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Regulatory History And Judicial Review, Todd Phillips, Anthony Moffa Jan 2026

Regulatory History And Judicial Review, Todd Phillips, Anthony Moffa

Minnesota Law Review Vols. 106:2 onward (2021-present)

The Administrative Procedure Act (APA) requires federal agencies to simply “incorporate in the rules adopted a concise general statement of their basis and purpose” after they receive comments from the public, and the Supreme Court ruled in Overton Park that courts are to adjudicate whether rules are arbitrary and capricious based on agencies’ contemporaneous rationales. Judge-created doctrines incentivize agencies to rely on these “concise” statements to elucidate their rationales, and, as a result, rulemaking preambles have ballooned in size as agencies seek to insulate themselves from critical courts.

This Article contends that although the APA’s statutory requirement is in tension …


Flexible Work, Rigid Discrimination, Natalia Ramírez Lee Jan 2026

Flexible Work, Rigid Discrimination, Natalia Ramírez Lee

Minnesota Law Review Vols. 106:2 onward (2021-present)

Legal scholars optimistically predicted that the adoption of remote work would provide historically excluded workers upward mobility through an opportunity to join the workforce or access better jobs. Remote work is now widespread and the empirical data on it demonstrates that, in practice, remote work arrangements are subject to the same workplace norms and biases that disadvantage marginalized groups on-site, risking exacerbating instead of remediating inequalities. Specifically, the data suggests that, in some instances, employers are deploying remote work unequally, denying remote work to workers of color who particularly benefit from flexibility.

This Article explains how the legal system is …


The Judiciary's Intrusion Into The Power To Tax: The Constitutionality Of Taxing Unrealized Gains And Argument For Deference To The Elected Branches, Blaise Knueppel Jan 2026

The Judiciary's Intrusion Into The Power To Tax: The Constitutionality Of Taxing Unrealized Gains And Argument For Deference To The Elected Branches, Blaise Knueppel

Minnesota Law Review Vols. 106:2 onward (2021-present)

In the United States, investment income (e.g., capital gains, dividends, interest) is favored over earned income (e.g., salary, self-employment, tips). While Congress bears some responsibility for the favorable treatment that investment income gets, it has not acted alone. The judiciary, for its part, has contributed a rule that shields any taxation of investments until they have become realized. In Eisner v. Macomber (1920), the Supreme Court determined that investments must be separated from their capital and that there must be some form of receipt before the gain is considered taxable. In other words, the Macomber Court read a rule that …


Improving Psychiatric Paraprofessional Preparedness Through Mental Health First Aid Training In An Outpatient Mental Health Clinic, Anisha Hampton Jan 2026

Improving Psychiatric Paraprofessional Preparedness Through Mental Health First Aid Training In An Outpatient Mental Health Clinic, Anisha Hampton

DNP Scholarly Projects

BACKGROUND: Paraprofessional staff in outpatient mental health clinics play a critical role in monitoring clients with serious mental illness (SMI) and supporting continuity of care in community-based settings. However, the absence of standardized training contributes to variability in staff knowledge, confidence, and ability to recognize early signs of mental health deterioration. Mental Health First Aid (MHFA) is an evidence-based training designed to improve mental health literacy and crisis response skills among frontline workers.

METHODS: This quality improvement project utilized a pre-post design within a Plan-DoStudy-Act (PDSA) framework at an outpatient mental health clinic. Paraprofessional staff completed the Mental Health Literacy …


Integrating Brief Cognitive Behavioral Therapy Into Telepsychiatry: A Professional Development Model For Pmhnps, Catherine A. Roberts Jan 2026

Integrating Brief Cognitive Behavioral Therapy Into Telepsychiatry: A Professional Development Model For Pmhnps, Catherine A. Roberts

DNP Scholarly Projects

Background: Mental illnesses remain among the most prevalent health conditions in the United States, affecting approximately 23% or nearly one in five adults in 2025 (Centers for Disease Control and Prevention [CDC], 2025); National Institute of Mental Health [NIMH], 2024a). Despite this high prevalence, only 50.6% of adults living with mental health disorders receive treatment (NIMH, 2024a); although the expansion of telepsychiatry has improved access to mental healthcare, medication-management visits are frequently brief and primarily focused on pharmacotherapy thereby limiting opportunities for delivery of psychotherapeutic interventions. This limitation highlights the need for structured, evidence-based psychotherapeutic approaches that can be …


