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West Virginia V. Epa: Maybe A Big Deal, But Maybe Not, Michael Lewyn

St. John's Law Review

(Excerpt)

In West Virginia v. EPA, the Supreme Court held that the Environmental Protection Agency (“EPA”) lacked statutory authority to enact the Clean Power Plan, an EPA rule that encouraged coal-fired power plants to use non-coal sources of energy. The Court’s decision relied on the “major questions doctrine.” Under this doctrine, even if an unclear statute does not directly prohibit an administrative agency’s action, courts will reject an agency’s action when it is “asserting highly consequential power beyond what Congress could reasonably be understood to have granted.” Because the major questions doctrine is itself unclear, a variety of commentators suggested …

A More Modest Major Questions Doctrine Rooted In The Appointments Clause, Yonatan Gelblum

St. John's Law Review

(Excerpt)

In this Essay, I explore how this constitutional mandate might guide courts adjudicating disputes that arise when agencies interpret ambiguous statutes in a manner granting them powers beyond those expressly vested by Congress. In Part I, I explain when such agency assertions of authority may implicate Appointments Clause limits on office creation. I also demonstrate how the test of Shoemaker v. United States, which assesses whether expanding an officer’s authority creates a new office for Appointments Clause purposes by adding duties not “germane” to existing duties, provides a standard for judicial review of such claims. Agency claims to …

“Major Questions” Malarkey: An Arbitrary And Capricious New Doctrine For Vetoing Controversial Agency Rules, Lars Noah

St. John's Law Review

(Excerpt)

In 2022, after years of hinting at the idea, the United States Supreme Court officially adopted the “major questions” doctrine in West Virginia v. EPA. Commentators have already spilled plenty of ink trying to make sense of what this might portend, but so far seemingly everyone has accepted at face value the Court’s framing of the issue that it confronted in that case. This essay offers a slightly different perspective on the decision and suggests that closer attention to the precise nature of the question posed therein might reveal a distinctive flaw at the heart of the majority’s newfangled …

Climate Change, Democracy, And The Major Questions Doctrine, Joshua Ulan Galperin

St. John's Law Review

(Excerpt)

This brief Essay progresses in four parts. I will first argue that climate change is impacting the Court’s decisionmaking. Next, I will show that the significance of climate change as a modern political issue has caused the Court to downplay the statutory arrangement Congress created in the Clean Air Act. Third, I will suggest that the Court is not genuinely failing to appreciate the design of the Clean Air Act. Instead, the Court is aware of that design and feels the design goes beyond a constitutionally acceptable delegation of legislative power. Confronting the Nondelegation Doctrine head-on, however, would force …

Black Hole Of Administrative Law: The Threat Of An Ever-Expanding Major Questions Doctrine To The Judiciary, Fred B. Jacob

St. John's Law Review

(Excerpt)

Below, this essay explores how an aggressive major questions doctrine could extend its reach to judicial interpretation and the implications of doing so. Indeed, had the Court applied the major questions doctrine to its own judicial holdings in seminal cases such as Bostock v. Clayton County or Allen v. Milligan, it would have flunked. This is also true for West Virginia’s creation of the doctrine itself, which claimed newfound authority to transform administrative law despite Congress’s significant legislative attention to agency rulemaking.

Expansion of the major questions doctrine to cases arising in the courts’ original jurisdiction would …

Perspectives On West Virginia V. Epa, St. John’S Law Review Editorial Board

St. John's Law Review

No abstract provided.

Officers Of Administration And Faculty

St. John's Law Review

No abstract provided.

Volume 98, 2024, Number 3

St. John's Law Review

No abstract provided.

Table Of Contents

St. John's Law Review

No abstract provided.

Khartoum, Sheila Nayar

Journal of Religion & Film

This is a film review of Khartoum (2025), directed by Anas Saeed, Rawia Alhag, Ibrahim Snoopy, Timeea M. Ahmed, and Phil Cox.

Endless Cookie, Sheila Nayar

Journal of Religion & Film

This is a film review of Endless Cookie (2025), directed by Seth Scriver and Peter Scriver.

