Pub Date : 2021-08-21DOI: 10.52214/CJGL.V40I3.8623
Callen Lowell
Live-in workers, for whom their bosses are typically also their landlords, are often trapped in sexually harassing situations that feel as though they have no practical or legal redress, especially when the worker’s harasser can both fire and evict them in one fell swoop. This Note explores the novel possibility of using fair housing law, including the Fair Housing Act (“FHA”) and state/local fair housing statutes, as a tool to provide legal protections to workers with employer-provided housing (“live-in workers”) who experience sexual harassment or violence in the workplace. There is currently very little case law in which live-in workers have brought fair housing and employment discrimination claims simultaneously, and functionally no case law in which attorneys have brought both claims for live-in worker sexual harassment cases. This Note argues that, under existing fair housing law, many live-in workers should be eligible to bring claims under the FHA and equivalent state laws that prohibit discrimination in housing. As a result, the FHA and equivalent state claims can provide sexual harassment and assault protections for workers, including domestic workers and farmworkers, who may not receive protections under federal or state employment discrimination law. Furthermore, this Note argues that the FHA can provide supplemental or stronger protections from sexual harassment for live-in workers than traditional Title VII or employment discrimination claims. It accordingly suggests that plaintiffs facing harassment or sexual assault in live-in industries should pursue fair housing claims in addition to or in place of Title VII and employment discrimination claims, in order to achieve maximum protection and relief.
{"title":"Working 9 to Non-Stop: The Fair Housing Act's Sexual Harassment Protections for Domestic, Agricultural, and Other Live-In Workers","authors":"Callen Lowell","doi":"10.52214/CJGL.V40I3.8623","DOIUrl":"https://doi.org/10.52214/CJGL.V40I3.8623","url":null,"abstract":"Live-in workers, for whom their bosses are typically also their landlords, are often trapped in sexually harassing situations that feel as though they have no practical or legal redress, especially when the worker’s harasser can both fire and evict them in one fell swoop. This Note explores the novel possibility of using fair housing law, including the Fair Housing Act (“FHA”) and state/local fair housing statutes, as a tool to provide legal protections to workers with employer-provided housing (“live-in workers”) who experience sexual harassment or violence in the workplace. There is currently very little case law in which live-in workers have brought fair housing and employment discrimination claims simultaneously, and functionally no case law in which attorneys have brought both claims for live-in worker sexual harassment cases. This Note argues that, under existing fair housing law, many live-in workers should be eligible to bring claims under the FHA and equivalent state laws that prohibit discrimination in housing. As a result, the FHA and equivalent state claims can provide sexual harassment and assault protections for workers, including domestic workers and farmworkers, who may not receive protections under federal or state employment discrimination law. Furthermore, this Note argues that the FHA can provide supplemental or stronger protections from sexual harassment for live-in workers than traditional Title VII or employment discrimination claims. It accordingly suggests that plaintiffs facing harassment or sexual assault in live-in industries should pursue fair housing claims in addition to or in place of Title VII and employment discrimination claims, in order to achieve maximum protection and relief.","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2021-08-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"45654597","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 : 2021-08-06DOI: 10.52214/CJGL.V40I3.8599
Sarah Ortlip-Sommers
Federal constitutional jurisprudence, as it stands today, provides insufficient protections for transgender individuals who are incarcerated. Transgender prisoners face high rates of physical and sexual assault, harassment, and other mistreatment by state and federal prison officials and individuals incarcerated with them. Commonly pursued avenues for relief—namely the Eighth Amendment, the Equal Protection Clause of the Fourteenth Amendment, and the right to privacy—present hurdles in the form of too-hard-to-meet legal standards, and they perpetuate harmful stereotypes and cultural norms that should occupy no place in modern constitutional law. This Note proposes that, instead of relying on these inadequate constitutional claims to vindicate their rights, transgender prisoners and their advocates should consider litigating under the Due Process Clause of the Fifth and Fourteenth Amendments, articulating a right to live freely in accordance with one’s gender identity. Recognition of such a right would enable plaintiffs to utilize more favorable substantive due process legal standards and eschew perpetuating outdated notions of gender within the law.