Occupational Therapy’S Role In The School System: Educating Teachers On The Role Of Occupational Therapy And Providing Them With Sensory Processing Strategies, Kiley N. Carter Jan 2026

Occupational Therapy’S Role In The School System: Educating Teachers On The Role Of Occupational Therapy And Providing Them With Sensory Processing Strategies, Kiley N. Carter

OTD Capstone Projects

This capstone project addresses the limited understanding and communication between teachers and occupational therapists (OT) in elementary school settings, particularly in Southern Illinois. Although occupational therapist are essential members of special education teams, teachers often lack clarity about the scope and impact of occupational therapy in schools. The project’s primary aim was to educate teachers about the role of OT and provide them with practical sensory strategies to support students with sensory processing disorders in the classroom. The methodology involved assessing teachers’ needs through observation, reviewing current literature, and collaborating with site and faculty mentors. An educational module and a …


Occupational Therapy For Perinatal Mothers In Rural Community Practice: Development & Implementation Of Educational Modules, Hannah M. Johnson Jan 2026

Occupational Therapy For Perinatal Mothers In Rural Community Practice: Development & Implementation Of Educational Modules, Hannah M. Johnson

OTD Capstone Projects

There are significant gaps in maternal healthcare in rural communities in Illinois where only 65.4% of pregnant people live within 30 minutes of a hospital that provides maternity care (State of Illinois, 2025). Pregnant and postpartum individuals in the region are inadequately supported during their transition to motherhood within the current healthcare system. This capstone project aimed to serve women in Southern Illinois during the perinatal period through occupational therapy-based and trauma-informed educational content. The project was conducted at The Little Resource Center, a parenting and family support center in Carbondale, under the guidance of their staff. Three educational modules, …


The Long And Short Of It: Exploring The Essential Dynamics Of Select Geophysical Flows, Adhithiya Sivakumar Jan 2026

The Long And Short Of It: Exploring The Essential Dynamics Of Select Geophysical Flows, Adhithiya Sivakumar

Doctoral Dissertations

Geophysical flows are central to important climatological processes, yet their strong turbulence and additional complexities -- density stratification, wave-current interaction, and phase change -- make analytical prediction and direct numerical simulation infeasible in many regimes. This dissertation adopts a reductionist approach in which simplified representations -- often inspired by observed scale disparities -- are utilized to isolate and investigate the organizing mechanisms of these complex flows. Within this framework, three distinct but thematically connected problems are studied.

We first study Langmuir turbulence in the open ocean, in which surface gravity waves interact with wind-driven currents to organize the mixed layer …


In Their Own Words: Why First-Generation Minority Students Take On Leadership Roles At Hispanic-Serving Institutions, Suzette Ramsundar Ed.D Jan 2026

In Their Own Words: Why First-Generation Minority Students Take On Leadership Roles At Hispanic-Serving Institutions, Suzette Ramsundar Ed.D

Theses and Dissertations

While there is an abundance of research on student leadership and how it impacts student retention (Tinto, 1987 and Pascarella & Terenzini, 2005), it is typically from the university's perspective. This phenomenological study, however, investigated the experiences and perceptions of first-generation minority students who commuted to campus and pursued leadership roles at Hispanic-Serving Institutions (HSIs). Utilizing phenomenological methodology, this research examined the lived experiences of eight student leaders to understand how they made meaning of their leadership engagement.

Student leaders in this study shared the details of the significant challenges they navigated, including financial pressures, commuting demands, cultural barriers, and …


Electronic Bills Of Lading And Blockchain Technology: A Regulatory Perspective, Hsin-Hua Tsai Jan 2026

Electronic Bills Of Lading And Blockchain Technology: A Regulatory Perspective, Hsin-Hua Tsai

Journal of Marine Science and Technology–Taiwan

Information and communications technology (ICT) systems are increasingly relevant to the maritime sector. Regarding the revolution of the bill of lading, many shipping lines and other technology startups have been looking into developing viable electronic transport documents that have the same functions as paper bills of lading to reduce supply chain risks. The limitations of the paper-based process have become increasingly visible in the COVID-19 crisis. The main purpose of the article is to analyze the application of blockchain bills of lading, which utilizes computational logic to create the digital ledger, and users can set up algorithms and rules to …