Learn By Doing: A Cure Approach To Teaching Exercise Testing And Prescription, Zakkoyya H. Lewis

Educational Practices in Kinesiology

The purpose of this paper is to outline a course-based undergraduate research experience (CURE) for exercise testing and prescription. The CURE is a non-human research study aimed to evaluate whether readily available fitness applications (apps) follow the Frequency-Intensity- Time-Type (FITT) principle for exercise prescription. The CURE is intended to be incorporated into an in-person introductory level course over the final month of the term. Through the project, students will develop a research question and hypothesis, conduct a literature review of related research, appraise fitness apps, and congregate the results. The overall structure of the CURE is a mini-lecture from the …

Cutting Through Rocks, Sheila Nayar

Journal of Religion & Film

This is a film review of Cutting Through Rocks (2025), directed by Sara Khaki and Mohammadreza Eyni.

Priming For Practice: A Teaching Strategy, Jennifer Tomesko, Diane L. Rigassio Radler

Journal of Dietetic Education

Authors present a brief educational teaching strategy.

Use Of Simulation In Dietetic Internships: A Qualitative Exploration Of Program Director Attitudes And Motivations, Theresa B. O'Reilly, Amy J. Nwora, Megan Whelan, Mary-Pat Maciolek

Journal of Dietetic Education

The use of simulation holds promise for the future of dietetics education for its use as an alternative for up to 30% of the 1,000 supervised practice hours for the training of Registered Dietitian Nutritionists. Even more so, simulation is a teaching tool. When done well, simulation can challenge students in a safe environment where they can receive constructive feedback from expert guides and meaningfully reflect on their learning. The purpose of this study was to interview dietetic internship (DI) program directors on their attitudes and motivations on the use of simulation in their programs, targeting the heavily program-congested states …

Conceptual Diagrams Help Dietetic Students To Understand And Apply The Nutrition Care Process, Janica Jamieson, Bojana Kovacic, Philippa Lyons-Wall, Therese O'Sullivan

Journal of Dietetic Education

Aim: To evaluate the impact of a conceptual diagram assessment task on dietetic student knowledge of and confidence applying the Nutrition Care Process. Methods: Situated within a pragmatic research paradigm, this mixed methods study applied a survey administered before and after a conceptual diagram assessment task using the Nutrition Care Process to explore changes in student knowledge, self-reported confidence, perceptions towards the Nutrition Care Process, and student experience. Nineteen students enrolled in a first-semester unit within a Master level dietetic course completed the assessment task, which visually presented a client case sourced from the student-run clinic within the Nutrition Care …

A Qualitative Analysis Of 14- To 17-Year-Olds’ Perceptions Of And Interest In Dietetics, Andrea Barney, Kelsey Mueller, Emily Patten

Journal of Dietetic Education

Objective: To understand 14-17-year-old youth’s perceptions of the field of dietetics and what would influence them to pursue or not pursue dietetics as a career. Design: Researchers developed an electronic survey asking about youth’s perceptions of the dietetics profession. Setting/Participants: The survey was distributed to a diverse population of youth aged 14-17 in the USA. Main Outcome Measures: Researchers aimed to understand what qualities 14-17-year-olds associate with dietetics professionals and if youth are interested in and/or view themselves as capable of becoming a dietitian. Analysis: SPSS software calculated descriptive statistics. Open-ended responses were analyzed using conventional content analysis. Results: Half …

Cover, Editor's Message, Table Of Contents, Diana Cuy Castellanos

Journal of Dietetic Education

No abstract provided.

