Digital Commons Network^™

Fisc Opinion Digest 2022 - 2025, Alejandra Gutierrez

Joint PIJIP/TLS Research Paper Series

This digest summarizes selected opinions of the Foreign Intelligence Surveillance Court (FISC) and the Foreign Intelligence Surveillance Court of Review (FISC-R) regarding Section 702 of the Foreign Intelligence Surveillance Act (FISA). It covers the FISC’s annual review of intelligence agencies’ Section 702 certifications and the FISC and FISC-R’s opinions related to the statutory definition of Electronic Communications Service Providers (ECSPs). Publicly available opinions are posted on the FISC website, and further resources are available through the Intel.gov IC on the Record Database, a website of the Office of the Director of National Intelligence (DNI).

Originalism, Methodolatry, And The Only Guarantee Of Wisconsin, Chad M. Oldfather

Faculty Publications

Originalism, loosely defined, commands a majority on the Supreme Court and dominates legal discourse in a way that would have been unrecognizable a generation ago. Yet its actual constraining effect on judicial behavior remains doubtful. This Article offers two contributions to the long-running debate. First, it identifies a pathology in both originalist scholarship and practice that it terms "methodolatry"—a preoccupation with methodological refinement that threatens to elevate method over the purposes interpretation is meant to serve. Second, and more importantly, it argues that debates over interpretive method, however vigorous, fail to address the core problem. Text and history offer relatively …

Blurring The Lines: A Reflection On The ‘Relaxation’ Of The Organization Requirement Of Article 7(2)(A) Of The Rome Statute Since The Situation In Kenya Decisions, Leonardo Helman

Human Rights Brief

International criminal liability for Crimes Against Humanity (CAH) was born during the International Military Tribunal at Nuremberg to address the atrocities committed by the Nazi regime against civilians throughout the Third Reich. Since the post-World War II tribunals at Nuremberg and Tokyo, the definition of CAH has undergone several evolutionary stages to better reflect the circumstances in which atrocities have been committed. The ad hoc tribunals for Yugoslavia and Rwanda substantially adjusted the definition of CAH to fit the context of these conflicts. However, this evolution of CAH in the ad hoc cases did not yield a definition applicable in …

Behind The Headlines: Media Control In Bangladesh Post July Revolution, Nahida Islam

Human Rights Brief

“I have always written for truth, for peo­ple, and for my country . . . [b]ut today, when I look at my own life, I feel that living by writing the truth is not easy.” The words from Bibhuran­jan Sarkar’s suicide note echo into the minds of all Bangladeshi journalists as fears of retaliation took precedent over the work of informing the public. Journalism in South Asia has always been a toxic balance between writing what is fair versus writing what people in power want you to write. In Bangladesh, the autocracy led by former Prime Minister Sheikh Hasina created …

Rights On Paper, Violations In Practice: Israel, The U.S., And The Failure To Enforce Judicial Pro¬Tections And International Obligations In Cases Of Arbitrary Detentions, Anjali Narayanan

Human Rights Brief

Muhammad Srur, a 34-year-old father, en­dured small cells, restricted movement, minimal family visits, and limited access to legal counsel when detained by Israel. He was beaten during arrest and interrogation, and the food, medical care, and living conditions fell below international standards. Half a world away, Abu Zubaydah remains in extreme isolation at Guantánamo Bay, following secret CIA detention where he faced prolonged confinement, sleep deprivation, stress positions, and other forms of torture. These men will never meet. Yet, their situations reflect the same legal reality: both have been placed into categories designed to fall outside the full protections of …

The Venice Commission’S Impact Regarding The Fight With Democratic Backsliding And Rule Of Law Recovery: Reflections Of The Polish Example, Adam Bodnar

Human Rights Brief

The Article examines the role of the Venice Commission — the expert body affiliated with the Council of Europe — in addressing democratic backsliding and supporting the restoration of the rule of law, using Poland as a case study. It places the Venice Commission within the broader system of European constitutional governance and discusses its role when Poland moved, after 2015, towards the system of illiberal democracy. Opinions of the Venice Commission were significant in the evaluation of reforms affecting the Polish Constitutional Court, judicial independence, the prosecution service, and surveillance powers. They had impact on policies of the European …

