The year 2019 has been defined by some experts in the field as “a critical time for abortion rights,” since during the first half of the year alone almost 60 abortion restrictions were enacted in 19 American states, including 26 abortion bans, and many more have been introduced by state legislators. In this article we want to reevaluate whether these recent shifts may amount to a real legal tsunami that could yield a new Archimedean point for women’s and fetuses’ rights, or only a temporary and shallow wave, which will probably abate after the Trump presidency. After exploring in a nutshell the recent restrictive as well as liberal developments in American abortion regulation, we will extensively elaborate on the real meaning and consequences of the 2019 Alabama case of “Baby Roe.” We will critically examine whether this is indeed a groundbreaking precedent with far-reaching results or just an additional local ruling in one of the most stringent states in the U.S. After briefly exploring the two main and central doctrines – best interests of the child and protection of his rights – we will thoroughly and comprehensively discuss their problematic and nuanced implementation in the hotly debated issue of abortion. Finally, we will discuss whether we are slowly but surely stepping towards a new conceptualization of the fetus’s rights and more broadly towards a new Archimedean point for maternal vs. fetal rights.
{"title":"Towards a New Archimedean Point for Maternal vs. Fetal Rights?","authors":"Yehezkel Margalit","doi":"10.2139/ssrn.3705975","DOIUrl":"https://doi.org/10.2139/ssrn.3705975","url":null,"abstract":"The year 2019 has been defined by some experts in the field as “a critical time for abortion rights,” since during the first half of the year alone almost 60 abortion restrictions were enacted in 19 American states, including 26 abortion bans, and many more have been introduced by state legislators. In this article we want to reevaluate whether these recent shifts may amount to a real legal tsunami that could yield a new Archimedean point for women’s and fetuses’ rights, or only a temporary and shallow wave, which will probably abate after the Trump presidency. After exploring in a nutshell the recent restrictive as well as liberal developments in American abortion regulation, we will extensively elaborate on the real meaning and consequences of the 2019 Alabama case of “Baby Roe.” We will critically examine whether this is indeed a groundbreaking precedent with far-reaching results or just an additional local ruling in one of the most stringent states in the U.S. After briefly exploring the two main and central doctrines – best interests of the child and protection of his rights – we will thoroughly and comprehensively discuss their problematic and nuanced implementation in the hotly debated issue of abortion. Finally, we will discuss whether we are slowly but surely stepping towards a new conceptualization of the fetus’s rights and more broadly towards a new Archimedean point for maternal vs. fetal rights.","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"81 1","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-10-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"41987006","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}
{"title":"A Louisiana Theory of Juridical Acts","authors":"Nikolaos A. Davrados","doi":"10.2139/ssrn.3749546","DOIUrl":"https://doi.org/10.2139/ssrn.3749546","url":null,"abstract":"","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"80 1","pages":"7"},"PeriodicalIF":0.0,"publicationDate":"2020-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68635488","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}
Recent mass shootings place patients’ gun rights in the public spotlight and may lead some physicians to discriminate against or harass law-abiding, gun-owning patients by expressing personal political views on gun ownership inside the patient-physician relationship in ways unrelated to patients’ medical care. Politicized physician gun speech is subject to regulation by state licensing authorities using their police powers, and laws compelling physician silence regarding non-medical gun advice are within States’ rights under the U.S. Constitution — including laws prohibiting physicians from discriminating against their lawful, gun-owning patients, from harassing those patients, and/or from making unnecessary inquiries or notations in their medical records.