{"title":"Living Freely Behind Bars: Reframing the Due Process Rights of Transgender Prisoners","authors":"Sarah Ortlip-Sommers","doi":"10.52214/CJGL.V40I3.8599","DOIUrl":"https://doi.org/10.52214/CJGL.V40I3.8599","url":null,"abstract":"Federal constitutional jurisprudence, as it stands today, provides insufficient protections for transgender individuals who are incarcerated. Transgender prisoners face high rates of physical and sexual assault, harassment, and other mistreatment by state and federal prison officials and individuals incarcerated with them. Commonly pursued avenues for relief—namely the Eighth Amendment, the Equal Protection Clause of the Fourteenth Amendment, and the right to privacy—present hurdles in the form of too-hard-to-meet legal standards, and they perpetuate harmful stereotypes and cultural norms that should occupy no place in modern constitutional law. This Note proposes that, instead of relying on these inadequate constitutional claims to vindicate their rights, transgender prisoners and their advocates should consider litigating under the Due Process Clause of the Fifth and Fourteenth Amendments, articulating a right to live freely in accordance with one’s gender identity. Recognition of such a right would enable plaintiffs to utilize more favorable substantive due process legal standards and eschew perpetuating outdated notions of gender within the law.","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2021-08-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46608729","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 : 2021-03-25DOI: 10.52214/CJGL.V40I2.8062
Hannah Gutenplan
On January 1, 2020, bail reform laws went into effect in New York that eliminated cash bail for thousands of defendants across the state. In step with other reforming jurisdictions across the country, New York aimed to ensure that a defendant’s freedom before trial would not be determined by the individual’s ability to pay. Unlike other reforming jurisdictions, however, New York’s bail laws do not include public safety as a legitimate factor for judges to consider when setting release conditions. Some domestic violence advocates have expressed concern for victims’ safety during the pretrial period in domestic violence cases. This Note explores the potential impact of New York’s bail reform laws on domestic violence cases and whether any mitigating measures may be implemented to promote victims’ safety.
{"title":"A Fairer, Safer, and More Just System for All New Yorkers: Domestic Violence and New York Bail Reform","authors":"Hannah Gutenplan","doi":"10.52214/CJGL.V40I2.8062","DOIUrl":"https://doi.org/10.52214/CJGL.V40I2.8062","url":null,"abstract":"\u0000 \u0000 \u0000On January 1, 2020, bail reform laws went into effect in New York that eliminated cash bail for thousands of defendants across the state. In step with other reforming jurisdictions across the country, New York aimed to ensure that a defendant’s freedom before trial would not be determined by the individual’s ability to pay. Unlike other reforming jurisdictions, however, New York’s bail laws do not include public safety as a legitimate factor for judges to consider when setting release conditions. Some domestic violence advocates have expressed concern for victims’ safety during the pretrial period in domestic violence cases. This Note explores the potential impact of New York’s bail reform laws on domestic violence cases and whether any mitigating measures may be implemented to promote victims’ safety. \u0000 \u0000 \u0000","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2021-03-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46277413","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 : 2021-03-25DOI: 10.52214/CJGL.V40I2.8063
J. Hickey
Abstract
摘要
{"title":"Nature Is Smarter Than We Are: Midwifery and the Responsive State","authors":"J. Hickey","doi":"10.52214/CJGL.V40I2.8063","DOIUrl":"https://doi.org/10.52214/CJGL.V40I2.8063","url":null,"abstract":"Abstract","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2021-03-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42799563","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 : 2021-03-25DOI: 10.52214/CJGL.V40I2.8061
N. Chandra
Since the 1690s, women in the United States have been arrested and punished for experiencing miscarriages and stillbirths—pregnancy outcomes that are completely normal. This practice continues to the modern day, where prosecutors charge women with concealing a birth, concealing a death, or abuse of a corpse for the actions they take after experiencing pregnancy loss. This Note argues that these statutes were originally enacted to punish women who had sex outside of marriage and are now being used to control women, mostly women of color and poor women, for not adhering to society’s idealized vision of femininity and motherhood. The use of these statutes advances notions of fetal personhood and will ultimately have a chilling effect on the availability of abortion through telemedicine. The Note suggests that while repealing these laws would help, the best solution is to approach the issue through a reproductive justice lens—namely, increasing the availability of education and medical services for women.
{"title":"What To Expect When You’re No Longer Expecting: How States Use Concealment and Abuse of a Corpse Statutes Against Women","authors":"N. Chandra","doi":"10.52214/CJGL.V40I2.8061","DOIUrl":"https://doi.org/10.52214/CJGL.V40I2.8061","url":null,"abstract":"\u0000 \u0000 \u0000Since the 1690s, women in the United States have been arrested and punished for experiencing miscarriages and stillbirths—pregnancy outcomes that are completely normal. This practice continues to the modern day, where prosecutors charge women with concealing a birth, concealing a death, or abuse of a corpse for the actions they take after experiencing pregnancy loss. This Note argues that these statutes were originally enacted to punish women who had sex outside of marriage and are now being used to control women, mostly women of color and poor women, for not adhering to society’s idealized vision of femininity and motherhood. The use of these statutes advances notions of fetal personhood and will ultimately have a chilling effect on the availability of abortion through telemedicine. The Note suggests that while repealing these laws would help, the best solution is to approach the issue through a reproductive justice lens—namely, increasing the availability of education and medical services for women. \u0000 \u0000 \u0000","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2021-03-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"49529585","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}
Morris B Hoffman, Francis X. Shen, Vijeth Iyengar, F. Krueger
We analyzed sentencing data from sixteen years of criminal trials in the State of Colorado, consisting of almost 3,000 individual sentences, and discovered an interaction effect of harm, gender, and age not reported in any of the empirical or experimental literature. Young female judges punished high harm crimes substantially more than their male and older female colleagues. These results, if confirmed, could have significant strategic and tactical implications for practicing lawyers. They may also inform policies surrounding judicial selection, education, training, and retirement.
