Digital Commons Network^™

The Implications Of Pulsifer V. United States For The Interpretation Of Criminal Statutes, Aparajita (Pj) Das

San Diego Law Review

All signs in Pulsifer point to considerable discretion for courts, all while operating within the confines of statutory text. For one, the opinion indicates that courts can override the text of a statute if the context so demands. The Court’s rejection of lenity also confirms this trend in two ways. It highlights the Court’s inconsistent approach when it comes to requiring the legislature to speak clearly. It also confirms that the threshold of ambiguity required to trigger lenity continues to be a high one, thus allowing judges to selectively apply the canon, even when a split in the Court demonstrates …

A Meta-Narrative Of Consumer Journeys In Access-Based Consumption: A Case Of Fashion Rentals, Swapnil Saravade, Mohammad Ali Zolfagharian, Reto Felix, Lorena Garcia Ramon, Jacob Almaguer, Hazel Husne Dadanlar

Marketing Faculty Publications

Purpose – The current research aims to identify a meta-narrative that depicts a big picture of the consumer journey with access-based consumption (ABC). Specifically, this research reveals the points of engagement and disengagement with ABC, as well as the transitions between them.

Design/methodology/approach – A qualitative research methodology is applied wherein online reviews and blogs pertaining to Rent the Runway (RTR), an access-based fashion company that enables consumers to rent designer dresses and accessories, are analyzed. Specifically, individual textual narratives of users’ experiences with RTR are analyzed, and a meta-narrative is identified that depicts an overarching story of the …

Law School News: Is It Legal For Trump To Send Troops Into U.S. Cities? 10-9-2025, Edward Fitzpatrick

Life of the Law School (1993- )

No abstract provided.

Rogue Prosecutor Panic, Michael L. Smith

The Scholar: St. Mary's Law Review on Race and Social Justice

Discussions of criminal law, enforcement, and reform are frequently messy and misleading. Anecdotes distract from systematic abuse, and perceptions of crime frequently win out over existing trends. This essay identifies Zack Smith and Charles Stimson’s book, Rogue Prosecutors: How Radical Soros Lawyers are Destroying America’s Communities, as an example of this shoddy discourse. Smith and Stimson’s claim that “Radical Soros Lawyers” are being mobilized to destructive ends crumbles under minimal scrutiny, and I identify several core defects throughout their narrative, including a failure to demonstrate a truly unified scheme of ideology and funding amongst the prosecutors they identify, baseless assumptions …

The History Behind The Enactment Of Public Law 115-126 And Whether Safesport Has Created A Safe Place For Competitive Athletes, Ashtyn L. Stevens

The Scholar: St. Mary's Law Review on Race and Social Justice

The Summer Olympic Games unite the world in celebrating athletic excellence, yet behind the global spectacle lies a troubling reality: the pervasive issue of sexual abuse within competitive sports. The high-profile case of former USA Gymnastics doctor Larry Nassar, who sexually assaulted hundreds of athletes over decades, including Olympic champions Simone Biles and Gabby Douglas, exposed systemic failures in reporting and accountability. This comment analyzes the legal and institutional response to such abuse, focusing on the enactment of Public Law 115-126 in 2018. Designed to protect minors and amateur athletes, the law mandates timely reporting of sexual abuse to law …

Tinkering With The Machinery Of Death: Execution Through Nitrogen Hypoxia, Emiliano Villarreal

The Scholar: St. Mary's Law Review on Race and Social Justice

The modern era of the death penalty in the United States began in 1976 when the Supreme Court reinstituted the death penalty just four years after having found it to be unconstitutional. Since then, various states, as well as the federal government, have experimented with different methods of execution to find the most “humane” way of carrying out an execution. In 2018, Alabama legalized the use of nitrogen hypoxia as a method of execution, and in 2024, became the first state to execute a person with this new, previously untested method. However, the use of nitrogen hypoxia has been the …