{"title":"States’ Rights to Protect Gun-Owning Patients from Politicized Physician Speech","authors":"F. Griffin","doi":"10.2139/SSRN.3341808","DOIUrl":"https://doi.org/10.2139/SSRN.3341808","url":null,"abstract":"Recent mass shootings place patients’ gun rights in the public spotlight and may lead some physicians to discriminate against or harass law-abiding, gun-owning patients by expressing personal political views on gun ownership inside the patient-physician relationship in ways unrelated to patients’ medical care. Politicized physician gun speech is subject to regulation by state licensing authorities using their police powers, and laws compelling physician silence regarding non-medical gun advice are within States’ rights under the U.S. Constitution — including laws prohibiting physicians from discriminating against their lawful, gun-owning patients, from harassing those patients, and/or from making unnecessary inquiries or notations in their medical records.","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"79 1","pages":"9"},"PeriodicalIF":0.0,"publicationDate":"2018-04-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"49221436","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}
Custom is an ancient source of law that predates codified or written law. Once law began to be codified, custom filled the lacunae. Custom’s status as a source of law has declined in modern times, however, as to exist it requires a homogenous group of people with shared values who feel bound by custom’s unwritten rules. In 1987 Louisiana amended article 1 of its Civil Code to state that Louisiana’s sources of law are legislation and custom. The comments to the article now state that custom is a primary source of law. But Louisiana courts have not decided a case based on true custom in almost a century, and Louisiana’s size and diversity make it unlikely the populace feels bound by any unwritten law. The only possible modern source of customary law in Louisiana is jurisprudence constante — repeated decisions in a long line of cases interpreting a rule of law. Legislative history, however, reveals that jurisprudence was never intended to be a primary source of law in Louisiana. This Article briefly reviews the historical basis of consuetudinary law, examines the legislative history of the 1987 amendment to the Louisiana Civil Code, surveys Louisiana courts’ treatment of custom, and looks at custom’s present decline as authority. It concludes by suggesting that custom no longer exists as a primary source of law in Louisiana and that the Civil Code and its comments should be amended to clarify that jurisprudence constante is only a secondary, persuasive source of law.
{"title":"Custom as a Source of Law in Louisiana","authors":"Gail S. Stephenson","doi":"10.2139/SSRN.3130198","DOIUrl":"https://doi.org/10.2139/SSRN.3130198","url":null,"abstract":"Custom is an ancient source of law that predates codified or written law. Once law began to be codified, custom filled the lacunae. Custom’s status as a source of law has declined in modern times, however, as to exist it requires a homogenous group of people with shared values who feel bound by custom’s unwritten rules. \u0000 \u0000In 1987 Louisiana amended article 1 of its Civil Code to state that Louisiana’s sources of law are legislation and custom. The comments to the article now state that custom is a primary source of law. But Louisiana courts have not decided a case based on true custom in almost a century, and Louisiana’s size and diversity make it unlikely the populace feels bound by any unwritten law. The only possible modern source of customary law in Louisiana is jurisprudence constante — repeated decisions in a long line of cases interpreting a rule of law. Legislative history, however, reveals that jurisprudence was never intended to be a primary source of law in Louisiana. \u0000 \u0000This Article briefly reviews the historical basis of consuetudinary law, examines the legislative history of the 1987 amendment to the Louisiana Civil Code, surveys Louisiana courts’ treatment of custom, and looks at custom’s present decline as authority. It concludes by suggesting that custom no longer exists as a primary source of law in Louisiana and that the Civil Code and its comments should be amended to clarify that jurisprudence constante is only a secondary, persuasive source of law.","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"40 9","pages":"7"},"PeriodicalIF":0.0,"publicationDate":"2018-02-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"41268364","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}
{"title":"A Tribute to Thanassi: The Influence of Justinian on American Common Law Property","authors":"Sally Brown Richardson","doi":"10.2139/ssrn.3458691","DOIUrl":"https://doi.org/10.2139/ssrn.3458691","url":null,"abstract":"","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"78 1","pages":"9"},"PeriodicalIF":0.0,"publicationDate":"2018-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68594916","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 punishment of juveniles remains a troubling yet under-theorized aspect of the criminal and juvenile justice systems. These systems emphasize accountability, victim restoration, and retribution as reasons to punish underage offenders. In fact, American juvenile systems will remove the most egregious offenders to criminal courts for trial and sentencing. The United States Supreme Court in recent years, however, has issued a number of opinions emphasizing that the Eighth Amendment requires that the punishment of children must account for their lesser moral culpability, developmental immaturity, and potential for rehabilitation. State courts also have begun to reconsider their own dispositional and sentencing schemes in light of the Supreme Court’s jurisprudence.The reality of ‘juveniles’ immaturity militates in favor of a right to redemption. This Article begins by discussing the available data about the number and types of dispositions juveniles receive, waivers to criminal court, and the criminal sentences imposed. The analysis also considers the collateral consequences for minors who are adjudicated delinquent or who are criminally convicted. The discussion then turns to the effects of juvenile and criminal court involvement on children and the subsequent impact on life outcomes. The analysis considers theoretical, jurisprudential, and constitutional implications of juvenile sentencing with a special emphasis on the Supreme Court’s recent decisions. This Article concludes with the proposal for the contours of a right to redemption and its implications for reform to the current system and suggests strategies for the individual defense lawyer.