Intelligent Formation Control Using Orfbls And Adaptive Backstepping Sliding-Mode Control To Address Uncertain Tilting In Multi-Quadrotors During Wind Gusts, Ching-Chih Tsai, Chun-Fu Mao, Kumail Hussain Jan 2026

Intelligent Formation Control Using Orfbls And Adaptive Backstepping Sliding-Mode Control To Address Uncertain Tilting In Multi-Quadrotors During Wind Gusts, Ching-Chih Tsai, Chun-Fu Mao, Kumail Hussain

Journal of Marine Science and Technology–Taiwan

In terms of aerial robotics, stable and precise formation control is a significant challenge for tilting multi-quadrotors during disturbances. This paper proposes a fixed-time formation control strategy for tilting multi-quadrotors to address the effect of external wind gusts. The observer accurately predicts environmental disturbances and an adaptive backstepping sliding-mode control (ABSMC) method with an output recurrent fuzzy broad learning system (ORFBLS) addresses these disturbances within a finite time. ORFBLS dynamically adjusts its structure through a growing ORFBLS structure to allow nodes to be added as needed. The method's stability is validated using Lyapunov stability theory and ensures the convergence of …


Entrainment And Surfacing Dynamics Of Submerged, Buoyant Turbulent Jets, Zeeshan Saeed Jan 2026

Entrainment And Surfacing Dynamics Of Submerged, Buoyant Turbulent Jets, Zeeshan Saeed

Doctoral Dissertations

Turbulent entrainment (TE) in buoyant jets plays a key role in dispersing environmental contaminants, carrying significant socio-economic implications. For example, the transport of heat and solutes through submarine volcanoes and the discharge of subglacial meltwater crucially affect the marine ecosphere. This, in turn, impacts coastal communities, the supply chains they support, and the broader socio-economic landscape. Therefore, advancing our understanding of how submerged buoyant jets mix and developing remote sensing tools to help monitor their changing status is crucial for devising strategies to mitigate marine-related challenges quickly, economically, and effectively. Therefore, this dissertation has three primary objectives: (I) examine the …


A Dose Of Accountability: Fixing Treaty Enforcement To Combat State Complicity In Transnational Illicit Fentanyl Trafficking, Caitlin Sharma Jan 2026

A Dose Of Accountability: Fixing Treaty Enforcement To Combat State Complicity In Transnational Illicit Fentanyl Trafficking, Caitlin Sharma

Vanderbilt Journal of Transnational Law

The international fentanyl crisis underscores significant gaps in treaty enforcement, particularly with state accountability for drug manufacturing and export practices leading to illicit fentanyl trafficking. Despite preventive measures established by United Nations drug conventions, legal loopholes in these provisions impede meaningful cooperation between state parties. This Note uses key countries, including the United States, Canada, Mexico, China, and India, as case studies in both producing and receiving fentanyl and its precursors. It evaluates current proposals to mitigate the crisis, such as enhanced international cooperation and the potential expansion of the International Criminal Court’s jurisdiction. However, these solutions remain insufficient due …


Biological Use Of Molybdenum And Tungsten Stems Back To 3.4 Billion Years Ago, Rika Anderson, Aya S. Klos, Morgan S. Sobol, Joanne S. Boden, Eva E. Stüeken, Kurt O. Konhauser, Betül Kaçar Jan 2026

Biological Use Of Molybdenum And Tungsten Stems Back To 3.4 Billion Years Ago, Rika Anderson, Aya S. Klos, Morgan S. Sobol, Joanne S. Boden, Eva E. Stüeken, Kurt O. Konhauser, Betül Kaçar

Biology Faculty Work

The biological significance of the transition metal molybdenum (Mo) lies in its function at the catalytic center of several enzymes that drive a wide spectrum of redox reactions underlying global biogeochemical cycles, yet a paradox persists. While modern life ubiquitously relies on Mo, geochemical evidence suggests that its availability in early Earth’s anoxic oceans was extremely limited. Modern organisms can use Mo down to trace levels; however, the rates of Mo-dependent metabolisms slow down when Mo availability decreases, posing fundamental questions about the extent to which changing Mo abundances shaped the evolution of molybdoenzymes, and when early life began harnessing …