Beyond Borders: Transnational Repression As A System Of Authoritarian Control In Russia, Kazakhstan, And Kyrgyzstan, Jasmine D. Cameron

Human Rights Brief

This Article examines transnational repression, state-sponsored persecution of citizens, human rights defenders, journalists, members of diaspora, and critical voices located outside physical borders, as a systemic tool of political control employed by Russia, Kazakhstan, and Kyrgyzstan. Based on analysis of legislation, published reports, UN Special Rapporteur findings, and case files, this Article provides three case studies that demonstrate different stages of an escalating trend towards transnational repression systems. From Kyrgyzstan, where the government has started to develop and implement harmful practices to persecute its citizens abroad, to a more established system in Kazakhstan, where numerous incidents of transnational repression showed …

B.T. And B.K.Cs. V. Hungary: Separating Roma Children From Their Mothers Before Births, Sara Apostol

Human Rights Brief

In June of 2025, the European Court of Human Rights (ECtHR) ruled in favor of a Roma mother, B.T., and her son after bringing a lawsuit against the Hungarian government for wrongfully violating their right to family life. The Hungarian government ordered the placement of B.T.’s unborn child into State care based on insufficient and dubious evidence used to justify such state action. This case focused on the prejudiced system that places Roma children into the State’s guardianship immediately after birth without evidence of imminent harm or other valid justification. Rather, it is based on the child’s ethnic and socio-economic …

How The Sui Generis Principle Has Been Historically Abused In International Law: From The British To The Israelis, Ahmad Hamdan

Human Rights Brief

I. Introduction

For over a century, powerful actors have used a single Latin phrase, sui generis, as a shield to evade accountability under international law. Meaning “of its own kind,” this theory dictates that a situation is so unique that ordinary rules should not apply. In international law, sui generis typically refers to situations or entities that cannot easily be categorized under existing legal frameworks or conventions. Its use indicates that there is no directly applicable precedent and that, as a result, no legal principles apply; instead, the situation itself will set the precedent. While some researchers argue that …

Stability And Accountability In Nagorno-Karabakh And The Armenia-Azerbaijan Conflict, Callum Heath

Human Rights Brief

I. Introduction

On August 8, 2025, President Ilham Aliyev of Azerbaijan and Prime Minister Nikol Pashinyan of Armenia were hosted at the White House by U.S. President Donald Trump to announce the Agreement on Establishment of Peace and Inter-State Relations (the Agreement) in a Joint Declaration. The Agreement sets out to end the decades-long conflict between Azerbaijan and Armenia over the Armenian ethnic enclave of Nagorno-Karabakh within Azerbaijan, and the Azerbaijani exclave of Nakhchivan, which is separated from the rest of Azerbaijan by Armenia. While the White House hails the Agreement as a “historic peace deal,” the reality is more …

“Durable Solutions” Revisited: Italy’S Train-To-Hire Pathway Under The Cutro Decree As Alternative Refugee Protection, Tim Streit

Human Rights Brief

I. Introduction

If the average person were asked to imagine a refugee, they might conjure the image of a migrant fleeing war or persecution, showing up at the border of a new country with a few belongings in hand, and asking not to be sent back to the dangerous place from which they came. In fact, it is not only the hypothetical “average person” who pictures this scenario. The international refugee protection system, developed after World War II through the 1951 Convention relating to the Status of Refugees (Refugee Convention) and its 1967 Protocol Relating to the Status of Refugees …

Toddlers, Investors, And Tax Policy, Lauren Shores Pelikan

Faculty Publications

There is a continuing childcare crisis that worsens every year. Congress has historically used tax incentives aimed at parents and employers to try to alleviate the lack of affordable childcare. However, with private equity's increasing investment in the childcare sector, this Article advocates for an entirely new approach: Congress should encourage more people to work in the childcare sector by enacting a tax benefit for the individual childcare service provider.

Childcare is a broken market. The labor-intensive nature of the industry results in razor thin profit margins, and wages remain low due to entrenched racial and gender norms. There is …

The Bankruptcy Judge And The Generalist Tradition, Alexander Gouzoules

Faculty Publications

The prevailing academic consensus is that bankruptcy judges are specialists presiding over specialized courts. This Article contends that this description is incomplete and, in some respects, inaccurate. Drawing on scholarly models of judicial specialization and historical surveys of the field, this Article contends that bankruptcy judges reflect a hybrid design choice: procedural specialization combined with substantive generalism. This model delivers many of the observed benefits of judicial specialization (including efficiency and technical competence) while preserving the cross-pollination of ideas and other benefits associated with the generalist tradition of American judging.