{"title":"The Right to Redemption: Juvenile Dispositions and Sentences","authors":"Federle","doi":"10.2139/SSRN.2876769","DOIUrl":"https://doi.org/10.2139/SSRN.2876769","url":null,"abstract":"The punishment of juveniles remains a troubling yet under-theorized aspect of the criminal and juvenile justice systems. These systems emphasize accountability, victim restoration, and retribution as reasons to punish underage offenders. In fact, American juvenile systems will remove the most egregious offenders to criminal courts for trial and sentencing. The United States Supreme Court in recent years, however, has issued a number of opinions emphasizing that the Eighth Amendment requires that the punishment of children must account for their lesser moral culpability, developmental immaturity, and potential for rehabilitation. State courts also have begun to reconsider their own dispositional and sentencing schemes in light of the Supreme Court’s jurisprudence.The reality of ‘juveniles’ immaturity militates in favor of a right to redemption. This Article begins by discussing the available data about the number and types of dispositions juveniles receive, waivers to criminal court, and the criminal sentences imposed. The analysis also considers the collateral consequences for minors who are adjudicated delinquent or who are criminally convicted. The discussion then turns to the effects of juvenile and criminal court involvement on children and the subsequent impact on life outcomes. The analysis considers theoretical, jurisprudential, and constitutional implications of juvenile sentencing with a special emphasis on the Supreme Court’s recent decisions. This Article concludes with the proposal for the contours of a right to redemption and its implications for reform to the current system and suggests strategies for the individual defense lawyer.","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"77 1","pages":"8"},"PeriodicalIF":0.0,"publicationDate":"2016-11-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68410159","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}
In this article, I use baseball as a springboard for discussing persuasive legal argument. In particular, I compare a lawyer making a legal argument to a batter at the plate. A batter with a well-made bat is poised to hit, but he or she still must connect with the ball. A lawyer with an accurate and complete rendition of applicable black letter law is poised to craft a persuasive argument, but he or she still must connect with the facts. The article was great fun to write (especially the footnotes), and, I hope, will be fun to read. I also hope it is instructive on the subject of written advocacy and also on the subject of baseball. Baseball long has held fascination for legal scholars. This article joins the long line of law review articles that use baseball as focus or jumping off point.