Restoring The Wild East: Predicting Public Support For Cougar And Red Wolf Reintroduction In The Eastern United States, Benjamin Ghasemi, Jeremy T. Bruskotter, John A. Vucetich, L. Mark Elbroch, Robyn S. Wilson, Neil H. Carter, Axel Moehrenschlager, Shelby Perry, Joseph W. Hinton Jan 2026

Restoring The Wild East: Predicting Public Support For Cougar And Red Wolf Reintroduction In The Eastern United States, Benjamin Ghasemi, Jeremy T. Bruskotter, John A. Vucetich, L. Mark Elbroch, Robyn S. Wilson, Neil H. Carter, Axel Moehrenschlager, Shelby Perry, Joseph W. Hinton

Michigan Tech Publications

Restoring large carnivores to human-dominated landscapes remains ecologically and socially contentious, though reintroduction may offer important benefits where coexistence is possible. Yet, efforts to reintroduce cougars (Puma concolor) and red wolves (Canis rufus) in the Eastern U.S. face major challenges, largely due to human-caused mortality and opposition. We employed the hazard acceptance model and structural equation modeling to investigate the socio-psychological drivers of public support for reintroduction. Survey data were collected from residents of the Eastern U.S. for cougars (n = 2665) and red wolves (n = 3825). For both species, support was positively associated with perceived personal and societal …


Eng 4801 : Integrating The English Language Arts In Middle And High Schools, English Jan 2026

Eng 4801 : Integrating The English Language Arts In Middle And High Schools, English

Approved Course Proposals

No abstract provided.


A World Of Connection: Asd, Morgan M. Gayton Jan 2026

A World Of Connection: Asd, Morgan M. Gayton

Entry Level Occupational Therapy Doctoral Capstone Projects Class of 2026

Autism Spectrum Disorder is a diagnosis that affects many school-aged children (CDC, 2025). Autistic children can have more difficulties engaging with both their peers and their families, which can lead to a lack of social participation. A World of Connection: ASD was a doctoral capstone project centering on social participation for autistic youth. The project blended the capstone student’s expanded knowledge in performing arts with their education in Occupational Therapy to create a 4-part capstone experience. A scoping review targeting the question “what are the most effective performing arts methods to enhance the social participation of autistic children” yielded 9 …


Moving Forward With Purpose: Aadej Adopts New Mission, Vision, And Values Statements, Jasmine Shafagh Dmd Jan 2026

Moving Forward With Purpose: Aadej Adopts New Mission, Vision, And Values Statements, Jasmine Shafagh Dmd

AADEJ - The Communicator

Regular feature from the president of AADEJ, Dr. Jasmine R. Shafagh with the latest updates from AADEJ.


Little Minds, Big Emotions, Marissa Fattorusso Jan 2026

Little Minds, Big Emotions, Marissa Fattorusso

Entry Level Occupational Therapy Doctoral Capstone Projects Class of 2026

Little Minds, Big Emotions is a doctoral capstone project designed to support the development of emotional regulation skills in preschool-aged children through the areas of program development, education, and clinical skills development. Emotional regulation is an essential component of children' s participation, social interactions, and overall well-being, yet many young children experience difficulties identifying emotions and using effective calming strategies. The purpose of this capstone project was to develop and implement a developmentally appropriate, play-based emotional regulation curriculum for preschool children while also providing educational resources for caregivers. This program was implemented three days a week for 14 weeks at …


A Neo-Kuyperian Approach To Mathematics, Calvin Jongsma, Kevin Vander Meulen Jan 2026

A Neo-Kuyperian Approach To Mathematics, Calvin Jongsma, Kevin Vander Meulen

Faculty Work Comprehensive List

This chapter develops a Reformational perspective on the discipline of mathematics that stems from the seminal ideas of Kuyper, Dooyeweerd, Wolters, Clouser, and others. The implications of the Biblical motif of Creation-Fall-Redemption is explored for the task of Christian scholarship in general and for the field of mathematics in particular, drawing upon relevant developments in the history and philosophy of mathematics.


