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The Second Amendment Rights Of Undocumented Immigrants, Alan Mygatt-Tauber Jan 2026

The Second Amendment Rights Of Undocumented Immigrants, Alan Mygatt-Tauber

Nebraska Law Review

In the 2008 case, District of Columbia v. Heller, the Supreme Court, for the first time, held that the Second Amendment protects an individual right to bear arms. Challenges to various federal gun control laws immediately followed, including challenges to 18 U.S.C. § 922(g)(5)(a), which prohibits possession by an undocumented immigrant. Between 2008 and 2022, courts faced with challenges to § 922(g)(5)(a) universally upheld it. Then the Court decided New York State Rifle and Pistol Association v. Bruen, in which it discarded the means-end balancing tests the courts of appeals had adopted, instead preferring a test focused on “history and …


Toward A General Legislative Presumption Of Probation In Nebraska, Velma Lockman Jan 2026

Toward A General Legislative Presumption Of Probation In Nebraska, Velma Lockman

Nebraska Law Review

“It is curious that the Legislature has chosen to give a presumption of probation for more serious felony offenses, but not for lesser misdemeanor offenses.” With those words, Judge Bishop concluded a heart-wrenching opinion in State v. Anderson, which upheld Courtney Anderson’s sentence of 240 days in jail. Despite being sentenced for a first offense Class I misdemeanor and nearly every sentencing factor counseling in favor of probation, the district court decided to separate Ms. Anderson from her two children, one of whom was a newborn. A combination of the Nebraska Supreme Court’s highly deferential standard of review for excessive …


Protecting (Restorative) Justice: An Analysis Of Confidentiality, Admissibility And Privilege Provisions In State Law, Thalia Gonzalez, Aidan Lorraine Tomlinson Jan 2026

Protecting (Restorative) Justice: An Analysis Of Confidentiality, Admissibility And Privilege Provisions In State Law, Thalia Gonzalez, Aidan Lorraine Tomlinson

Nebraska Law Review

Over the last thirty years, the use of restorative justice within and adjacent to state juvenile and criminal proceedings, including community contexts, has expanded significantly in the United States. As such, what once could be fairly characterized by scholars as a norm and practice at the legal margins has moved widely into the mainstream. As increased legal institutionalization occurred, so too has scholarly attention. Shifting away from foundational “first generation” theoretical and empirical legal studies of practices and programs, a second stream of interdisciplinary legal scholarship has emerged centralizing structural questions as to the legalization of restorative justice. In this …


Posthumous Restorative Justice, Michael L. Moffitt Jan 2026

Posthumous Restorative Justice, Michael L. Moffitt

Nebraska Law Review

Restorative justice (“RJ”) processes typically envision the prospect of voluntary participation by those who suffered harm, by those who caused the harm, and often by the community or communities of people who surround them. When one or more of these potential participants opts not to participate, RJ processes often adapt to provide as many of the restorative benefits as possible to those who do choose to participate. This Article asks what, if any, adaptations of RJ processes may be appropriate in contexts in which some or all of the people listed above cannot participate, because they are now dead.


Restorative Reparatory Justice, Inga N. Laurent Jan 2026

Restorative Reparatory Justice, Inga N. Laurent

Nebraska Law Review

As global calls for reparatory justice—aimed at addressing “historical” and ongoing harms stemming from genocide, dispossession, assimilation, and enslavement—grow, this Article explores critical challenges in designing transformative processes of reparation. While a host of transitional justice mechanisms, such as reparations, tribunals, and truth and reconciliation processes are at the forefront of these discussions, a critical examination of their limitations will provide the groundwork for their enhancement. Past applications of transitional justice mechanisms have frequently failed to address root causes of violence, which reinforces State power despite its failures to protect its citizens from that violence, causing secondary harm to survivors/victims.


America’S Recount Addiction, Derek T. Muller Jan 2026

America’S Recount Addiction, Derek T. Muller

Book Chapters

Election recounts are costly and rarely change the results. By narrowing recount laws and relying on more precise safeguards, states can cut costs, deliver final results more swiftly, and reinforce public confidence in elections.

Imprint: NYU Global Access Publications, 2026, Open Access Since 2026.


