Since the Nixon Administration, the U.S. government has attempted to promote tribal self-determination among Native Americans. Under the Indian Self-Determination Act, the tribes can enter into agreements with the federal government to take over services previously provided to the tribes by the Bureau of Indian Affairs (BIA). By entering into these contracts, the tribes have been able to administer a wide variety of services, including construction and law enforcement, which bring income and employment to Indian country. These contracts do not always run smoothly, however, and sometimes people get injured. Under a series of amendments to the Indian Self-Determination Act, when tribal contractors commit torts, the federal government steps in and defends the tribal contractors under the Federal Tort Claims Act (FTCA) as if they were employees of the government. The government pays out any settlements or judgments from the Judgment Fund. This scenario is a complete departure from the traditional FTCA rule whereby contractors are only treated as government employees in exceedingly limited circumstances.In hastily extending the FTCA to cover tribal contractors, Congress contravened FTCA jurisprudence in theory and in practice. Congress intended to help the tribes avoid having to buy costly insurance by directly assuming liability under the FTCA. While perhaps well-intentioned, the result is a system of perverse incentives and a string of inconsistent decisions. Courts struggle to apply the FTCA's waiver of the federal government's sovereign immunity to the tribes, which remain separate sovereigns that retain some of their own sovereign immunity. The arrangement also creates problems in determining whether tribal contractors are within the scope of their employment and undertaking discretionary functions. Furthermore, the statutory scheme creates the potential for tribal law to govern the United States' tort liability and may have inadvertently created a loophole for the intentional torts of tribal law enforcement officers. The end result of this untenable situation is that savvy tribes recognize the unpredictability of the FTCA protection and purchase private insurance anyway, sometimes with federal contract support funds. This is the exact result Congress hoped to avoid.Congress should end the experiment of extending the FTCA to cover tribal contractors and replace it with subsidized private insurance. This new arrangement would simplify the process for potential claimants and keep the government from having to pay the duplicative costs of insurance and judgments.
{"title":"Help Me Help You: Why Congress's Attempt To Cover Torts Committed by Indian Tribal Contractors with the FTCA Hurts the Government and the Tribes","authors":"Joseph W. Gross","doi":"10.2139/SSRN.2286298","DOIUrl":"https://doi.org/10.2139/SSRN.2286298","url":null,"abstract":"Since the Nixon Administration, the U.S. government has attempted to promote tribal self-determination among Native Americans. Under the Indian Self-Determination Act, the tribes can enter into agreements with the federal government to take over services previously provided to the tribes by the Bureau of Indian Affairs (BIA). By entering into these contracts, the tribes have been able to administer a wide variety of services, including construction and law enforcement, which bring income and employment to Indian country. These contracts do not always run smoothly, however, and sometimes people get injured. Under a series of amendments to the Indian Self-Determination Act, when tribal contractors commit torts, the federal government steps in and defends the tribal contractors under the Federal Tort Claims Act (FTCA) as if they were employees of the government. The government pays out any settlements or judgments from the Judgment Fund. This scenario is a complete departure from the traditional FTCA rule whereby contractors are only treated as government employees in exceedingly limited circumstances.In hastily extending the FTCA to cover tribal contractors, Congress contravened FTCA jurisprudence in theory and in practice. Congress intended to help the tribes avoid having to buy costly insurance by directly assuming liability under the FTCA. While perhaps well-intentioned, the result is a system of perverse incentives and a string of inconsistent decisions. Courts struggle to apply the FTCA's waiver of the federal government's sovereign immunity to the tribes, which remain separate sovereigns that retain some of their own sovereign immunity. The arrangement also creates problems in determining whether tribal contractors are within the scope of their employment and undertaking discretionary functions. Furthermore, the statutory scheme creates the potential for tribal law to govern the United States' tort liability and may have inadvertently created a loophole for the intentional torts of tribal law enforcement officers. The end result of this untenable situation is that savvy tribes recognize the unpredictability of the FTCA protection and purchase private insurance anyway, sometimes with federal contract support funds. This is the exact result Congress hoped to avoid.Congress should end the experiment of extending the FTCA to cover tribal contractors and replace it with subsidized private insurance. This new arrangement would simplify the process for potential claimants and keep the government from having to pay the duplicative costs of insurance and judgments.","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2012-12-27","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"86783334","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}