Ambiguity's Final Auer: Insisting On Consistency After Loper Bright Enterprises, Shannon S. Pickrell Jan 2026

Ambiguity's Final Auer: Insisting On Consistency After Loper Bright Enterprises, Shannon S. Pickrell

Emory Law Journal

Can one lose something they still have? Apart from this potential brainteaser, a common sense understanding of loss requires an item to actually be removed from its owner. Nevertheless, under the United States Sentencing Commission Guidelines, an interpretive rule automatically punishes convicted defendants for money they never took by including “intended loss” in the definition of loss. This interpretive rule multiplies the number of years a defendant spends in prison due to the doctrine of Auer deference, even though such a rule is not supposed to have the weight of law. Auer deference requires courts to defer to agency interpretations …


Silver Lining In A Soap Opera: A Boon For Hospital Debtors In The Midst Of In Re Steward's Madness, Mackie S. Garwood Jan 2026

Silver Lining In A Soap Opera: A Boon For Hospital Debtors In The Midst Of In Re Steward's Madness, Mackie S. Garwood

Emory Law Journal

Lost in the technical jargon of the Medicare Statute and Bankruptcy Code are the powers to shape the posterity of hospitals that serve the American public. Distressed health care providers are increasingly turning to Chapter 11 relief, and ultimately the deal market, to salvage their businesses and fully monetize their assets. In the frequent event of an unsuccessful reorganization, hospital failures tank the health and well-being of their surrounding communities.

Hospital buyers regularly acquire a debtor’s Medicare Provider Agreement (Provider Agreement), a one-page form which credentials providers to participate in Medicare. In re Steward Health Care System, LLC, the …


Is The Gig Really Up?: Exploring Statutory Protections For Moonlighting Workers, Chiazom E. Ugo-Obi Jan 2026

Is The Gig Really Up?: Exploring Statutory Protections For Moonlighting Workers, Chiazom E. Ugo-Obi

Emory Law Journal

Moonlighting, side hustles, and part-time jobs often refer to secondary employment pursued by employees. While the terminology may vary, the underlying reality remains the same: Legal protections against an employer’s ability to restrict such activities are limited. Nothing stops employers from implementing policies or employment contracts prohibiting participation in additional employment. For many workers, holding an additional job is not a choice born of passion or professional fulfillment but a financial necessity driven by rising costs, stagnant wages, and economic instability. These workers, often already vulnerable within the labor market, face significant challenges when employers impose restrictive policies that limit …


Genes For Sale!, Anya E.R. Prince Jan 2026

Genes For Sale!, Anya E.R. Prince

Emory Law Journal

In March 2025, 23andMe, the flagship direct-to-consumer (DTC) genetic testing company, filed for bankruptcy. Just like that, the genetic information of fifteen million customers was up for sale to the highest bidder, creating a firestorm of reactions from the public, media, state attorneys general, and legislators warning of the dire outcomes that could arise from the sale of such sensitive data. The warnings seemed reasonable, as federal law does little to protect consumers from the widespread sale and misuse of their genetic data.

Yet, in retrospect, the public concerns and media frenzy could potentially be seen as excessive given the …


Unlikely Criminals: Inside The Ivf Drug Grey Market, Maybell Romero Jan 2026

Unlikely Criminals: Inside The Ivf Drug Grey Market, Maybell Romero

Emory Law Journal

In this Article, I admit to committing crimes, specifically buying fertility drugs on the in vitro fertilization (IVF) drug grey market. Drawing from personal experience, I explore how people wanting to undergo IVF turn to the criminalized fertility drug grey market to access necessary but prohibitively expensive fertility medications that would otherwise be out of reach. In the absence of comprehensive insurance coverage, patients often rely on informal online communities to obtain medications at lower prices, often from other patients whose IVF cycles have been canceled or who have excess drugs. While these transactions fulfill a critical need, they also …


Elevated Temperatures Disrupt Wolbachia-Induced Feminisation And Reshape Microbial Community Dynamics Across Generations In A Spider Host, Virginija Mackevicius-Dubickaja, Jennifer A. White, Ellen E. Williams, Eyal Klement, Yuval Gottlieb, Matthew R. Doremus Jan 2026

Elevated Temperatures Disrupt Wolbachia-Induced Feminisation And Reshape Microbial Community Dynamics Across Generations In A Spider Host, Virginija Mackevicius-Dubickaja, Jennifer A. White, Ellen E. Williams, Eyal Klement, Yuval Gottlieb, Matthew R. Doremus

