusions in question are based on misapplications of the theory. Some of the conclusions in question are based on Kenneth Arrow's famous possibility theorem. We identify a substantial chasm between what Arrow proves and what others claim in his name. Other conclusions come from a failure to realize that applying social choice theory to questions of legislative intent entails accepting assumptions such as legislators are omniscient and legislators have infinite resources for changing law and policy. We demonstrate that adding more realistic assumptions to models of social choice theory yields very different theoretical results - including ones that allow meaningful inferences about legislative intent. In all of the cases we describe, important aspects of social choice theory were lost in the translation from abstract formalisms to real political and legal domains. When properly understood, social choice theory is insufficient to negate legislative intent.","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"14 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2004-04-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130030689","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2003-03-01DOI: 10.2308/ACCH.2003.17.1.47
Murphy D. Smith
This article (editorial) proposes actions to be taken by educators and practitioners in providing ethical direction to the accounting profession. In the wake of corporate scandals and a shaky stock market, Congress passed legislation that established a new board to oversee auditors of publicly traded companies and increased prison sentences for fraud. This article is based on the author's opening statement to the U.S. House of Representatives Subcommittee on Commerce, Trade, and Consumer Protection, Friday, July 26, 2002. At the Congressional Hearing, Truett Cathy, founder of Chick-Fil-A, quoted Proverbs 22:1, which says: A good name is more desirable than great riches; to be esteemed is better than silver or gold. The truth is that living an honorable life really is more satisfying than fame and fortune. The accounting professional must be skilled at implementing moral judgments so that he or she can consider the welfare of those affected by his or her actions. The ultimate measure of success is not fame and fortune, but moral character and personal integrity. The leadership of the accounting profession has a responsibility to inculcate in practitioners and students ethical behavior and personal integrity. Rules and regulations of government cannot preserve a free and ethical society whose people lack integrity.
{"title":"A Fresh Look at Accounting Ethics (or Dr. Smith Goes to Washington)","authors":"Murphy D. Smith","doi":"10.2308/ACCH.2003.17.1.47","DOIUrl":"https://doi.org/10.2308/ACCH.2003.17.1.47","url":null,"abstract":"This article (editorial) proposes actions to be taken by educators and practitioners in providing ethical direction to the accounting profession. In the wake of corporate scandals and a shaky stock market, Congress passed legislation that established a new board to oversee auditors of publicly traded companies and increased prison sentences for fraud. This article is based on the author's opening statement to the U.S. House of Representatives Subcommittee on Commerce, Trade, and Consumer Protection, Friday, July 26, 2002. At the Congressional Hearing, Truett Cathy, founder of Chick-Fil-A, quoted Proverbs 22:1, which says: A good name is more desirable than great riches; to be esteemed is better than silver or gold. The truth is that living an honorable life really is more satisfying than fame and fortune. The accounting professional must be skilled at implementing moral judgments so that he or she can consider the welfare of those affected by his or her actions. The ultimate measure of success is not fame and fortune, but moral character and personal integrity. The leadership of the accounting profession has a responsibility to inculcate in practitioners and students ethical behavior and personal integrity. Rules and regulations of government cannot preserve a free and ethical society whose people lack integrity.","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"48 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2003-03-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122664196","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The key question addressed in this article is at what points does European law impose constraints on the national legislative process, and does this mean that the national legislature’s powers are no longer wholly autonomous?
{"title":"National Legislative Autonomy? The Procedural Constraints of European Law","authors":"J. Jans","doi":"10.54648/leie1998002","DOIUrl":"https://doi.org/10.54648/leie1998002","url":null,"abstract":"The key question addressed in this article is at what points does European law impose constraints on the national legislative process, and does this mean that the national legislature’s powers are no longer wholly autonomous?","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"27 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1998-06-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122326151","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
All jurisdictions within the United States have some form of repeat offender statute that enhances sentences based on prior convictions. Many criminals in the United States have committed crimes in other countries. It is no surprise, then, that a recurring question is whether convictions from foreign countries count as predicate offenses for the purpose of recidivist statutes. Some state legislatures have addressed that question directly, but many more have enacted ambiguous statutes that use phrases such as outside this state. Some courts have interpreted those phrases as embracing convictions from outside the United States, while others have limited their scope to the United States. This note discusses doctrinal and policy considerations and proposes a standard courts should use in deciding when to include foreign country convictions.