The Usefulness Of 3d Heart Models As A Tool Of Congenital Heart Disease Education: A Narrative Review, Raghad Abdulaziz Alhojailan, Reghd Husain M Alkhalifah, Bana Albani, Majed Wadi

Journal of the Saudi Heart Association

Objectives: The objective of this review is to evaluate the effectiveness of three-dimensional (3D) heart models as teaching tools for congenital heart disease (CHD), addressing the limitations of traditional medical education methods. Methods: A thorough literature review was conducted using PubMed, Google Scholar, Scientific Direct and Scopus databases. Relevant articles were screened and selected based on their discussion of the application of 3D models in CHD education. Results: The comprehensive review of 19 studies revealed that 3D heart models provide students, healthcare professionals, and patients with meaningful experiences that significantly enhance understanding and learning outcomes. These models improve …

British Latino: Investigating Discourse-Stylistic Variables And The Construction Of Persona Within Podcasting, Jonathan A. Pye

International Journal of the Linguistic Association of the Southwest

This study expands upon previous work (McIlwaine et al., 2011; McIlwaine & Bunge, 2016) by analyzing how the Latin American community in the UK constructs identity through podcasting. The sociolinguistic construct of the persona (Campbell-Kibler, 2008; Coupland, 2007; D’Onofrio, 2020; Eckert, 2019; Podesva, 2007) is operationalized to understand how the persona of the British Latino is discursively constructed in the podcast of the British Latino Network. Using qualitative discourse analysis and values coding (Saldaña, 2013), this analysis finds that the British Latino persona is indexed in the podcast as a bricolage of four principal attributes: (1) aspirational, (2) educated, …

Advances In 2024: Update And Thanking Our Peer Reviewers, Richard Alweis, Christina Goodermote, Elizabeth Mamo

Advances in Clinical Medical Research and Healthcare Delivery

The Editors review the performance of the journal and thank the peer reviewers for 2024.

Monroe County Medical Society Abstract Competition, Janine Fogarty

Advances in Clinical Medical Research and Healthcare Delivery

Established in 1821 in Rochester, New York, Monroe County Medical Society is a non-profit, professional organization whose 1,200 members are physicians, residents, and medical students. The society advocates for physicians and patients for the betterment of the medical profession and the health of the community. Monroe County Medical Society encompasses the 7th District Branch of the Medical Society of the State of New York and serves the New York State counties of Monroe, Livingston, Ontario, Seneca, Steuben, Wayne & Yates Counties

A call for abstracts was requested for the Monroe County Medical Society 203rd Anniversary Gala held on September 25th, …

Murder Mystery Solved! Unmasking Multi-Generational Familial Death As A Result Of Brugada Syndrome, Ryan Tam, Sandres Aodish, Jeremiah Tom, Mohammad Jawish

Advances in Clinical Medical Research and Healthcare Delivery

Brugada syndrome is an inherited condition that has an increased risk of developing ventricular arrhythmias and sudden cardiac death. This condition can be diagnosed by using the Shanghai Scoring System. Here, we present a patient with an incidental finding of Type 1 Brugada pattern on electrocardiogram amidst atypical neurological findings on presentation to the emergency department and a history of cardiac-related familial deaths of uncertain etiology.

Abdominal/Pelvic Ct Scans Ordered Pre-Physical Exam In The Emergency Department, A Pilot Study, Ryanne M. Burke, Hannah Zazulak, Andrea M. Bodine Md

Advances in Clinical Medical Research and Healthcare Delivery

Introduction: Computerized tomography (CT) scans are effective for evaluating abdominal pain, a common emergency department (ED) complaint. In ED “physician in triage” (PIT) models, CTs can be ordered in triage. PIT has been shown to have higher clinical yield of abdominal/pelvic CTs than the traditional ED model. We explored the benefit versus radiation risk of abdominal/pelvic CTs ordered in an ED where physicians may order CTs in triage (pre-PE) to determine if results were similar to post physical exam (post PE) CTs.

Methods: In this retrospective study at Berkshire Medical Center in Pittsfield, Massachusetts, 969 patients had abdominal/pelvic CTs in …

Unique Case Of Acute Pancreatitis Linked To L-Arginine Supplement Use In A Bodybuilder, Farah Majdoub, Sarah Hewitt, Rohail Baig, Luke Pettet, Thaddeus John Sullivan, Daniel Chin

Advances in Clinical Medical Research and Healthcare Delivery

The two most common etiologies of acute pancreatitis are alcohol abuse and gallstones which comprise greater than 80% of all cases. There are many other possible etiologies, including hypertriglyceridemia, trauma, ischemia, autoimmune, drugs such as anabolic steroids and toxins such as scorpion venom. We report a unique case of acute pancreatitis in a 34-year-old body-builder related to use of the L-arginine protein product. The patient denied any alcohol use or any use of anabolic steroids for bodybuilding. He had a past medical history of bipolar disorder treated with valproic acid but had no longer been taking this medication for the …