{"title":"Swinging at the Facts: How Baseball Informs Legal Argument","authors":"Josephine R. Potuto","doi":"10.2139/SSRN.2786676","DOIUrl":"https://doi.org/10.2139/SSRN.2786676","url":null,"abstract":"In this article, I use baseball as a springboard for discussing persuasive legal argument. In particular, I compare a lawyer making a legal argument to a batter at the plate. A batter with a well-made bat is poised to hit, but he or she still must connect with the ball. A lawyer with an accurate and complete rendition of applicable black letter law is poised to craft a persuasive argument, but he or she still must connect with the facts. The article was great fun to write (especially the footnotes), and, I hope, will be fun to read. I also hope it is instructive on the subject of written advocacy and also on the subject of baseball. Baseball long has held fascination for legal scholars. This article joins the long line of law review articles that use baseball as focus or jumping off point.","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"78 1","pages":"11"},"PeriodicalIF":0.0,"publicationDate":"2016-05-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68323341","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}
Restitution is a component of many criminal sentences. There is little agreement, however, upon whether and how the Eighth Amendment of the Constitution limits restitution orders in criminal cases. Courts have long been divided over whether the Excessive Fines Clause applies to restitution orders at all, whether to apply the “grossly disproportional” test to restitution orders or some other causation-based test, and how to measure gross disproportionality in the restitution context. First, the Excessive Fines Clause of the Eighth Amendment should be read as a limit on restitution orders in criminal cases. The Eighth Amendment applies because these monetary payments are partially punitive. And, although restitution payments are not made to the sovereign, the concept of “fines” for purposes of the Excessive Fines Clause is properly understood to encompass payments to third parties that result from government-initiated action. Second, the same “grossly disproportional” test that has been applied to criminal fines and forfeitures should apply to restitution orders as well. Indeed, all monetary sanctions should be pooled together for purposes of a single Excessive Fines Clause proportionality analysis. The constitutionally-relevant question should be whether an offender’s total monetary sanction is grossly disproportional to the gravity of the offense. Although causation between the offense conduct and the victim’s loss is generally a statutory requirement of restitution orders, it is not a constitutional one. The causation requirement furthers restitution’s remedial purpose; it is not relevant to the Eighth Amendment’s excessiveness inquiry, which functions to limit the punitive severity of monetary sanctions. Lastly, the question of gross disproportionality is largely an exercise of judgment that should be left to the judiciary. Some courts have inappropriately wholly relied on analyzing whether the monetary sanction was authorized by the legislature in assessing the constitutionality of the penalty. This approach inappropriately collapses the constitutional inquiry into the statutory one. Although the statutory restitution or fine range may be a useful input in the constitutional analysis, it cannot be the sole component. In the end, the judiciary's independent judgment must be trusted to weigh proportionality and detect unconstitutionally excessive monetary sanctions.
{"title":"Restitution and the Excessive Fines Clause","authors":"Kevin Bennardo","doi":"10.2139/SSRN.2724857","DOIUrl":"https://doi.org/10.2139/SSRN.2724857","url":null,"abstract":"Restitution is a component of many criminal sentences. There is little agreement, however, upon whether and how the Eighth Amendment of the Constitution limits restitution orders in criminal cases. Courts have long been divided over whether the Excessive Fines Clause applies to restitution orders at all, whether to apply the “grossly disproportional” test to restitution orders or some other causation-based test, and how to measure gross disproportionality in the restitution context. First, the Excessive Fines Clause of the Eighth Amendment should be read as a limit on restitution orders in criminal cases. The Eighth Amendment applies because these monetary payments are partially punitive. And, although restitution payments are not made to the sovereign, the concept of “fines” for purposes of the Excessive Fines Clause is properly understood to encompass payments to third parties that result from government-initiated action. Second, the same “grossly disproportional” test that has been applied to criminal fines and forfeitures should apply to restitution orders as well. Indeed, all monetary sanctions should be pooled together for purposes of a single Excessive Fines Clause proportionality analysis. The constitutionally-relevant question should be whether an offender’s total monetary sanction is grossly disproportional to the gravity of the offense. Although causation between the offense conduct and the victim’s loss is generally a statutory requirement of restitution orders, it is not a constitutional one. The causation requirement furthers restitution’s remedial purpose; it is not relevant to the Eighth Amendment’s excessiveness inquiry, which functions to limit the punitive severity of monetary sanctions. Lastly, the question of gross disproportionality is largely an exercise of judgment that should be left to the judiciary. Some courts have inappropriately wholly relied on analyzing whether the monetary sanction was authorized by the legislature in assessing the constitutionality of the penalty. This approach inappropriately collapses the constitutional inquiry into the statutory one. Although the statutory restitution or fine range may be a useful input in the constitutional analysis, it cannot be the sole component. In the end, the judiciary's independent judgment must be trusted to weigh proportionality and detect unconstitutionally excessive monetary sanctions.","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"77 1","pages":"7"},"PeriodicalIF":0.0,"publicationDate":"2016-01-29","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68274981","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 standard of proof in criminal trials in many liberal democracies is proof beyond a reasonable doubt, the BARD standard. It is customary to describe it, when putting a number on it, as requiring that the fact finder be at least 90% certain, after considering the evidence, that the defendant is guilty. Strikingly, no good reason has yet been offered in defense of using that standard. A number of non-consequentialist justifications that aim to support an even higher standard have been offered; all are morally unsound. Meanwhile, consequentialist arguments plausibly support a substantially lower standard — in some cases so low as to undermine the idea that punishment is what is at stake. In this paper, I offer a new retributive justification that supports excluding the instrumental benefits of punishment from the balance that sets the standard. The resulting balance supports a standard arguably in the ballpark of the customary understanding of BARD: a standard requiring that the fact finder have a high, though not maximally high, degree of confidence that the defendant is guilty.