Much of contemporary torts scholarship has been devoted to determining who should bear the costs of unintended injury, that is, whether and when defendants should be strictly liable for the harm caused by their activities, as opposed to limiting plaintiffs to recovery when they can prove that the defendant’s conduct was negligent. Comparatively little scholarship has explored the appropriate distinction between the intentional torts and the non-intentional torts, such as negligence or strict liability. Recently, torts scholars have begun to explore some interesting and unresolved questions surrounding the intentional torts, particularly battery, stemming in part from the completion of various stages of the Restatement (Third) of Torts and the current position of the ALI that it will not attempt a restatement of the non-economic intentional torts that were addressed in great detail in the Restatement (Second) on the grounds that intentional tort doctrine is clear and that the Restatement (Second) provisions have been widely adopted. This article joins the work of several torts scholars who have recently questioned the clarity of intentional tort law doctrine. These scholars have focused on the ambiguity of the Restatement’s provisions with respect to the intent to cause a harmful or offensive bodily contact, that is, whether these provisions require both intent to cause bodily contact and intent to cause harm or offense (dual intent) or whether it is sufficient that the defendant intends a bodily contact that turns out to be either harmful or offensive (single intent). Some of these scholars have also suggested that the essence of battery is not the intent to cause a harmful or offensive contact, but rather the intent to cause an unpermitted contact. This article demonstrates that the current confusion and controversy over battery law doctrine is far more extensive than even these recent torts scholars have demonstrated. It extends beyond the element of intent and includes uncertainty concerning the role of the plaintiff’s lack of actual or apparent consent - that is, whether consent is an affirmative defense or whether lack of consent is an element of the plaintiff’s prima facie case - and the relationship between intent and lack of consent. Moreover, this confusion and controversy is reflected not only in modern battery court opinions, but also in the cursory and contradictory treatment given to battery law in most torts casebooks and treatises. Finally, despite the ALI’s assumption that the Restatement provisions have been widely adopted, there are many jurisdictions where courts are formulating battery doctrine using terminology that departs significantly from the Restatement provisions. Part I of this article gives a detailed account of the current confusion and controversy in battery doctrine. Part II provides a brief account of the historical development of the modern tort of battery, which is necessary to understanding why it is that so ma
{"title":"Intent and Consent in the Tort of Battery: Confusion and Controversy","authors":"N. Moore","doi":"10.2139/SSRN.2008843","DOIUrl":"https://doi.org/10.2139/SSRN.2008843","url":null,"abstract":"Much of contemporary torts scholarship has been devoted to determining who should bear the costs of unintended injury, that is, whether and when defendants should be strictly liable for the harm caused by their activities, as opposed to limiting plaintiffs to recovery when they can prove that the defendant’s conduct was negligent. Comparatively little scholarship has explored the appropriate distinction between the intentional torts and the non-intentional torts, such as negligence or strict liability. Recently, torts scholars have begun to explore some interesting and unresolved questions surrounding the intentional torts, particularly battery, stemming in part from the completion of various stages of the Restatement (Third) of Torts and the current position of the ALI that it will not attempt a restatement of the non-economic intentional torts that were addressed in great detail in the Restatement (Second) on the grounds that intentional tort doctrine is clear and that the Restatement (Second) provisions have been widely adopted. This article joins the work of several torts scholars who have recently questioned the clarity of intentional tort law doctrine. These scholars have focused on the ambiguity of the Restatement’s provisions with respect to the intent to cause a harmful or offensive bodily contact, that is, whether these provisions require both intent to cause bodily contact and intent to cause harm or offense (dual intent) or whether it is sufficient that the defendant intends a bodily contact that turns out to be either harmful or offensive (single intent). Some of these scholars have also suggested that the essence of battery is not the intent to cause a harmful or offensive contact, but rather the intent to cause an unpermitted contact. This article demonstrates that the current confusion and controversy over battery law doctrine is far more extensive than even these recent torts scholars have demonstrated. It extends beyond the element of intent and includes uncertainty concerning the role of the plaintiff’s lack of actual or apparent consent - that is, whether consent is an affirmative defense or whether lack of consent is an element of the plaintiff’s