One Center's Experience Of Pulmonary Embolism After Covid-19: Impact Of Vaccination Status, Cara Gose, Kaylee Dixon, Andrea M. Bodine Md

Advances in Clinical Medical Research and Healthcare Delivery

Background: The incidence of pulmonary embolism (PE) has increased since the outbreak of the COVID-19 pandemic and may be due to the observed hypercoagulable state. There is conflicting evidence that thromboembolism risk increases after vaccination and that vaccines decrease the probability of having a thromboembolic event. This study aimed to explore how vaccination status impacts occurrence of PE after a positive COVID-19 test. The hypothesis was that vaccinated, immunocompetent patients have a lower incidence of PE after COVID-19 compared to unvaccinated patients.

Methods: This was a retrospective chart review at a teaching hospital in New England from 1/01/2021 to 3/31/2023 …

A Compelling Case Of The Use Of Electroconvulsive Therapy In Severe Treatment Resistant Depression With Suicidality, Neha Narayanan, Ryan Tam, James Mead

Advances in Clinical Medical Research and Healthcare Delivery

Treatment-resistant depression is a condition that occurs when an individual, experiencing major depressive disorder episodes, has failed the first line of treatment with medication therapy of adequate dose and duration. This is important to be addressed as there is a high likelihood of progression to having thoughts and an intended plan for suicide. Electroconvulsive therapy is a recommended option for those who have failed medication therapy, but it has been controversial in its use due to its stigma and side effects of memory impairment. Here, we present a case of a patient who had undergone several sessions of ECT with …

Special Patient Populations - A Case Report Of A Jehovah’S Witness, Michael P. Mullinax, S. Jiaming Lin, Paige M. Kieper, Jake W. Vogel, Orlando Nunez Isaac

Advances in Clinical Medical Research and Healthcare Delivery

This case report describes a Jehovah’s Witness patient with a life-threatening exacerbation of chronic anemia, warranting blood transfusion. This case highlights the complex medical management and ethical considerations encountered when treating special patient populations. Moreover, this case illustrates the delicate balance that healthcare providers must maintain when delivering necessary medical interventions to patients with competing religious beliefs.

Enfortumab Vedotin Induced Cutaneous Manifestations, Zeni Kharel, Farhan S. Imran

Advances in Clinical Medical Research and Healthcare Delivery

Enfortumab vedotin(EV) comprises of an anti–nectin-4 monoclonal antibody bound to the chemotherapeutic agent called monomethyl auristatin E, forming an antibody-drug conjugate. It is currently approved for the treatment of locally advanced or metastatic urothelial carcinoma after disease progression on two prior lines of therapy including chemotherapy and immunotherapy. Since nectin-4 is also expressed on the surface of keratinocytes, cutaneous adverse effects are common. Our clinical image depicts a cutaneous adverse reaction to EV and its resolution after discontinuation of EV.

Coexisting Renal Artery Stenosis And Large Angiomyolipoma In A Solitary Kidney: A Therapeutic Dilemma, Yohannes B. Tilahun, Arjun Sekar

Advances in Clinical Medical Research and Healthcare Delivery

Title: Coexisting Renal Artery Stenosis and Large Angiomyolipoma in a Solitary Kidney: A Therapeutic Dilemma

Authors: Tilahun YB, Mentor/Attending: Sekar A

Background: Angiomyolipomas (AMLs) are the most common benign renal tumors, typically presenting as incidental findings. However, large AMLs can lead to life-threatening complications such as retroperitoneal hemorrhage, particularly in the setting of a solitary kidney. The presence of concomitant renal artery stenosis (RAS) further complicates management, posing a unique therapeutic challenge in balancing the need to prevent hemorrhage, preserve renal function, and optimize renovascular perfusion.

Case: A 77-year-old African American woman with a history of left nephrectomy for renal …