Scrolling Into Risk: Navigating The Legal Landscape Of Social Media Influencers And Securities Promotion Under Section 12(A)(2) Of The Securities Act, Nathan T. Nguyen

San Diego Law Review

This Comment argues that the Supreme Court should clarify the definition of a “person who offers or sells” under Section 12(a)(2) of the Securities Act to resolve the disagreement among the circuit courts. Part II outlines the legal context of the Securities Act, examining efforts to safeguard investors from the illicit sale of unregistered securities. Part III delves into disagreements among circuit courts regarding the definition of a “seller” in today’s social media landscape. Part IV asserts that classifying social media influencers as sellers aligns with the Securities Act’s legislative intent and statutory language. Part V contends that the Ninth …

The Cowl - V. 89 N. 4 - October 9, 2025

The Cowl

The Cowl - student newspaper of Providence College. Vol. 89 No. 4 - October 9, 2025. 16 pages.

History Of Art, Architecture And Design Subject Benchmarking Statements: Draft Version For Consultation, Péter Bokody, Paul Alexander Stewart, Nadira Begum, Christina Bradstreet, Derrik Ferney, Ferren Gipson, Kate Grandjouan, Alison Hamilton-Pryde, Sophie Hatchwell, Christie Johnson, Lenia Kouneni, Joseph Mcbrinn, Lynda Nead, Samuel Raybone, Jennifer Walden

School of Law, Humanities and Social Sciences

No abstract provided.

Strategies To Prevent Employee Turnover And Revenue Losses Resulting From Workplace Bullying, Sylvester Doby Jr

Walden Dissertations and Doctoral Studies

Workplace bullying is a serious issue that can lead to high employee turnover and significant revenue loss. To maintain a healthy work environment and support their employees, business leaders need to develop and implement effective strategies to prevent bullying. Grounded in the transformational leadership theory, the purpose of this qualitative pragmatic inquiry study was to identify and explore the successful strategies that U.S. business leaders used to prevent workplace bullying. Six business leaders who have successfully implemented strategies to combat workplace bullying were purposively recruited and interviewed using semistructured interviews. The reflexive six-step thematic analysis of the interview transcripts and …

Special Education Teachers’ Perceptions Of Teaching Effectiveness When Working With Students With Emotional And Behavioral Disorders, Ernest J. Fruge

Walden Dissertations and Doctoral Studies

This qualitative study examined how special education teachers perceived their teaching effectiveness in supporting students identified with emotional and behavioral disorders (EBD). The study addressed a gap in the literature by examining the factors that influence special educators’ sense of self-efficacy when working with this population. Bandura’s theory of self-efficacy served as the conceptual framework. A generic qualitative research design was employed, and data were collected through semi-structured interviews with eight participants from two central Texas school districts. Braun and Clarke’s thematic analysis guided the coding and interpretation process, supported by MAXQDA software. Analysis of the data revealed seven key …

Sers And Seira Detection Of Polycyclic Aromatic Hydrocarbons And Their Derivatives In Murine Tissues: Bioaccumulation And Clearance, Oara Neumann, Andrés B Sánchez-Alvarado, Weiwu Jiang, Guo Dong Zhou, Sachin B Jorveka, Parmeet Dhindsa, Nagireddy Putluri, Peter Nordlander, Melissa A Suter, Bhagavatula Moorthy, Naomi J Halas

Faculty, Staff and Students Publications

The toxicological effects of polycyclic aromatic hydrocarbons (PAHs) and polycyclic aromatic compounds (PACs) have attracted considerable research interest due to their known bioaccumulation. However, time-resolved and longitudinal studies that examine in vivo bioaccumulation and clearance remain limited. Here we use Surface-Enhanced Raman Scattering (SERS) and Surface-Enhanced Infrared Absorption (SEIRA) spectroscopies to detect and track the presence of two PAHs: pyrene, benzo[a]pyrene, and one PAC: 5,12-naphthacenequinone, in murine organ tissues. Mice were exposed to a three-component mixture of these three chemicals, then their organs were collected at 24-, 48-, and 72- hours post-exposure. The accumulation of each of these chemicals in …

Roller Rebels Win Preliminary Injunction Against Nassau County’S Anti-Trans Sports Law, Arthur S. Leonard

Other Publications

No abstract provided.

