The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law最新文献

{"title":"'Shouting Fire in a Theater': The Life and Times of Constitutional Law’s Most Enduring Analogy","authors":"Carlton F. W. Larson","doi":"10.2139/SSRN.2548849","DOIUrl":"https://doi.org/10.2139/SSRN.2548849","url":null,"abstract":"In 1919, Justice Oliver Wendell Holmes introduced the specter of a man falsely shouting fire in a theater into First Amendment law. Nearly one hundred years later, this analogy remains the most enduring analogy in constitutional law. It has been relied on in hundreds of constitutional cases and it has permeated popular discourse on the scope of individual rights.This Essay examines the both the origins and the later life of Holmes’s theater analogy. Part One is a detective story, seeking to solve the mystery of how Holmes came up with this particular example. This story takes us to the forgotten world of the late nineteenth and early twentieth centuries, when false shouts of fire in theaters were a pervasive problem that killed hundreds of people both in the United States and Great Britain. The person who shouted “fire” in a crowded theater was a recognizable stock villain of popular culture, condemned in newspapers, magazines and books from coast to coast. The analogy, lifted by Holmes from a federal prosecutor in Cleveland, was rooted in this larger world of popular culture. Understanding this world also answers another question: Why do lawyers and non-lawyers alike refer to “shouting fire in a crowded theater” rather than “falsely shouting fire in a theater and causing a panic,” which is what Holmes actually wrote? Along the way, we will encounter a real detective and even a mustachioed villain.Part Two is based on an empirical study of the 278 subsequent judicial opinions that employ the theater analogy. In lower courts, opinions that invoke the analogy, not surprisingly, typically reject free speech claims, but opinions that paraphrase Holmes are, counter-intuitively, more receptive to free speech claims than opinions that quote Holmes precisely. The Essay concludes by noting that the theater analogy has largely lost its capacity to frighten in the visceral way that Holmes’s audience would have understood it. Although it persists in constitutional law, it has become rarified and largely abstract, perhaps contributing in some small way to the general libertarian trend of modern First Amendment law.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"1 1","pages":"181"},"PeriodicalIF":0.0,"publicationDate":"2015-01-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"88345521","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Historically Unappealing: Boumediene v. Bush, Appellate Avoidance Mechanisms, and Black Holes Extending Beyond Guantanamo Bay","authors":"Dennis Schmelzer","doi":"10.2139/SSRN.2527510","DOIUrl":"https://doi.org/10.2139/SSRN.2527510","url":null,"abstract":"This article revisits the historical questions raised by the U.S. Supreme Court in Boumediene v. Bush about the reach of the writ of habeas corpus at common law to territories like Guantanamo Bay. Despite extensive oral arguments and briefing about the significance of prior case law, both the Court’s majority and dissenting opinions concluded that there was no precedent definitively answering their historical questions about the reach of the Great Writ. Justice Kennedy suggested that there simply may not have been good historical parallels for the detentions at Guantanamo Bay given the “uniqueness” of the territory and the particular challenges of terrorism in the present age. Justice Scalia suggested that the absence of case law demonstrated on its own that the writ was simply unavailable at common law to similar foreign prisoners held outside the sovereign control of the United States or the English Crown. This Article provides a different explanation. Its research reveals the following discoveries: (1) the legal status of the U.S. Naval Station at Guantanamo is not that unique compared with other territories acquired in the early Nineteenth Century; (2) the writ of habeas corpus and other Constitutional rights were routinely recognized in all of those territories by statute or Executive Order; and (3) the availability of these rights is masked in Article III case law because constitutional disputes were primarily handled by territorial courts established outside the purview of Article III of the U.S. Constitution. This Article further offers the theory that the political branches “voluntarily” recognized most rights (including the privilege of habeas corpus) and granted territorial courts jurisdiction to hear constitutional challenges in the first instance in an effort to intentionally avoid or delay judicial review of most constitutional questions arising in those territories by Article III courts. These developments were spurred by early Supreme Court decisions indicating that the Court might intervene if certain fundamental Constitutional rights were denied in those territories. From that point on, the political branches actively manipulated doctrines of judicial avoidance to prevent potentially adverse constitutional precedent. The absence of most of this history in reported case law from Article III courts demonstrates a significant blind spot of reported precedent as a historical guide.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"23 1","pages":"965"},"PeriodicalIF":0.0,"publicationDate":"2014-11-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"82647368","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Sovereign Impunity: The Supreme Court of Georgia's False Textualism Expands the Doctrine of Sovereign Immunity in the State","authors":"Laura Dove","doi":"10.2139/SSRN.2526226","DOIUrl":"https://doi.org/10.2139/SSRN.2526226","url":null,"abstract":"Until recently, sovereign immunity — the doctrine that protects state entities from suit without the State’s consent — had been held by the Supreme Court of Georgia not to apply to suits seeking solely injunctive relief to prevent the State, its departments, or agencies from acting illegally or outside the scope of their authority. This rule stemmed partly from the fact that a significant policy basis for sovereign immunity is the protection of taxpayer funds, but also was