Parity In Practice: The Defender's Duty To Ethically Use Ai, Mason R. Clark Jan 2026

Parity In Practice: The Defender's Duty To Ethically Use Ai, Mason R. Clark

Faculty Articles

This white paper provides a framework for ethical and practical AI use across all types of criminal defense practice, grounded in the ABA Model Rules of Professional Conduct and best practices as described by practitioners, academics, and other experts. While AI tools can meaningfully improve efficiency and expand analytical capacity, those benefits are highly contingent on tool selection, implementation, and oversight. The white paper also recognizes that cost, access to training, and institutional resources remain significant barriers — particularly for solo practitioners, small firms, and under-resourced public defense offices — and discusses AI throughout as a set of tools whose …


Assessing The Effects Of Theta Transcranial Alternating Current Stimulation During Working Memory Performance On Theta-Gamma Phase Amplitude Coupling In Healthy Adults, Samantha M. Zimmer Jan 2026

Assessing The Effects Of Theta Transcranial Alternating Current Stimulation During Working Memory Performance On Theta-Gamma Phase Amplitude Coupling In Healthy Adults, Samantha M. Zimmer

UNF Graduate Theses and Dissertations

Transcranial alternating current stimulation (tACS) is an emerging form of noninvasive brain stimulation with substantial effects on behavior and brain function due to its ability to entrain endogenous neural oscillations. Working memory is a cognitive process that involves holding onto information that is no longer present in the environment and manipulating or reorganizing information for immediate use. Theta oscillations are critical for the functionality of the frontoparietal network and are involved in strengthening communication and coordination between frontal and parietal brain regions, especially during working memory processing. TACS applied at the theta frequency, targets theta oscillations, strengthens network communications, and …


The Impact Of High-Quality Phonological Awareness Professional Learning On In-Service Teachers' Content Knowledge And Pedagogical Content Knowledge, Roberta S. Thomas Jan 2026

The Impact Of High-Quality Phonological Awareness Professional Learning On In-Service Teachers' Content Knowledge And Pedagogical Content Knowledge, Roberta S. Thomas

UNF Graduate Theses and Dissertations

This convergent mixed-method study examined the impact of high-quality phonological awareness professional learning on Montessori primary lead, associate, and team associate teachers’ content knowledge and pedagogical content knowledge of phonological awareness. Eleven teachers (4 lead, 4 associates, and 2 team associates) from a private school in northeast Florida participated in four professional sessions with a content focus on the levels of phonological awareness, including word, syllable, onset and rime, and phoneme awareness. In contrast to previous studies that reported low levels of teacher content knowledge prior to professional learning, participants in this study demonstrated relatively high levels of content knowledge. …


Transformational Leadership And Employees’ Organizational Citizenship Behavior: Examining The Role Of Perspective-Taking, Job Satisfaction, And Organizational Trust, Marie A. Smith Jan 2026

Transformational Leadership And Employees’ Organizational Citizenship Behavior: Examining The Role Of Perspective-Taking, Job Satisfaction, And Organizational Trust, Marie A. Smith

Dissertations

The study surveyed employees in the service and helping professions (for example retail, healthcare related, hospitality), to examine the impact of transformational leadership on employee organizational citizenship behavior (OCB). Specifically, it tested job satisfaction and organizational trust as possible mediators to the transformational leader to employee OCB relationship and evidence of perspective-taking as a possible moderator to either of these mediated relationships. The study employed PLS-SEM as the method of analysis and examined the influence of transformational leadership, and employee job satisfaction and trust, on employee OCB. The social exchange theory’s reciprocal nature and the leader-member exchange (LMX) theory, based …


Fragmented Conceptions Of Agency In Ai-Enabled Systems: A Bibliometric Analysis Of Is Research., Cherie Noteboom, Vahini Atluri, Stephen Surles Jan 2026

Fragmented Conceptions Of Agency In Ai-Enabled Systems: A Bibliometric Analysis Of Is Research., Cherie Noteboom, Vahini Atluri, Stephen Surles

Research & Publications

As artificial intelligence (AI) systems become increasingly embedded in organizational decision-making and work practices, Information Systems (IS) research has devoted growing attention to questions of agency: who or what acts, decides, and bears responsibility in AI-enabled contexts. However, existing scholarship examines agency across multiple parallel research streams, raising questions about how coherently the construct is theorized as AI technologies evolve. This study conducts a bibliometric analysis of 741 AI- and agency-related articles published between 1977 and 2025 in the AIS Senior Scholars' Basket of Journals to examine how IS research conceptualizes agency and how these conceptualizations have evolved over time. …


Decentralizing Work: How Blockchain Reshapes Project Coordination, Trust, And Accountability Through The Strategic-Decentralized Resilience Theory (Sdrt), Aravindh Sekar, Cherie Noteboom Jan 2026