{"title":"The Intersectionality of Age and Gender on the Bench: Are Younger Female Judges Harsher with Serious Crimes?","authors":"Morris B Hoffman, Francis X. Shen, Vijeth Iyengar, F. Krueger","doi":"10.7916/CJGL.V40I1.7059","DOIUrl":"https://doi.org/10.7916/CJGL.V40I1.7059","url":null,"abstract":"We analyzed sentencing data from sixteen years of criminal trials in the State of Colorado, consisting of almost 3,000 individual sentences, and discovered an interaction effect of harm, gender, and age not reported in any of the empirical or experimental literature. Young female judges punished high harm crimes substantially more than their male and older female colleagues. These results, if confirmed, could have significant strategic and tactical implications for practicing lawyers. They may also inform policies surrounding judicial selection, education, training, and retirement.","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":"40 1","pages":"128-165"},"PeriodicalIF":0.0,"publicationDate":"2020-09-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42991466","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 use of intrastate preemption by states to undo local ordinances enacted to protect reproductive health and access to reproductive services has increased in recent years. State-local conflict is a long-standing aspect of the United States government system; however, these conflicts have become increasingly politicized. Explicit intrastate preemption of localities’ protective action is a new strategy states are using to make accessing reproductive care more difficult and adding burdens to the right to choose. This article explores the intrastate preemption trend, possible litigation under traditional preemption jurisprudence, and reproductive specific litigation strategies to combat this form of anti-choice legislation. While litigation against intrastate preemption may be more successful in the reproductive health space as compared to non-public health related local measures experiencing state preemption, this article concludes that advocacy against intrastate preemption legislation is the best strategy to allow localities to protect access.
{"title":"Intrastate Preemption: A New Frontier in Burdening Choice","authors":"Juliana L. Bennington","doi":"10.7916/CJGL.V40I1.7055","DOIUrl":"https://doi.org/10.7916/CJGL.V40I1.7055","url":null,"abstract":"The use of intrastate preemption by states to undo local ordinances enacted to protect reproductive health and access to reproductive services has increased in recent years. State-local conflict is a long-standing aspect of the United States government system; however, these conflicts have become increasingly politicized. Explicit intrastate preemption of localities’ protective action is a new strategy states are using to make accessing reproductive care more difficult and adding burdens to the right to choose. This article explores the intrastate preemption trend, possible litigation under traditional preemption jurisprudence, and reproductive specific litigation strategies to combat this form of anti-choice legislation. While litigation against intrastate preemption may be more successful in the reproductive health space as compared to non-public health related local measures experiencing state preemption, this article concludes that advocacy against intrastate preemption legislation is the best strategy to allow localities to protect access.","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":"40 1","pages":"93-127"},"PeriodicalIF":0.0,"publicationDate":"2020-09-07","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"43993781","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 Role of the State in the Intra-Group Vulnerability of Women: Revisiting Debates About Multiculturalism Through the Case of Polygamy Among the Bedouins in Israel","authors":"Miriam Zucker","doi":"10.2139/ssrn.3707703","DOIUrl":"https://doi.org/10.2139/ssrn.3707703","url":null,"abstract":"Abstract","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":"1 1","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-08-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47125834","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 article systematically explores the evolving human rights jurisprudence relating to infertility, a significant public health issue worldwide. There is no real question that the failure to prevent infertility, the failure to treat infertility, and the failure to recognize and respond to infertility, raise human rights concerns. But beyond the relevant human rights norms, we argue that human rights analyses can aid jurisdictions in structuring their responses to infertility. Through case studies and country-specific research, we adduce evidence that human rights norms are, in fact, already providing such guidance at the national level. The article further identifies a series of pending human rights challenges in the infertility arena – including the issue of “conditional childlessness” (also known as social infertility) – and offers suggestions for analyzing these issues.