grounded on the principle that the State may not “cloak itself in the mantle of sovereign immunity” to prevent its citizens from holding the State accountable to its own laws. In a recent case, however, the Supreme Court of Georgia nullified this longstanding principle by overruling a previous decision recognizing and affirming it. The Court’s decision to overrule the earlier case was based on a purportedly textualist analysis of a 1991 amendment to Georgia’s Constitution reserving sovereign immunity to the State, its departments, and agencies, and granting the exclusive power to waive sovereign immunity to Georgia’s General Assembly. Textualism, an approach to statutory and constitutional interpretation, requires courts to interpret texts based on the ordinary meaning of the terms employed within their context. Georgia courts’ interpretation jurisprudence typically reflects textualist principles. Although the Court examined the language in several portions of the Constitution’s sovereign immunity provision, it neglected the meaning of the provision’s most significant phrase: “sovereign immunity” itself. The Court failed to consider the constitutional language within its appropriate historical context, namely by refusing to examine the historical meaning of sovereign immunity as developed through decisions of the Georgia courts. This Article concludes that the Court’s decision is unsupported by the textualist principles of constitutional interpretation that it espouses and by the Court’s own precedent on the interpretation of constitutional text.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"37 1","pages":"1045"},"PeriodicalIF":0.0,"publicationDate":"2014-09-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"88462766","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Confronting Cops in Immigration Court","authors":"Mary Holper","doi":"10.2139/SSRN.2485328","DOIUrl":"https://doi.org/10.2139/SSRN.2485328","url":null,"abstract":"Immigration judges routinely use police reports to make life-altering decisions in noncitizens’ lives. The word of the police officer prevents a detainee from being released on bond, leads to negative discretionary decisions in relief from removal, and can prove that a past crime fits within a ground of removability. Yet the police officers who write these reports rarely step foot in immigration court; immigration judges rely on the hearsay document to make such critical decisions. This practice is especially troubling when the same police reports cannot be used against the noncitizen in a criminal case without the officer testifying, due to both the Sixth Amendment’s Confrontation Clause and Federal Rules of Evidence, neither of which apply in immigration court. In these days of the increasing criminalization of immigration law and prioritization of deporting so-called “criminal aliens,” the police report problem is salient, and impacts thousands of noncitizens every year. This article argues for a right to confront police officers in immigration court by examining three different ways to conceptualize removal proceedings: (1) in light of the Supreme Court’s 2010 decision in Padilla v. Kentucky, deportation should be considered punishment, thus guaranteeing all of the protections of a criminal trial, including the Sixth Amendment Confrontation Clause; (2) under the Mathews v. Eldridge case-by-case balancing test of the due process clause, courts should balance the interests at stake and adopt a right to confrontation and cross-examination of police officers in immigration court; and (3) if deportation is conceptualized as “quasi-criminal” and thus deserving of some, but not all, of the protections guaranteed at a criminal trial, one of those protections should be the right to confront one’s accuser, especially when the accuser is a police officer. The scholarship has focused on why other rights guaranteed in a criminal trial – court-appointed counsel, freedom from ex post facto laws, freedom from double jeopardy, proportionality principles, and the Fourth Amendment exclusionary rule – should apply to removal proceedings. An overlooked criminal protection is the right to confront one’s accuser in immigration court.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"15 1","pages":"675"},"PeriodicalIF":0.0,"publicationDate":"2014-08-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"84969715","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Private Standards Organizations and Public Law","authors":"P. Strauss","doi":"10.2139/SSRN.2194210","DOIUrl":"https://doi.org/10.2139/SSRN.2194210","url":null,"abstract":"Simplified, universal access to law is one of the important transformations worked by the digital age. With the replacement of physical by digital copies, citizens ordinarily need travel only to the nearest computer to find and read the texts that bind them. Lagging behind this development, however, has been computer access to standards developed by private standards development organizations, often under the umbrella of the American National Standards Institute, and then converted by agency actions incorporating them by reference into legal obligations. To discover what colors OSHA requires for use in workplace caution signs, one must purchase from ANSI the standard OSHA has referenced in its regulations, at the price ANSI chooses to charge for it.The regulations governing incorporation by reference as a federal matter have not been revised since 1982, and so do not address the changes the digital age has brought about in what it means for incorporated matter to be “reasonably available,” as 5 U.S.C. §552(a)(1) requires. This essay seeks to bridge that gap, suggesting a variety of approaches that might bring the use of incorporation by reference into conformity with modern rulemaking practices and respect the general proposition that documents stating citizens’ legal obligations are not subject to copyright, while at the same time both honoring clear federal statutory policy favoring the use of privately developed standards in rulemaking and respecting the needs standards organizations have to find reasonable means to support the costs of their operations. Business models created in the age of print need to change; the challenge is to find ways to permit the market in privately developed voluntary standards to thrive, without thereby permitting the monopoly pricing of access to governing law.