Seeking Liberty’s Refuge: Analyzing Legislative Purpose Under Casey’s Undue Burden Standard

In the 1992 decision Planned Parenthood of Southeastern Pennsylvania v. Casey, the U.S. Supreme Court crafted the “undue burden” standard for evaluating the constitutionality of abortion laws. Under that standard, a state is free to regulate abortion, as long as the regulation does not impose an undue burden on a woman’s right to an abortion. Although the standard is disjunctive, the Casey opinion focuses on the “effect” prong of the test, with little guidance as to what a “purpose” prong inquiry would look like. Subsequent Supreme Court abortion jurisprudence has served only to obscure the issue. Circuit courts, therefore, have taken differing approaches to claims that an abortion law was adopted for an invalid purpose. This Note addresses the divide in how courts evaluate purpose-based challenges under Casey’s undue burden standard. One group of courts— including the Tenth, Fifth, and Eighth Circuits—apply heightened scrutiny to purpose prong challenges, requiring that the state articulate an important governmental interest, which is substantially related to the regulation in question. In contrast, a second group of courts–comprised of the Seventh and Fourth Circuits–apply rational basis review to purpose-based claims, requiring only that the law be rationally related to a legitimate state interest. This Note argues that the application of heightened scrutiny to purpose-based challenges more accurately applies prior Supreme Court abortion precedent, and is more consonant with substantive due process jurisprudence as a whole. It concludes with a discussion of the effect that heightened scrutiny would have on many common abortion laws

Introduction to a Special Issue on Disclosure and Concealment in Psychotherapy

Given that questions related to disclosure have long held the interest of both clinicians and researchers, we are excited to present this special issue of Counselling Psychology Quarterly focusing on disclosure and concealment in psychotherapy. All forms of human communication involve some degree of disclosure, whether through verbal or non-verbal means. Most of us are quite careful about both the content and quantity of what we share with others. One factor that affects decisions about disclosure is the type of relationship. Friendships typically include an approximately equal amount of disclosure from both members, whereas in other relationships (e.g. parent–child, boss–employee), disclosure patterns may be less equal. Psychotherapy is one such relationship where participants likely do not disclose equally. Clients are expected to reveal themselves as much as possible so that therapists can help them, although the depth of such disclosures may gradually evolve as clients begin to feel safe with their therapists. In contrast, given that the purpose of psychotherapy is to help the client, therapist self-disclosure (TSD) is usually much more limited and ideally used only to help the client rather than meet therapists’ needs. Because psychotherapy is on the one hand much like a friendship, given the level of intimacy and sharing (Schofield, 1986), yet on the other hand a professional relationship focused on the client, it offers a rich opportunity for examining the disclosure process. We can consider disclosure to exist on a continuum. At one extreme, nothing is withheld and the person is completely open with all conscious thoughts and feelings. At the other extreme, a person does not disclose at all and in fact, might be actively concealing or lying. Few people live at the extremes, as it is almost impossible either to share or withhold all thoughts and feelings. In addition, it is important to recognize that disclosure is a state rather than a trait, such that although one may be generally open, that same person might not disclose in a particular given situation. For this special section, then, we focus on several aspects of this disclosure continuum. First, we focus on TSD. Next, we focus on client disclosure and concealment. We refer readers to prior reviews of the literature to gain more perspective on past research in this area (Henretty, Berman, Currier, & Levitt, 2014; Henretty & Levitt, 2010; Hill & Knox, 2002; Knox & Hill, 2003)

The Use of Dreams in Modern Psychotherapy

We review theories of dream work. We also review the empirical research about how dreams are used in psychotherapy, as well as the process and outcome of different models of dream work. Finally, we review how dream content can be used to understand client, the role of culture in dream work, client and therapist dreams about each other, and training therapists to do dream work

A new state space model for the NASA/JPL 70-meter antenna servo controls

A control axis referenced model of the NASA/JPL 70-m antenna structure is combined with the dynamic equations of servo components to produce a comprehansive state variable (matrix) model of the coupled system. An interactive Fortran program for generating the linear system model and computing its salient parameters is described. Results are produced in a state variable, block diagram, and in factored transfer function forms to facilitate design and analysis by classical as well as modern control methods

Processing the Therapeutic Relationship

The authors propose that if therapists and clients process their therapeutic relationship (i.e., directly address in the here and now feelings about each other and about the inevitable problems that emerge in the therapy relationship), feelings will be expressed and accepted, problems will be resolved, the relationship will be enhanced, and clients will transfer their learning to other relationships outside of therapy. The authors review theories supporting the idea of processing the therapeutic relationship, discuss the relevant empirical literature in this area, and provide their conceptualization of the construct of processing the therapeutic relationship based on the theory and empirical findings. Finally, they discuss methodological concerns and suggest implications for clinical practice, training, and further research

A correct, precise and efficient integration of set-sharing, freeness and linearity for the analysis of finite and rational tree languages

It is well known that freeness and linearity information positively interact with aliasing information, allowing both the precision and the efficiency of the sharing analysis of logic programs to be improved. In this paper, we present a novel combination of set-sharing with freeness and linearity information, which is characterized by an improved abstract unification operator. We provide a new abstraction function and prove the correctness of the analysis for both the finite tree and the rational tree cases. Moreover, we show that the same notion of redundant information as identified in Bagnara et al. (2000) and Zaffanella et al. (2002) also applies to this abstract domain combination: this allows for the implementation of an abstract unification operator running in polynomial time and achieving the same precision on all the considered observable properties

The Efficacy of Selected Desensitizing OTC Products: A Systematic Review.

Licensed by the Creative Commons Attribution LicenseObjectives. The aim of the present study was to review the published literature in order to identify relevant studies for inclusion and to determine whether there was any evidence on the clinical effectiveness of selected desensitizing toothpastes, calcium sodium phosphosilicate (CSPS), amorphous calcium phosphate (ACP), nanohydroxyapatite, and casein phosphopeptide-amorphous calcium phosphate (tooth mousse) on reducing dentine hypersensitivity (DH). Materials and Methods. Following a review of 593 papers identified from searching both electronic databases (PUBMED) and hand searching of relevant written journals, only 5 papers were accepted for inclusion. Results. Analysis of the included studies (3 CSPS and 2 ACP) would suggest that there may be some benefit for patients using these products for reducing DH. No direct comparative studies were available to assess all these products under the same conditions neither were there any comparative randomised controlled studies that compared at least two of these products in determining their effectiveness in treating DH. Conclusions. Due to the small number of included studies, there are limited clinical data to support any claims of clinical efficacy of these OTC products. Further studies are therefore required to determine the efficacy of these products in well-controlled RCT studies with a larger sample size

Burst diaphragm flow initiator Patent

Burst diaphragm flow initiator for installation in short duration wind tunnel

Out-of-School Immigrant Youth

Describes the population of out-of-school immigrant youth in California and the subset of this group served by California's Migrant Education Program. Suggests ways to target services, improve future data collection, and enhance program organization