Salmon Rushdie’S Frontier Pedagogy: Notes On Two Episodes In “Step Across This Line", Narayana Chandran Kizhakkethil

Asian American Literature: Discourses & Pedagogies

In the Indian multilingual classrooms teachers often discover certain details about the political semantics of the English texts they teach. When that happens, the language means much more to non-English readers who happily realize that English grants them a little more freedom to convey meanings to them than it does a monolingual readership. My example here is Salman Rushdie’s Tanner Lectures in Human Values called “Step Across This Line.” While his immediate context is the 9/11 tragedy and the politically prudent ways the US might cope with its aftermath, he returns time and again to those who brave borders, face …

Transpacific Rhizomatic Migration In Kyoung H. Park’S Mina: Settler Desire And Identity Formation In Korean-Latin American Literature In The U.S., Chase Kim

Asian American Literature: Discourses & Pedagogies

The Korean diaspora to the United States is a phenomenon that has long been analyzed for its sociocultural, political, and economic implications. However, generally ignored by scholarship of frameworks such as the transpacific is Korean-Latin American remigration to the United States. Korean migration to Latin America and this group’s subsequent migration to the US was motivated largely by economic factors such as the availability of Latin American agricultural labor in the mid-1960s and the growth of Korean-American professional communities during the 1980s. Situating this migration in a transpacific framework improves our understanding of settler colonial desire and identity formation. I …

Ellen White And The Shut Door, Merlin D. Burt

Ellen White and Current Issues Symposium

No abstract provided.

Who Owns The Truth? Another Look At The Plagiarism Debate, Jerry Moon

Ellen White and Current Issues Symposium

No abstract provided.

Ellen G. White As Messenger Of The Lord: What Else Could Dr. Smithurst Say?, Denis Fortin

Ellen White and Current Issues Symposium

No abstract provided.

From Ambiguity To Accountability: The Case For A Legal Definition Of Antisemitism In Academia, Andrea J. Martin

Pepperdine Law Review

Following the October 7, 2023, Hamas attacks on Israel, U.S. college campuses experienced a sharp rise in antisemitic incidents, driven by an antizionism movement aimed at demonizing and delegitimizing the Jewish state and its supporters. A congressional investigation found that antisemitism persisted at prominent universities because administrators repeatedly failed to denounce antizionist conduct that functions as a vehicle for harassment of Jewish students and neglected to enforce their own nondiscrimination policies. The congressional committee, as well as several university antisemitism task forces, identified antizionism as a primary driver of campus antisemitism and strongly recommended that university leaders recognize and address …

2022 - Appalachian Student Research Forum Program Booklet, Appalachian Student Research Forum, East Tennessee State University

Appalachian Student Research Forum

No abstract provided.

Government Communication Strategies And Citizen Participation: A Thematic Review, Ojonugwa Emmanuel, Andrew I. E. Ewoh

Journal of Public Management & Social Policy

none

Co-Creation As A Trust-Building Tool: An Application To Ghanaian Local Governments, Richard K. Nkrumah

Journal of Public Management & Social Policy

none

Devolution And Administrative Burden In Tanf: An Assessment Of Welfare Rules, Rhucha P. Samudra

Journal of Public Management & Social Policy

none

Parents’ Dispositions On Social Emotional Learning And Their Policy Imperatives: The Relevance Of Context/Locality, Nicholas O. Alozie, Megan Armstrong, Kathy Thomas

Journal of Public Management & Social Policy

none

Fcc V Consumers' Research: The Non-Delegation Doctrine And The Power To Tax, Bernard W. Bell