This Article also reflects on contemporary developments—most notably the rise …

Anticancer Efficacy Of Methyl-Cantharidimide (Mca) In Liver Cancer, Yidong Li

Theses and Dissertations

Cancer is still one of the major public health challenges worldwide to the present day. Multi-drug resistance (MDR) that occurs in cancer chemotherapies is a non-negligible cause of cancer treatment failure and tumor recurrence. Overexpression of ATP-binding cassette (ABC) transporters is one of the most frequent mechanisms of MDR occurrence. Therefore, the establishment of a chemotherapy agent whose anticancer efficacy would not be affected by the overexpression of ABC transporters is in demand. Methyl-cantharidimide (MCA), a cantharidin (CTD) analog, has been approved in China for clinical liver cancer treatment. This study revealed that MCA was efficacious in the ABCB1-, ABCG2-mediated …

The Impact Of Social Media On The Occurrence And Prevalence Of Stress And Anxiety On College Students, Pushpita Paul

Theses and Dissertations

The purpose of this study was to examine the ways that social media affects stress and anxiety levels within college students. A self-administered, anonymous survey was used to assess college students’ perceptions of social media’s impact on mental health. The 14- item survey included questions on social media use, stress, anxiety, social interaction, and demographics. Data were collected both online and in person at St. John’s University. Online surveys were shared through student groups using Google Forms. In-person surveys were conducted at campus locations such as the cafeteria, student lounge, library, and events. Each survey took about 5–10 minutes to …

Deconstructing Shifting Narratives: Critical Discourse Analysis Of Terminology Trends In Unfpa’S State Of World Population Reports (1978-2024), Naqib A. Noory

Theses and Dissertations

Rooted in both scholarly inquiry and lived experience in global development, this study explored how language shapes power, inclusion, and representation. It analyzed the evolution of population and development discourse in UNFPA’s State of World Population reports (1978–2024) using Fairclough’s Level 1 Critical Discourse Analysis framework. Giddens’ Structuration Theory provided a broader lens linking linguistic change to the interaction between institutional structures and human agency. A theory-based coding framework, drawing on Malthusian, Senian, Spivakian, and MDG/SDG paradigms, guided the analysis of evolving discourse. Findings revealed a layered narrative: earlier scarcity framings persisted beneath newer development language; rights and empowerment rhetoric …

Peeking Behind The Veil Of The District-Level Literacy Leader: Does Research Match Reality?, Kristel R. Collins

Theses and Dissertations

The purpose of this study was to investigate district-level literacy leadership (DLLL), focusing on the leadership behaviors enacted by district-level literacy leaders, their alignment with the International Literacy Association Standards for the Preparation of Literacy Professionals (2017), and their use of systems thinking principles to influence literacy improvement in K–12 settings. The study addressed a critical gap in the literature regarding how DLLLs function at the district level to mediate between policy and classroom practice. Participants included six DLLLs from Central Texas public school districts. All participants held advanced degrees, had at least two years of district-level literacy leadership experience, …

Exploring The Leadership Qualities Of Lgbtq+ School Administrators Through The Prism Of The Developmental Model Of The Closet, Andrew Mcintosh

Theses and Dissertations

This qualitative study explored how LGBTQ+ school administrators perceive the influence of their lived experiences on their leadership qualities. Additionally, this study examined post-closet growth, closet adaptations, and how legal protections influence LGBTQ+ school administrators. A narrative methodology was employed to shed light on the lived experiences of participants. A mix of purposive, convenience, and snowball sampling was used for this study. The researcher recruited school administrators from public school districts and private schools located in the Northeastern United States. School administrators include positions such as assistant principal, principal, assistant superintendent, director, superintendent, and head of school. Eight participants took …

Investigating The Practicality Of Parent-Implemented Intervention In Literacy For Children With Autism Residing In Under-Resourced Communities, Chasidy P. Kennedy