{"title":"The Treatment of Foreign Country Convictions as Predicates for Sentence Enhancement Under Recidivist Statutes","authors":"Alex Glashausser","doi":"10.2307/1372868","DOIUrl":"https://doi.org/10.2307/1372868","url":null,"abstract":"All jurisdictions within the United States have some form of repeat offender statute that enhances sentences based on prior convictions. Many criminals in the United States have committed crimes in other countries. It is no surprise, then, that a recurring question is whether convictions from foreign countries count as predicate offenses for the purpose of recidivist statutes. Some state legislatures have addressed that question directly, but many more have enacted ambiguous statutes that use phrases such as outside this state. Some courts have interpreted those phrases as embracing convictions from outside the United States, while others have limited their scope to the United States. This note discusses doctrinal and policy considerations and proposes a standard courts should use in deciding when to include foreign country convictions.","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"7 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1994-10-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"129292282","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Asset forfeiture has become an important weapon in the fight against narcotics trafficking and racketeering. ... Pearson addressed the constitutionality of Puerto Rico's civil forfeiture statute. ... Who had standing to assert it? For example, would a reasonable precautions defense be available to a bona fide purchaser who paid full value for a conveyance and neither knew, nor had reason to know, of any prior illegal use? Similarly, would the defense be available to a lienholder acting reasonably without knowledge of any impropriety? Such third party claimants seem to deserve more protection than an owner because they generally lack any opportunity to prevent illegal use of the conveyance. ... In 1970 Congress provided for criminal forfeiture in the newly enacted CCE and RICO statutes. CCE authorized forfeiture of assets linked to drug trafficking, and RICO extended asset forfeiture beyond narcotics trafficking to other racketeering activities as defined in the statute. ... By adopting a negligence test instead of some higher standard or one that distinguishes between types of third party claims, Congress has failed to adequately protect the third party interest. ...
{"title":"Asset Forfeiture and Third Party Rights: The Need for Further Law Reform","authors":"Michael Goldsmith, M. Linderman","doi":"10.2307/1372518","DOIUrl":"https://doi.org/10.2307/1372518","url":null,"abstract":"Asset forfeiture has become an important weapon in the fight against narcotics trafficking and racketeering. ... Pearson addressed the constitutionality of Puerto Rico's civil forfeiture statute. ... Who had standing to assert it? For example, would a reasonable precautions defense be available to a bona fide purchaser who paid full value for a conveyance and neither knew, nor had reason to know, of any prior illegal use? Similarly, would the defense be available to a lienholder acting reasonably without knowledge of any impropriety? Such third party claimants seem to deserve more protection than an owner because they generally lack any opportunity to prevent illegal use of the conveyance. ... In 1970 Congress provided for criminal forfeiture in the newly enacted CCE and RICO statutes. CCE authorized forfeiture of assets linked to drug trafficking, and RICO extended asset forfeiture beyond narcotics trafficking to other racketeering activities as defined in the statute. ... By adopting a negligence test instead of some higher standard or one that distinguishes between types of third party claims, Congress has failed to adequately protect the third party interest. ...","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"113 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1989-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122703701","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This paper evaluates the cases for and against plant closing legislation. In spite of the growth of legislative efforts in the area, there has been surprisingly little effort devoted to analyzing what the effects are of existing plant closing legislation, of provisions in privately negotiated collective bargaining agreements that provide for advance notice in case of plant shutdowns and/or layoffs, and of voluntary employer provision of advance notice. The paper summarizes the results of previous research, and our own empirical analyses that used the January 1984 Bureau of Labor Statistics Survey of Displaced Workers, on the effects of advance notice on displaced workers' durations of nonemployment and post-displacement earnings. Based upon these findings, implications for public policy are drawn.
{"title":"Advance Notice Provisions in Plant Closing Legislation: Do They Matter?","authors":"Ronald G. Ehrenberg, George H. Jakubson","doi":"10.3386/W2611","DOIUrl":"https://doi.org/10.3386/W2611","url":null,"abstract":"This paper evaluates the cases for and against plant closing legislation. In spite of the growth of legislative efforts in the area, there has been surprisingly little effort devoted to analyzing what the effects are of existing plant closing legislation, of provisions in privately negotiated collective bargaining agreements that provide for advance notice in case of plant shutdowns and/or layoffs, and of voluntary employer provision of advance notice. The paper summarizes the results of previous research, and our own empirical analyses that used the January 1984 Bureau of Labor Statistics Survey of Displaced Workers, on the effects of advance notice on displaced workers' durations of nonemployment and post-displacement earnings. Based upon these findings, implications for public policy are drawn.","PeriodicalId":297504,"journal":{"name":"Legislation & Statutory Interpretation","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1988-06-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"128507187","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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