ConLawNOW

This Essay examines the 2025 Supreme Court case of Federal Communications Commission v. Consumers’ Research which seemingly involved an esoteric question of telecommunications law, but instead provided the Court with an opportunity some Justices have long sought to prune a foundational doctrine of the administrative state—the nondelegation doctrine. The nondelegation doctrine has garnered considerable judicial and academic attention, especially in comparison to the paucity of cases invalidating federal statutes on such grounds. The Court could have abandoned the forgiving “intelligible principle” test applied to congressional delegations for almost one hundred years, or, more cautiously, could have crafted a special rule …

From A Shtetl House To An Urban Apartment: The Soviet Jewish Home Negotiated, Transformed, And Reimagined, Anna Kushkova

Jewish Folklore and Ethnology

This essay argues that despite the powerful forces of assimilation, official campaigns against Jewish religion/languages, and grassroots/state antisemitism, the “Jewish home” did not disappear, as is sometimes assumed, but continued to present a site of Jewish ethnic production and transmission, creativity, and resistance during the Soviet regime. In the Soviet Union, especially in the postwar period, Jewish ethnic culture was forced to leave the public sphere, where it became unwelcome and even dangerous, and withdrew into the less visible space of domestic interiors. The degree of Jewish public presence varied geographically: the situation was generally better in the Baltic Republics, …

Poetic Playing Fields: The Israel Folktale Archives As A Social Arena, Dina Stein

Jewish Folklore and Ethnology

The literary biography of Yaakov Lasri, from his time as a frustrated transcriber of stories he heard from others until the publication of his last book, in which he molded stories with artistic freedom, is a voyage through the literary polysystem of Israel of his day and the literary and political fields available to him. His disappointment in the real and symbolic capital that the Israeli Folktale Archives (IFA) offered drove him to seek alternative literary fields at play within the political discourse that blossomed in the late 1960s. The Mizrachi discourse in which social-political marginality started to challenge the …

Editorial: Jewish Cultural Scholarship And Scholars—And Their Institutions—Under Duress, Simon J. Bronner, Amy K. Milligan, Tsafi Sebba-Elran

Jewish Folklore and Ethnology

The editors of Jewish Folklore and Ethnology (JFE) express concern about intimidation and estrangement of Israeli and Jewish professors in the international academic community after the surprise attack by Hamas in southern Israel on October 7, 2023. The editors point out that these types of hurtful antisemitic incidents against Israeli and Jewish academics preceded the attack, and they call on their colleagues and administrators to voice their outrage at the harassment, boycotts, and violence against Israeli and Jewish academics in addition to the suppression of Jewish studies, and their adverse effects on scholarship as well as Jewish students and their …

Asynchronous Reliable Transmission Protocol For Application-To-Application Communication, Ashish Kumar Khatri Mr., Preet Nepolean Dabre

Defensive Publications Series

Techniques are disclosed for providing asynchronous reliable transmission (ART) protocol for Application-to-Application messages. A communication protocol is designed to support communication between two devices asynchronously over channels that have limitations to facilitate asynchronous communication and have limited bandwidth. The ART protocol solves communication challenges that arise when transmitting data over channels with such limitations. The ART protocol has the provision to expand for future use cases such as encryption. Further, the ART Protocol provides mechanisms for data packet fragmentation, allowing larger packets to be transmitted over channels with limited bandwidth.

First Confirmed Nestings Of Red-Necked Grebe In York Region, Ontario, Roy B.H. Smith

Ontario Birds

On 1 June 2019, the first recorded breeding by Red-necked Grebe (Podiceps grisgena) in York Region, Ontario, was established when a nest with one egg was found at the Moody Drive storm - water pond in the City of Vaughan. Although this nest was unsuccessful, a pair returned in 2020 and made another six unsuccessful nesting attempts. Also in 2020, another pair was found at the New Enterprise stormwater pond in Vaughan; they too made multiple unsuccessful nesting attempts. Both sites were reoccupied in 2021, and this time the pair at Moody Drive produced one young. In all three years, …