Decentralizing Work: How Blockchain Reshapes Project Coordination, Trust, And Accountability Through The Strategic-Decentralized Resilience Theory (Sdrt), Aravindh Sekar, Cherie Noteboom

Research & Publications

Blockchain adoption is reshaping how work is organized, coordinated, and governed in project environments. Existing research, however, has largely focused on the methodological and theoretical trends in blockchain-based project management rather than on how blockchain modifies the very structure of work. Building on a systematic literature review of blockchain project management research, this paper draws on the Strategic–Decentralized Resilience Theory (SDRT) as an integrative framework to explain work modification in decentralized project contexts. SDRT captures three interlinked dimensions of resilience: strategic resilience (leadership, alignment, and adaptability), organizational resilience (collaboration, training, and ecosystem readiness), and decentralized resilience (distributed governance, trust, and …


University Of Richmond Magazine - Summer 2026 Jan 2026

University Of Richmond Magazine - Summer 2026

University of Richmond Magazine

No abstract provided.


Coaching For Emotional Resilience And Reflective Growth: Applying The University-Based Coaching Framework In Pre-Service Teacher Supervision, Dana L. Morris Jan 2026

Coaching For Emotional Resilience And Reflective Growth: Applying The University-Based Coaching Framework In Pre-Service Teacher Supervision, Dana L. Morris

Education Faculty Publications and Presentations

Teacher preparation is an emotional as well as a cognitive process in which pre-service teachers must develop both reflective judgment and the emotional resilience needed for demanding instructional contexts. This study examined how university-based supervisors enacted the relational spaces of the University-Based Coaching Framework (UBCF) and how these enactments shaped pre-service teachers’ emotional and reflective development. Drawing on qualitative analysis of coaching discourse among three supervisor-preservice teacher pairs, the comparative case study identifies distinct coaching identities that emerged from supervisors’ patterned relational moves. These identities corresponded to varying intensities of UBCF space enactment and produced differential pathways through a reflective-motional …


Cormac’S Court: Knights Without God In A Savage Land; Or, Chivalry And Existentialism In Cormac Mccarthy’S The Road, Zoë Margaret Metelerkamp Jan 2026

Cormac’S Court: Knights Without God In A Savage Land; Or, Chivalry And Existentialism In Cormac Mccarthy’S The Road, Zoë Margaret Metelerkamp

Graduate Student Theses, Dissertations, & Professional Papers

Cormac McCarthy scholars have examined the influence of romantic grail quest literature and existential philosophy on McCarthy’s oeuvre, but they have treated these subjects independently of each other. This thesis offers a novel exploration of McCarthy’s use of these specific philosophical and literary precedents by focusing on the ways The Road unifies medieval literary principles in Chretien’s Perceval with the existential chivalry Søren Kierkegaard extrapolates in Fear and Trembling.


Adults With Dyslexia: Experiences Accessing And Using Reading Strategies And Assistive Technology, Brenda Rosalie King Jan 2026

Adults With Dyslexia: Experiences Accessing And Using Reading Strategies And Assistive Technology, Brenda Rosalie King

Graduate Student Theses, Dissertations, & Professional Papers

Dyslexia is a specific learning disorder of neurobiological origin characterized by persistent difficulties with accurate and/or fluent reading, word recognition, spelling, and decoding. Although dyslexia is widely recognized as a lifelong learning difference, the majority of research has historically focused on children and adolescents, with less attention given to adult experiences. The purpose of this study was to explore how adults with dyslexia access and use reading strategies and assistive technologies to support reading comprehension and independence across contexts. The study also examined barriers and supports influencing access to these tools, as well as the emotional experiences associated with their …


Comprehensive Characterization Of Volatile Organic Compounds And Particulate Matter Emissions From Residential Wood Combustion And Their Impacts On Indoor And Outdoor Air Quality, Damien Tyler Ketcherside Jan 2026

Comprehensive Characterization Of Volatile Organic Compounds And Particulate Matter Emissions From Residential Wood Combustion And Their Impacts On Indoor And Outdoor Air Quality, Damien Tyler Ketcherside

Graduate Student Theses, Dissertations, & Professional Papers

Residential wood combustion (RWC) is a major wintertime source of fine particulate matter (PM2.5) and a potentially important source of volatile organic compounds (VOCs). Yet, uncertainties remain regarding its contribution to ambient air pollution, its representation in anthropogenic emissions inventories, and its direct impacts on indoor air quality via fugitive emissions. This dissertation investigates VOC and PM2.5 emissions from RWC activities, using in situ measurements of gas- and particle-phase pollutants in indoor and outdoor environments.