prima facie case - and the relationship between intent and lack of consent. Moreover, this confusion and controversy is reflected not only in modern battery court opinions, but also in the cursory and contradictory treatment given to battery law in most torts casebooks and treatises. Finally, despite the ALI’s assumption that the Restatement provisions have been widely adopted, there are many jurisdictions where courts are formulating battery doctrine using terminology that departs significantly from the Restatement provisions. Part I of this article gives a detailed account of the current confusion and controversy in battery doctrine. Part II provides a brief account of the historical development of the modern tort of battery, which is necessary to understanding why it is that so ma","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2012-02-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"88916979","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}
Informants are valued law enforcement tools, and active criminal informants – criminals who maintain their illicit connections and feed evidence to the police in exchange for leniency – are the most prized of all. Yet society does little to protect active criminal informants from the substantial risks inherent in their recruitment and cooperation. As I have explored elsewhere, society’s apathy toward these informants is a result of distaste with their disloyalty and a concern that protecting them will undermine law enforcement effectiveness. This Article takes a different tack, however, building on existing scholarship on vulnerability and paternalism to argue that society has a duty to protect some vulnerable informant interests. In particular, I assess informant vulnerabilities against accepted societal norms to determine which informants deserve greatest protection and balance informant autonomy interests against informant interests in avoiding harm.Against this backdrop, I propose safeguards to protect the vulnerable safety and autonomy interests of active criminal informants that most deserve society’s protection while minimally interfering with law enforcement effectiveness. The proposals include: requiring court approval for the use of particularly vulnerable active informants and prosecutorial consent for the use of all others; providing training for informants and law enforcement agents in minimizing the risks of harm from cooperation; and folding informants into existing workers’ compensation schemes.
{"title":"Brass Rings and Red-Headed Stepchildren: Protecting Active Criminal Informants","authors":"M. Rich","doi":"10.2139/SSRN.1998787","DOIUrl":"https://doi.org/10.2139/SSRN.1998787","url":null,"abstract":"Informants are valued law enforcement tools, and active criminal informants – criminals who maintain their illicit connections and feed evidence to the police in exchange for leniency – are the most prized of all. Yet society does little to protect active criminal informants from the substantial risks inherent in their recruitment and cooperation. As I have explored elsewhere, society’s apathy toward these informants is a result of distaste with their disloyalty and a concern that protecting them will undermine law enforcement effectiveness. This Article takes a different tack, however, building on existing scholarship on vulnerability and paternalism to argue that society has a duty to protect some vulnerable informant interests. In particular, I assess informant vulnerabilities against accepted societal norms to determine which informants deserve greatest protection and balance informant autonomy interests against informant interests in avoiding harm.Against this backdrop, I propose safeguards to protect the vulnerable safety and autonomy interests of active criminal informants that most deserve society’s protection while minimally interfering with law enforcement effectiveness. The proposals include: requiring court approval for the use of particularly vulnerable active informants and prosecutorial consent for the use of all others; providing training for informants and law enforcement agents in minimizing the risks of harm from cooperation; and folding informants into existing workers’ compensation schemes.","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2012-02-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"89733299","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 newest approach to discouraging children's unhealthy eating habits, amidst increasing rates of childhood obesity and other diet-related diseases, seeks to ban something that is not even edible. In 2010, San Francisco enacted the Healthy Food Incentives Ordinance, which prohibits toys in kids' meals if the meals do not meet certain nutritional requirements. Notwithstanding the Ordinance's impact on interstate commerce or potential infringement on companies' commercial speech rights and on parents' rights to determine what their children eat, this Comment argues that the Ordinance does not violate the dormant Commerce Clause, the First Amendment, or substantive due process. The irony is that although the Ordinance likely avoids the constitutional hurdles that hindered earlier measures aimed at childhood obesity, it intrudes on civil liberties more than its predecessors. This Comment analyzes the legality of the Healthy Food Incentives Ordinance to understand its implications on subsequent legislation aimed at combating childhood obesity and on the progression of public health law.