{"title":"Proof Beyond a Reasonable Doubt: A Balanced Retributive Account","authors":"A. Walen","doi":"10.2139/SSRN.2562563","DOIUrl":"https://doi.org/10.2139/SSRN.2562563","url":null,"abstract":"The standard of proof in criminal trials in many liberal democracies is proof beyond a reasonable doubt, the BARD standard. It is customary to describe it, when putting a number on it, as requiring that the fact finder be at least 90% certain, after considering the evidence, that the defendant is guilty. Strikingly, no good reason has yet been offered in defense of using that standard. A number of non-consequentialist justifications that aim to support an even higher standard have been offered; all are morally unsound. Meanwhile, consequentialist arguments plausibly support a substantially lower standard — in some cases so low as to undermine the idea that punishment is what is at stake. In this paper, I offer a new retributive justification that supports excluding the instrumental benefits of punishment from the balance that sets the standard. The resulting balance supports a standard arguably in the ballpark of the customary understanding of BARD: a standard requiring that the fact finder have a high, though not maximally high, degree of confidence that the defendant is guilty.","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"76 1","pages":"6"},"PeriodicalIF":0.0,"publicationDate":"2015-12-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68204743","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 literature considering various possible procedural reforms to United States jury trial practice suffers from a high dose of American Exceptionalism. The experience of other nations rarely is acknowledged, much less considered as possibly informative. This Article argues that as a British-derived system of roughly identical vintage as the United States, the jury practices of Malta can inform American practice in three respects: (1) the desirability of increased juror interaction – in particular allowing oral juror questions to witnesses and allowing deliberation during the trial, (2) the utility of eliminating voir dire in jury selection, and (3) the possibility of procedural reform such as modifying the verdict form to insulate jurors from external pressures on the verdict.
{"title":"Comparative Jury Procedures: What a Small Island Nation Teaches the United States About Jury Reform","authors":"K. Klein","doi":"10.2139/SSRN.2569689","DOIUrl":"https://doi.org/10.2139/SSRN.2569689","url":null,"abstract":"The literature considering various possible procedural reforms to United States jury trial practice suffers from a high dose of American Exceptionalism. The experience of other nations rarely is acknowledged, much less considered as possibly informative. This Article argues that as a British-derived system of roughly identical vintage as the United States, the jury practices of Malta can inform American practice in three respects: (1) the desirability of increased juror interaction – in particular allowing oral juror questions to witnesses and allowing deliberation during the trial, (2) the utility of eliminating voir dire in jury selection, and (3) the possibility of procedural reform such as modifying the verdict form to insulate jurors from external pressures on the verdict.","PeriodicalId":39678,"journal":{"name":"Louisiana Law Review","volume":"76 1","pages":"7"},"PeriodicalIF":0.0,"publicationDate":"2015-02-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"https://sci-hub-pdf.com/10.2139/SSRN.2569689","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"68208459","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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