Chapter 2 presents ambient field observations of 24 volatile organic compounds (VOCs), carbon monoxide (CO), ozone (O3), and fine particulate matter (PM2.5) in the intermountain …


Real-Time Immersive Wildfire Simulation: A Game Engine Approach, Jake Bova Jan 2026

Real-Time Immersive Wildfire Simulation: A Game Engine Approach, Jake Bova

Graduate Student Theses, Dissertations, & Professional Papers

Wildfires are growing in frequency, size, and severity, placing escalating demands on firefighting resources and putting lives, property, and ecosystems at risk. Accurate prediction of fire behavior is critical to suppression planning, evacuation decisions, and firefighter training, yet the operational models that fire managers rely upon face a persistent tradeoff. High-fidelity physics-based models capture fire–atmosphere interactions faithfully but are computationally expensive, often running far slower than real time on CPU hardware, while faster empirical models sacrifice the dynamic coupling between a fire and the wind field it generates. Furthermore, most existing tools produce abstract, two-dimensional outputs that offer limited visual …


Gvsu Undergraduate And Graduate Catalog 2026-2027, Grand Valley State University Jan 2026

Gvsu Undergraduate And Graduate Catalog 2026-2027, Grand Valley State University

Course Catalogs, 1963 - Current

Grand Valley State University 2026-2027 undergraduate and graduate course catalog. Course catalogs are published annually to provide students with information and guidance for enrollment.


Forget Me Not? Machine Unlearning’S Implications For Privacy Law, Jevan Hutson, Cedric Whitney, Jay T. Conrad Jan 2026

Forget Me Not? Machine Unlearning’S Implications For Privacy Law, Jevan Hutson, Cedric Whitney, Jay T. Conrad

Articles

Generative AI systems are increasingly relied on and are already actively reshaping how we think about privacy and data protection law. Models ingest and process vast amounts of personal and sensitive data, challenging assurances of compliance with legal frameworks like the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) with increasing intensity. Machine unlearning is an emerging tool in practitioners’ attempts to address these challenges: the act of selectively removing or suppressing specific data, such as personal data that a data subject requests be deleted, from AI models as means of complying with legal obligations or …


Scholarly Productivity Of Non–Pharmacy Practice Faculty In U.S. Schools And Colleges Of Pharmacy, 2019–2023, Osama A. Shoair, Sierra Pollard, Faith Fosuhene-Apenteng, Michael Pimentel-Galvan, Abrar Elagami, May H. Abdelaziz Jan 2026

Scholarly Productivity Of Non–Pharmacy Practice Faculty In U.S. Schools And Colleges Of Pharmacy, 2019–2023, Osama A. Shoair, Sierra Pollard, Faith Fosuhene-Apenteng, Michael Pimentel-Galvan, Abrar Elagami, May H. Abdelaziz

Pharmacy Faculty Publications and Presentations

Purpose: Scholarly productivity is central to academic advancement, institutional benchmarking, and accreditation in pharmacy education. This study evaluated the national scholarly productivity among non–pharmacy practice (NPP) faculty in U.S. schools and colleges of pharmacy and assessed variation in publication output across faculty and institutional characteristics.

Methods: A retrospective bibliometric analysis was conducted between January 2019 and December 2023. Faculty were identified using the American Association of Colleges of Pharmacy Roster of Faculty and Professional Staff and classified as biomedical and pharmaceutical sciences (BPS) or social and administrative sciences (SAS). Publications were retrieved from Web of Science and characterized …


Redefining Family Law, 2026: New State Laws From 2025, Family Law Quarterly 2025–2026 Editors, New York Law School Jan 2026

Redefining Family Law, 2026: New State Laws From 2025, Family Law Quarterly 2025–2026 Editors, New York Law School

Redefining Family Law: State Legislative Updates

This is the fifth annual Family Law Quarterly article discussing new state family laws that were enacted in the previous year. The article discusses 34 laws from 27 states, New York City, and the District of Columbia, grouped into the following categories: (1) Child Welfare, (2) Parents’ and Children’s Rights, (3) Parentage, (4) Child Custody and Visitation, (5) Financial Support, (6) Domestic Violence, and (7) Technology and Artificial Intelligence. Specific topics of the laws featured in this article include, among others: • Restrictions on anonymous reports of child abuse and neglect (New York); • Protections for gender-affirming and reproductive health …