Theses and Dissertations

The opportunity to learn how to read is a human right that should be available to all students. Developing strong reading skills significantly impacts a student’s quality of life, societal integration, and establishes the foundation for future academic success. Unfortunately, this belief is not always equally prioritized when it comes to educating students with developmental delays, such as autism spectrum disorder (ASD). Students with ASD often face unfair assumptions about their abilities, leading to delays in exposure to literacy instruction. Additionally, students with ASD from under-resourced communities face increased challenges, as access to timely diagnosis, high-quality educational facilities, and supportive …

A Case Study On Implementing Culturally Responsive Sustaining Education: Tesol Teachers’ Perspectives On Supporting Caribbean Immigrant Ell Students, Barbara Delaleu

Theses and Dissertations

The purpose of this qualitative case study was to explore how Teaching English to Speakers of Other Languages (TESOL) teachers implemented Culturally Responsive and Sustaining Education (CRSE) practices to support Caribbean immigrant English Language Learners (ELLs) in suburban schools. Grounded in Ogbu’s cultural ecological theory and the CRSE framework, the study examined teachers’ beliefs, instructional practices, and professional experiences to understand how culturally sustaining pedagogy (CSP) influenced student engagement and academic growth. Eight middle school TESOL teachers who worked with Caribbean immigrant ELLs—speakers of Haitian Creole, Spanish, and English-based Creoles participated in the study. Data were collected through semi-structured interviews, …

An Exploration Of The Perceptions Of Black Women Leading Interscholastic Sports Programs, Leslie Zeelika Pieters-Klatsky

Theses and Dissertations

The purpose of the study was to examine the perceptions of Black women leading interscholastic sports programs. Prior research examined the underrepresentation of women in sports leadership, but no study has examined prejudice toward the Black woman in an interscholastic sports leadership role. Data were collected through in-depth semi-structured interviews with Black women leading interscholastic athletics, using Kimberlé Crenshaw's intersectionality as a theoretical framework. This study sought to give voice to a select group of women who perceived being barred entry into the white-male-dominated field of interscholastic sports leadership by the Good Old Boys’ Network and the Good Old Girls’ …

Reading Between The Lines: Exploring How Technical High School Teachers Navigate Race And Neurodiversity Through Literacy Practices, Genesis A. Ryant

Theses and Dissertations

This qualitative study employed a hybrid hermeneutic phenomenological design to explore how technical high school teachers experienced and interpreted literacy instruction for Black and Brown neurodivergent students. Grounded in Critical Race Theory (CRT) and Disability Critical Race Theory (DisCrit), the research examined how educators’ perceptions, instructional practices, and collaborative relationships shaped access, equity, and empowerment in career and technical education contexts. Data was collected from seven academic and trade teachers through semi-structured interviews, focus groups, lesson artifacts, and reflective journals. Analysis followed Peoples’ (2020) hermeneutic explication process and Saldaña’s (2021) multi-cycle coding methods, integrating in vivo, process, and axial coding …

Police Supervisor Selection Process And The Need For Uniformity In Practices To Improve Police Leadership In The Usa, Catrina M. Rhatigan

Theses and Dissertations

Effective police leadership is crucial to sustaining the culture shift in law enforcement. Leaders need to lead, and how the executive staff assess their leadership capabilities will determine whether they are up to the task. Police executives need to determine first what their motives are: to fill open supervisory spots? Promote the best leaders? This study and the results highlight the need to focus on the latter, identify the leadership qualities that best fit your department's needs, and work from there. A lack of oversight and inconsistent standards for police supervisors leads to poor policing and inadequate responses to significant …

The Latent Lens: Exploring Hetereogeneity In The Use Of Physical Restraints Via Latent Class Analysis And The Lens Model, Andrew Miele

Theses and Dissertations

Research on the use of physical restraints has revealed high rates of heterogeneity between clinical settings and an array of potential risk factors at both the patient and provider level. This is most evident in general medical hospitals, where patient populations are more heterogenous than other settings and physicians often can rely only on observable characteristics of patients to assess safety risks. More recent work has shown that coherent subgroups of restrained patients can be derived from demographic and clinical indicators. Identification of coherent patient subgroups may aid in understanding both the heterogeneity of the restrained patient population and differences …