{"title":"Infertility and Human Rights: A Jurisprudential Survey","authors":"Martha F. Davis, R. Khosla","doi":"10.7916/CJGL.V40I1.6847","DOIUrl":"https://doi.org/10.7916/CJGL.V40I1.6847","url":null,"abstract":"This article systematically explores the evolving human rights jurisprudence relating to infertility, a significant public health issue worldwide. There is no real question that the failure to prevent infertility, the failure to treat infertility, and the failure to recognize and respond to infertility, raise human rights concerns. But beyond the relevant human rights norms, we argue that human rights analyses can aid jurisdictions in structuring their responses to infertility. Through case studies and country-specific research, we adduce evidence that human rights norms are, in fact, already providing such guidance at the national level. The article further identifies a series of pending human rights challenges in the infertility arena – including the issue of “conditional childlessness” (also known as social infertility) – and offers suggestions for analyzing these issues.","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":"40 1","pages":"1-45"},"PeriodicalIF":0.0,"publicationDate":"2020-06-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42016016","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}
Between 1946 and 1948, researchers sponsored by the United States government intentionally exposed more than 1,300 Guatemalan men and women to sexually transmitted diseases without their informed consent. Many of the surviving victims and their descendants suffer from the effects of untreated syphilis, gonorrhea, and similar illnesses. But the general public did not become aware of these non-consensual human experiments for more than sixty years. After a researcher uncovered the experiments, the United States government apologized to the Guatemalan victims, but the victims received no compensation for their injuries. So far, the efforts of the victims to receive legal redress for their injuries have been unsuccessful. This Article has two aims—one descriptive and the other conceptual. First, it seeks to bring awareness to the history and legacy of the Guatemalan sexually transmitted disease experiments. Second, it argues that litigation—even if unsuccessful—can play a role in amplifying the victims’ voices in a way that acknowledges their pain and helps to repair harm that was done. Even if the United States government is immune from formal legal liability, the government and the corporate interests that benefitted from the Guatemalan experiments, have a moral obligation to compensate the victims. The lens of reproductive justice makes clear this obligation. By critically investigating the Guatemalan sexually transmitted disease experiments and their legacy, one can better understand how gender, race, socioeconomic class, geopolitical power, and even geography informed the initial decision to conduct non-consensual human experimentation in that country and why the victims have been unable to obtain formal legal recognition for their suffering. * Susan S. Lee will begin her career as Judge Advocate Officer in the United States Air Force in 2020. She is a graduate of North Carolina State University (BA 2015) and the Elisabeth Haub School of Law at Pace University (JD 2019). Aurora Grutman is an independent researcher based in New York City. Affiliations are listed for informational purposes only. The views expressed in this article are those of the individual authors alone and do not represent the views of any employer or affiliated institution. 39.2 COLUMBIA JOURNAL OF GENDER AND LAW 55
{"title":"Seeking Justice for Victims of the Guatemalan Sexually Transmitted Disease Experiments 1946–1948","authors":"S. S. Lee, Aurora J. Grutman","doi":"10.7916/CJGL.V39I2.5700","DOIUrl":"https://doi.org/10.7916/CJGL.V39I2.5700","url":null,"abstract":"Between 1946 and 1948, researchers sponsored by the United States government intentionally exposed more than 1,300 Guatemalan men and women to sexually transmitted diseases without their informed consent. Many of the surviving victims and their descendants suffer from the effects of untreated syphilis, gonorrhea, and similar illnesses. But the general public did not become aware of these non-consensual human experiments for more than sixty years. After a researcher uncovered the experiments, the United States government apologized to the Guatemalan victims, but the victims received no compensation for their injuries. So far, the efforts of the victims to receive legal redress for their injuries have been unsuccessful. This Article has two aims—one descriptive and the other conceptual. First, it seeks to bring awareness to the history and legacy of the Guatemalan sexually transmitted disease experiments. Second, it argues that litigation—even if unsuccessful—can play a role in amplifying the victims’ voices in a way that acknowledges their pain and helps to repair harm that was done. Even if the United States government is immune from formal legal liability, the government and the corporate interests that benefitted from the Guatemalan experiments, have a moral obligation to compensate the victims. The lens of reproductive justice makes clear this obligation. By critically investigating the Guatemalan sexually transmitted disease experiments and their legacy, one can better understand how gender, race, socioeconomic class, geopolitical power, and even geography informed the initial decision to conduct non-consensual human experimentation in that country and why the victims have been unable to obtain formal legal recognition for their suffering. * Susan S. Lee will begin her career as Judge Advocate Officer in the United States Air Force in 2020. She is a graduate of North Carolina State University (BA 2015) and the Elisabeth Haub School of Law at Pace University (JD 2019). Aurora Grutman is an independent researcher based in New York City. Affiliations are listed for informational purposes only. The views expressed in this article are those of the individual authors alone and do not represent the views of any employer or affiliated institution. 39.2 COLUMBIA JOURNAL OF GENDER AND LAW 55","PeriodicalId":84468,"journal":{"name":"Columbia journal of gender and law","volume":"39 1","pages":"54-90"},"PeriodicalIF":0.0,"publicationDate":"2020-04-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"41343169","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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