Reinterpreting Stochastic Optimal Control Under Ecological Uncertainty: Inferring Decision Urgency From Vegetation Biomass Dynamics, Komi Mensah Agboka, Tobias Landmann, Elfatih M. Abdel-Rahman Jan 2026

Reinterpreting Stochastic Optimal Control Under Ecological Uncertainty: Inferring Decision Urgency From Vegetation Biomass Dynamics, Komi Mensah Agboka, Tobias Landmann, Elfatih M. Abdel-Rahman

All Peer-Reviewed Publications

Stochastic optimal control provides a rigorous framework for systems subject to uncertainty, yet its operational use in ecological crisis contexts remains limited by interpretability. We reinterpreted a stochastic control formulation in which selected parameters emerged as indicators of decision urgency rather than normative preferences. Vegetation biomass was modeled as a stochastic stock subject to nonlinear loss driven by feeding pressure (e.g., desert locust activity) and multiplicative noise, with uncertainty represented by a time-varying volatility term that integrated extreme rainfall anomalies and conflict-related disruption. Rather than prescribing an optimal policy, we inverted the closed-form solution of the control problem to infer …


Fumigant Toxicity Of Essential Oils From Chemotypes Of Curry Tree (Murraya Koenigii) Against Adult African Malaria Mosquito (Anopheles Gambiae Sensu Stricto), Clarence M. Mang’Era, Fathiya M. Khamis, Ahmed Hassanali, Paul O. Mireji Jan 2026

Fumigant Toxicity Of Essential Oils From Chemotypes Of Curry Tree (Murraya Koenigii) Against Adult African Malaria Mosquito (Anopheles Gambiae Sensu Stricto), Clarence M. Mang’Era, Fathiya M. Khamis, Ahmed Hassanali, Paul O. Mireji

All Peer-Reviewed Publications

The toxicity of fumigant formulations of essential oils (EOs) from curry tree (Murraya koenigii (L.) Spreng (Rutaceae)) against African malaria adult mosquito (Anopheles gambiae sensu stricto (Giles, 1902) (Diptera: Culicidae: Culicini)) was evaluated to identify most effective chemotype of the curry tree against the mosquitoes. Ninety-two compounds (91.78%–96.47% coverage) in the EO profiles were identified, among which EO isolated from curry tree chemotype from Kibwezi was most toxic. This chemotype had a median lethal dose (LD50) of 3.6 × 10−3 mg/cm3 (95% CI: 2.70–4.58) and a lethal time (Ti50) of 1.91 ± 0.086 h (p < 0.001). The equivalent LD50 of EOs of chemotypes from Mombasa, Makindu, and Malindi in Kenya was 4.9 × 10−3, 6.6 …


Land Suitability For Seasonal Crops: Limiting Factors And Sdg-Aligned Management Strategies, Rahmawaty Rahmawaty, Abdul Rauf, T Alief Aththorick, R Hamdani Harahap, Christine Pepah, Rohani Simbolon, Minhajul Abidin, Nawang Wulan, Anggiat Hosea O Siregar, Mohd Hasmad Ismail, Seca Gandaseca Jan 2026

Land Suitability For Seasonal Crops: Limiting Factors And Sdg-Aligned Management Strategies, Rahmawaty Rahmawaty, Abdul Rauf, T Alief Aththorick, R Hamdani Harahap, Christine Pepah, Rohani Simbolon, Minhajul Abidin, Nawang Wulan, Anggiat Hosea O Siregar, Mohd Hasmad Ismail, Seca Gandaseca

Baghdad Science Journal

A land evaluation study of Muara Batang Toru Sub-district is essential to determine its development prospects for seasonal crops. This study evaluates land suitability for six seasonal plants, including red chili, cucumber, shallot, tomato, eggplant, and bitter melon, in Muara Batang Toru Sub-district, South Tapanuli Regency. This study employs a survey method, integrating field observations and laboratory analysis with predetermined criteria based on a combination of internationally recognized standards and local conditions. Geographic information systems are used to map the actual and potential land suitability classes for vegetable crops. The findings indicate that most of the actual land suitability classes …


Assessment Of Carbon Capture Potential In Rubber Plantations Via Landsat 9 Imagery Analysis, Ade Fitria, Rahmawaty Rahmawaty, Razali Razali, Jamin Saputra, Seca Gandaseca Jan 2026