Emotional Valence In Sustainable Fashion Advertising And The Cognitive And Affective Drivers Of Consumer Response As Determinants Of Digital Engagement Behavior, Cassidy Jane Cisz

Theses and Dissertations

The dominance of the linear value chain and its perpetuation of overconsumption create persistent barriers to sustainable fashion brands in their effort to articulate a value proposition that justifies the price premium associated with ethical and sustainable production. To address this challenge and remain competitive within a marketplace dominated by low-cost fast fashion, these brands must differentiate through appeals that clearly reflect their values, mission, and climate commitments. While advertisements for sustainable goods use a broad set of persuasive strategies, this study evaluates two dominant emotional appeals, Positive Environmental Appeals (PEA) and Negative Environmental Appeals (NEA), both of which are …

Reading Comprehension For The English As A Second Language Learner: Oral Or Silent Reading Which Method Of Instruction Is More Effective?, Rosanne Ravo-Vernon

Theses and Dissertations

Educators have seen and will continue to see an influx of students in the classrooms who require English as a second language (ESL) instruction. The goal of this research will provide support for educators and administrators in preparing curriculum that focuses on the needs of these students. In pursuit of this aim, the researcher of this study sought to identify which method of reading instruction best suits English language learning (ELL) in the classroom. The research would identify components of both oral round robin and silent reading activities and then reading comprehension activities completed over the course of a two- …

Violence, Alcoholism, And Marriage In Nineteenth Century New York, Gina Rossetti

Theses and Dissertations

There is a wealth of information regarding the various facets of nineteenth century American history. However, the topic of uxoricide, husband-perpetrated wife murder, has not been the focus of many American historians. Women, particularly in middle- and working-class families, tackled a variety of challenges as American society was enduring many social and cultural changes. Every day women have been often kept in the background of previous historical narratives and were rarely the focus of previous literature. This dissertation places ordinary women as the focal point by examining the questions of how changes in American society, regarding alcohol consumption and views …

Disability And Demographic Influences On Advanced Placement Calculus Performance: A Quantitative Analysis, Edward J. Storck

Theses and Dissertations

This quantitative study examined equity in Advanced Placement (AP) Calculus outcomes for students with Individualized Education Programs (IEPs) in New York State. Using statewide data from 16,457 AP Calculus AB and BC exam takers in 2023, the study investigated whether disability status, race/ethnicity, economic status, and English language proficiency predicted performance and the likelihood of passing. Findings revealed that disability status was not a statistically or practically significant predictor of AP Calculus outcomes; students with IEPs performed comparably to peers without IEPs once enrolled. No significant interaction effects were found between disability status and other demographic variables, suggesting that students …

Novel Mechanistic Divergence Of The Hsp70–Hsp110 Chaperone System In Fungi And Humans, Justin M. Kidd, Ayil Perrott, Cancan Sun, Anusri Arun Prasath, Spoorti Kalashetti, Sky Evans, Vadim Barnakov

Physiology and Biophysics Publications and Presentations

Heat shock proteins (HSPs) are conserved, ubiquitous molecular chaperones that play various roles in preserving proteostasis, particularly in response to cellular stressors (e.g., heat, oxidation). In addition, their dysregulation is linked to various diseases, including neurodegeneration, cancer, and fungal infections. HSPs are generally grouped by molecular weight into families with related functions. Members of the 70-kDa family (Hsp70s) are central, energy-driven chaperones that bind and release clients in a cyclical manner dependent on ATP hydrolysis, facilitated by multiple co-chaperones such as nucleotide exchange factors (NEFs). In addition to solubilizing protein aggregates, members of the 110-kDa family (Hsp110s) constitute the primary …

An Examination Of Ethics When Using Chatgpt, Blake V. Ailes

CCAC Theses and Dissertations

With the general population’s recent and dramatic increase in the frequency of ChatGPT and other similar Artificial Intelligence Generated Content (AIGC) usage throughout various industries, gray areas are becoming more prominent regarding whether ChatGPT is considered to be ethical or unethical in certain situations. Examples of unethical use of ChatGPT include plagiarism, the use of inaccurate information in drawing conclusions, and the creation of malicious code that negatively impacts various companies. Not all of these ethical concerns are necessarily the fault of the user or the AIGC. To date, peer-reviewed research on the ethical usage of ChatGPT is limited, primarily …