{"title":"No toy for you! The healthy food incentives ordinance: paternalism or consumer protection?","authors":"Alexis M Etow","doi":"","DOIUrl":"","url":null,"abstract":"<p><p>The newest approach to discouraging children's unhealthy eating habits, amidst increasing rates of childhood obesity and other diet-related diseases, seeks to ban something that is not even edible. In 2010, San Francisco enacted the Healthy Food Incentives Ordinance, which prohibits toys in kids' meals if the meals do not meet certain nutritional requirements. Notwithstanding the Ordinance's impact on interstate commerce or potential infringement on companies' commercial speech rights and on parents' rights to determine what their children eat, this Comment argues that the Ordinance does not violate the dormant Commerce Clause, the First Amendment, or substantive due process. The irony is that although the Ordinance likely avoids the constitutional hurdles that hindered earlier measures aimed at childhood obesity, it intrudes on civil liberties more than its predecessors. This Comment analyzes the legality of the Healthy Food Incentives Ordinance to understand its implications on subsequent legislation aimed at combating childhood obesity and on the progression of public health law.</p>","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2012-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"32762254","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":"The Federal Circuit's decision in Myriad: isolated DNA molecules are patentable subject matter.","authors":"Seth R Ogden","doi":"","DOIUrl":"","url":null,"abstract":"","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2011-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"32762252","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 shot in the arm: what a modern approach to Jacobson v. Massachusetts means for mandatory vaccinations during a public health emergency.","authors":"Ben Horowitz","doi":"","DOIUrl":"","url":null,"abstract":"","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2011-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"32762251","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":"Veterans benefits in 2010: a new dialogue between the Supreme Court and the Federal Circuit.","authors":"Paul R Gugliuzza","doi":"","DOIUrl":"","url":null,"abstract":"","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2011-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"32762250","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}
Expressing its concern about growing rates of cancer and other diseases, coupled with the lack of data about the effect of the thousands of chemicals used in U.S. society, in 1976 Congress enacted the Toxic Substances Control Act (TSCA). Congress intended for TSCA to shed new light on chemical risks and provide the U.S. Environmental Protection Agency (EPA) with a set of tools to address those risks and protect human health and the environment. In the years since TSCA's passage, the procedural hurdles and the difficult-to-meet legal standards built into the statute, along with a court decision rejecting EPA's use of its authority to ban dangerous chemicals, have impeded EPA's ability to regulate chemical use and manufacture. This Comment argues that both the EPA and state governments have the authority to act now to address the risks posed by dangerous chemicals. By utilizing certain sections of the statute in new and aggressive ways, EPA can effectively address chemical risks. Further, this Comment argues that TSCA's preemption provision affords states leeway to continue to regulate the use of chemicals within their borders. Though reform of TSCA is necessary, EPA and states can effectively protect against chemical risks in the near-term by using the full extent of their authority under the current law.