Assessment Of Carbon Capture Potential In Rubber Plantations Via Landsat 9 Imagery Analysis, Ade Fitria, Rahmawaty Rahmawaty, Razali Razali, Jamin Saputra, Seca Gandaseca

Baghdad Science Journal

Indonesia is a significant greenhouse gas (GHG) emitter, contributing 12.3% of carbon dioxide (CO2) of total emissions. Carbon dioxide (CO2), a major GHG, is increasing in the Earth’s atmosphere. The CO2 absorption can be increased through rubber plantations because rubber plants, such as forest plants, can process CO2 as a carbon source for photosynthesis. This research aims to analyze carbon uptake in relation to tree density, biomass of rubber vegetation, and soil organic carbon (SOC) content, as well as to map the distribution of carbon potential using remote sensing. This research was conducted in …


Simplified Function For Predicting Superconducting Critical Temperature, Pakin Tasee, Nattawut Natkunlaphat, Udomsilp Pinsook Jan 2026

Simplified Function For Predicting Superconducting Critical Temperature, Pakin Tasee, Nattawut Natkunlaphat, Udomsilp Pinsook

Journal of Metals, Materials and Minerals

Currently, there is intense competition to develop models that can accurately estimate the critical temperature across a wide range of superconductors, while striving for straightforward derivations and comprehensive predictions. In this work, we present an approach to determining the critical temperature based on the linearized Eliashberg gap equations employing the bandwidth model. To verify the accuracy of our model, we collect Eliashberg spectral functions from various independent studies, compute the necessary parameters, and solve the Eliashberg gap equations numerically to obtain the exact solutions, along with utilizing the modified Allen-Dynes equation. The findings suggest that both models are in good …


An Integrated Experimental–Numerical Approach For Characterizing Deformation Behavior Of High-Strength Steels, Weerapong Julsri, Apichat Sanrutsadakorn, Vitoon Uthaisangsuk Jan 2026

An Integrated Experimental–Numerical Approach For Characterizing Deformation Behavior Of High-Strength Steels, Weerapong Julsri, Apichat Sanrutsadakorn, Vitoon Uthaisangsuk

Journal of Metals, Materials and Minerals

This study aims to establish an integrated experimental–numerical framework for characterizing the deformation behavior of DP590 high-strength steel sheet. The framework combines experimental uniaxial tensile and Nakajima tests with finite element (FE) simulations to provide a comprehensive assessment of forming limits and fracture behavior. Forming limit curves (FLCs) and forming limit stress curves (FLSCs) were determined with the integrated approach and then validated numerically using the Hill’48 yield criterion together with both Swift and Voce hardening laws. Model calibration incorporated experimental data on directional mechanical properties to ensure that material anisotropy was accurately represented. The FE simulations demonstrated strong agreement …


No Exception For Ultra Vires Discrimination, Rev. James Deboer Jan 2026

No Exception For Ultra Vires Discrimination, Rev. James Deboer

American University Journal of Gender, Social Policy & the Law

The Ministerial Exception (“the Exception”) is an affirmative defense that religious institutions may use to obtain dismissal of discrimination claims brought by current and former ministerial employees.The Exception rests on the seemingly straightforward premise that churches and other religious institutions must be free to select and remove their own ministers without interference from secular laws.  It applies with equal force to any kind of discrimination; extends to harassment and retaliation; and is not confined to forms of alleged discrimination motivated by religious belief.

The Supreme Court has only addressed the Exception twice. First, in 2012, through Hosanna-Tabor Evangelical Lutheran Church …


The Ambiguity That Isn’T: Why Same-Sex Marriage Is Legal In American Samoa, Dante Cade Harootunian, Sammi Lawrence Jan 2026

The Ambiguity That Isn’T: Why Same-Sex Marriage Is Legal In American Samoa, Dante Cade Harootunian, Sammi Lawrence

American University Journal of Gender, Social Policy & the Law

After the U.S. Supreme Court ruled in Obergefell v. Hodges that prohibitions on same-sex marriage violate the equal protection guarantees of the U.S. Constitution, several government officials in American Samoa issued statements claiming that the decision had no effect in American Samoa, and, to date, no same-sex couples have

applied for a marriage license in the territory. This Article analyzes the Obergefell decision in light of other federal and territorial court decisions that determined the applicability of constitutional rights to U.S. territories and concludes that, despite the statements of local officials, the Obergefell decision applies in American Samoa, and the …