Entomology Faculty Publications

Longitudinal microbial interactions within a host are challenging to study, leading to a focus on constructed microbial communities in vitro settings. Here, we take advantage of a naturally defined microbial community within a spider host to study how elevated temperatures influence microbial dynamics and phenotypes across host generations. The spider Mermessus fradeorum hosts up to five endosymbionts, including a Wolbachia strain, W1, which induces feminisation, causing genetic males to develop as phenotypic females, skewing sex ratios and promoting symbiont spread. Despite this, Wolbachia 1 persists at intermediate frequencies in wild populations. We hypothesised that elevated temperatures might reduce penetration of …


Variability In Mountain Pine Beetle (Coleoptera: Curculionidae) Gene Expression In Response To Increasing Concentrations Of Species-Specific Double-Stranded Rna, Kylie J. Bickler, Zachary Bragg, Flávia Pampolini, Bethany R. Kyre, Lynne K. Rieske Jan 2026

Variability In Mountain Pine Beetle (Coleoptera: Curculionidae) Gene Expression In Response To Increasing Concentrations Of Species-Specific Double-Stranded Rna, Kylie J. Bickler, Zachary Bragg, Flávia Pampolini, Bethany R. Kyre, Lynne K. Rieske

Entomology Faculty Publications

Sensitivity to double-stranded RNA (dsRNA)-induced gene silencing has been observed in multiple coleopterans. Initial work with mountain pine beetle, Dendroctonus ponderosae Hopkins, determined that specific ubiquitously expressed essential genes can cause mortality when silenced by carefully designed dsRNAs. However, current dsRNA production methods are not economically feasible for production at scale. Therefore, identifying the minimum efficacious dose is a critical step to deployment. To investigate the relationship between dsRNA dose and subsequent gene expression, adult mountain pine beetles were fed either a target or control dsRNA across a gradient of concentrations, including 2.5, 1.0, 0.25, and 0.025µg/µl, and relative gene …


Dissolution Or Restructuring? Fiscal Implications For Taxpayers In Special Tax Districts: A Case Study Of The Reedy Creek Improvement District, Tasha Huber Jan 2026

Dissolution Or Restructuring? Fiscal Implications For Taxpayers In Special Tax Districts: A Case Study Of The Reedy Creek Improvement District, Tasha Huber

MPA/MPP/MPFM Capstone Projects

Although extensive research has examined the creation and function of special tax districts in the U.S., little research has been done regarding the fiscal and governance implications of dissolution of these entities. This study examines the fiscal outcomes of dissolution versus restructuring special districts, using the former Reedy Creek Improvement District as the primary case study. Using a qualitative approach, the analysis compares restructuring and dissolution cases in California, Vermont, and Tennessee. Drawing on publicly available material such as financial documents, media coverage, and legislative records, this research evaluates impacts on taxpayer burden. Findings suggest that dissolving large, active special …


Ai Data Center Boom: An Analysis Of Economic And Legislative Impacts, Shelby Jackson Jan 2026

Ai Data Center Boom: An Analysis Of Economic And Legislative Impacts, Shelby Jackson

MPA/MPP/MPFM Capstone Projects

The United States is currently experiencing an Artificial Intelligence (AI) data center boom due to increased demand for generative AI following the launch of models such as ChatGPT. Data centers, particularly hyperscale data centers, have become a flashpoint due to environmental and public health concerns, along with rising utility costs. Although more than 70% of Americans do not want data centers in their community, state and local governments often offer tax incentives to attract data center development with the aim of job creation and tax revenue.

This study assessed whether the financial benefits that AI data centers may offer state …


Balancing Accountability And Efficiency: A Policy Review Of The City Of Toledo's Purchasing Contract Threshold, Jennifer L. Baskey Jan 2026

Balancing Accountability And Efficiency: A Policy Review Of The City Of Toledo's Purchasing Contract Threshold, Jennifer L. Baskey

MPA/MPP/MPFM Capstone Projects

Municipal procurement policies are intended to balance fiscal accountability with the efficient acquisition of goods and services necessary to support public operations. One of the primary mechanisms used to achieve this balance is the establishment of purchasing thresholds that determine when formal contracts are required. While these controls are essential for protecting public resources, procurement policies should also evolve to reflect changing economic conditions and contemporary public-sector management practices.

The City of Toledo currently requires formal contracts and legislative approval for purchases exceeding $10,000 pursuant to Toledo Municipal Code, Chapter 13, Section 228 (City of Toledo Municipal Code, 2026). This …