{"title":"Human health and the environment can't wait for reform: current opportunities for the federal government and states to address chemical risks under the Toxic Substances Control Act.","authors":"Lauren Trevisan","doi":"","DOIUrl":"","url":null,"abstract":"<p><p>Expressing its concern about growing rates of cancer and other diseases, coupled with the lack of data about the effect of the thousands of chemicals used in U.S. society, in 1976 Congress enacted the Toxic Substances Control Act (TSCA). Congress intended for TSCA to shed new light on chemical risks and provide the U.S. Environmental Protection Agency (EPA) with a set of tools to address those risks and protect human health and the environment. In the years since TSCA's passage, the procedural hurdles and the difficult-to-meet legal standards built into the statute, along with a court decision rejecting EPA's use of its authority to ban dangerous chemicals, have impeded EPA's ability to regulate chemical use and manufacture. This Comment argues that both the EPA and state governments have the authority to act now to address the risks posed by dangerous chemicals. By utilizing certain sections of the statute in new and aggressive ways, EPA can effectively address chemical risks. Further, this Comment argues that TSCA's preemption provision affords states leeway to continue to regulate the use of chemicals within their borders. Though reform of TSCA is necessary, EPA and states can effectively protect against chemical risks in the near-term by using the full extent of their authority under the current law.</p>","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2011-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"32762253","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}
Directors’ and officers’ liability under corporate and securities laws continues to be a hotly debated subject. Yet, their liability toward non-shareholder third parties under common tort law and statutory provisions has generated relatively modest scholarly interest. Thus, it has gone mostly unnoticed that corporate directors and officers can be held personally liable in tort to non-shareholder third parties based on failures in exercising their core corporate duties - supervision and management.However, as this article explains, the current liability regime in this area is in need of repair. It fails to distinguish between the corporation’s duties and the duties of directors and officers, neglects the separate corporate personality of the corporation, unduly shifts the risk of doing business to directors and officers, and undermines the heightened liability protections provided to directors and officers by corporate laws. Consequently, a new approach is required. This article proposes a novel model for corporate liability that is centered around the nature of directors’ and officers’ duties and focuses on the individual’s state of mind. At its core, the proposed model is based on the belief that in order to preserve the corporate shield, liability standards in tort law should not conflate the standards imposed on individuals with those imposed on directors and officers.
{"title":"The Curious Case of Directors' and Officers' Liability for Supervision and Management: Exploring the Intersection of Corporate and Tort Law","authors":"M. Petrin","doi":"10.2139/SSRN.1407589","DOIUrl":"https://doi.org/10.2139/SSRN.1407589","url":null,"abstract":"Directors’ and officers’ liability under corporate and securities laws continues to be a hotly debated subject. Yet, their liability toward non-shareholder third parties under common tort law and statutory provisions has generated relatively modest scholarly interest. Thus, it has gone mostly unnoticed that corporate directors and officers can be held personally liable in tort to non-shareholder third parties based on failures in exercising their core corporate duties - supervision and management.However, as this article explains, the current liability regime in this area is in need of repair. It fails to distinguish between the corporation’s duties and the duties of directors and officers, neglects the separate corporate personality of the corporation, unduly shifts the risk of doing business to directors and officers, and undermines the heightened liability protections provided to directors and officers by corporate laws. Consequently, a new approach is required. This article proposes a novel model for corporate liability that is centered around the nature of directors’ and officers’ duties and focuses on the individual’s state of mind. At its core, the proposed model is based on the belief that in order to preserve the corporate shield, liability standards in tort law should not conflate the standards imposed on individuals with those imposed on directors and officers.","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2010-01-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"85255726","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 : 2009-01-01DOI: 10.1017/CBO9780511609800.061
William J. Turnier, P. J. Conover, D. Lowery
{"title":"Critical Tax Theory: Redistributive Justice and Cultural Feminism","authors":"William J. Turnier, P. J. Conover, D. Lowery","doi":"10.1017/CBO9780511609800.061","DOIUrl":"https://doi.org/10.1017/CBO9780511609800.061","url":null,"abstract":"","PeriodicalId":80193,"journal":{"name":"The American University law review","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2009-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"88065070","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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