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"1 1","pages":"497-561"},"PeriodicalIF":0.0,"publicationDate":"2013-07-23","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"83532593","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"In Defense of Implied Injunctive Relief in Constitutional Cases","authors":"John F. Preis","doi":"10.2139/ssrn.2199451","DOIUrl":"https://doi.org/10.2139/ssrn.2199451","url":null,"abstract":"If Congress has neither authorized nor prohibited a suit to enforce the Constitution, may the federal courts create one nonetheless? At present, the answer mostly turns on the form of relief sought: if the plaintiff seeks dam- ages, the Supreme Court will normally refuse relief unless Congress has specifically authorized it; in contrast, if the plaintiff seeks an injunction, the Court will refuse relief only if Congress has specifically barred it. These contradictory approaches naturally invite arguments for reform. Two common arguments - one based on the historical relationship between law and equity and the other based on separation of powers principles - could quite forseeably combine to end implied injunctive relief as we know it.In this Article, I defend the federal courts’ power to issue injunctions in constitutional cases without explicit congressional authorization - a practice known as “implying” a suit for relief. The defense rests on two proofs, both largely historical. First, I show that the historical relationship between law and equity has largely been misunderstood in the realm of injunctive relief. Second, I show that implied injunctive relief does not contravene separation of powers principles because Congress and the federal courts have, since the Founding, viewed implied injunctive relief as permissible and even appropriate. These proofs do not account for policy concerns that might impact the inquiry, but they do suggest that such concerns must be extraordinarily compelling to overcome the federal courts’ centuries-old power to imply injunctive relief in constitutional cases.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"119 1","pages":"1"},"PeriodicalIF":0.0,"publicationDate":"2013-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"76605347","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Constitutional Remedies and Public Interest Balancing","authors":"John M. Greabe","doi":"10.2139/SSRN.2131761","DOIUrl":"https://doi.org/10.2139/SSRN.2131761","url":null,"abstract":"The conventional account of our remedial tradition recognizes that courts may engage in discretionary public interest balancing to withhold the specific remedies typically administered in equity. But it generally does not acknowledge that courts possess the same power with respect to the substitutionary remedies usually provided at law. The conventional account has things backwards when it comes to constitutional remedies. The modern Supreme Court frequently requires the withholding of substitutionary constitutional relief under doctrines developed to protect the perceived public interest. Yet it has treated specific relief to remedy ongoing or imminent invasions of rights as routine, at least when the underlying claim is justiciable and subject to neither a judicial federalism doctrine nor statutory preclusion.This paper details the reversal of the conventional account of remedial power and advances a two-part hypothesis that the Court’s behavior traces an appropriate con- stitutional boundary. The hypothesis is as follows. First, substitutionary constitutional remedies, while integral to the proper functioning of our constitutional order, are individually contingent and susceptible of legislative or judicial expansion, contraction, or replacement as the perceived public interest dictates. But second, specific relief must be available for justiciable and meritorious claims of constitutional right to which neither a judicial federalism nor a statutory diversion doctrine applies, and an effective constitutional remedy ultimately must be available even in these exceptional cases.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"19 1","pages":"857"},"PeriodicalIF":0.0,"publicationDate":"2012-10-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"81225896","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Social Science Studies and the Children of Lesbians and Gay Men: The Rational Basis Perspective","authors":"C. Ball","doi":"10.2139/SSRN.2079991","DOIUrl":"https://doi.org/10.2139/SSRN.2079991","url":null,"abstract":"This Article seeks to determine whether the social science literature on the children of lesbians and gay men precludes the government from relying on child welfare considerations to justify same-sex marriage bans and parenting restrictions affecting lesbians and gay men under the highly deferential rational basis test. Under that test, courts must uphold laws and regulations that have any conceivable basis of fact which is rationally related to a legitimate state interest. After comprehensively reviewing the social science literature, the Article concludes that the empirical evidence showing the lack of an association between parental sexual orientation and the psychological and social functioning of children is so conclusive and uniform that there is no conceivable factual basis for suggesting otherwise. The Article, however, also concludes that there are sufficient indicia of possible differences — between the children of lesbian/gay parents and those of heterosexual parents — in matters related to gender attitudes/interests and sexual orientation to satisfy the easy-to-meet factual component of the rational basis test. But this indicia of possible difference does not justify the differential treatment of lesbians and gay men in matters related to marriage and parenting because the government does not have a legitimate interest in either promoting specific gender attitudes and interests or in discouraging same-sex sexual orientations and conduct. At the end of the day, therefore, child welfare considerations constitute impermissible bases for the government’s differential treatment of lesbians and gay men in matters related to marriage and parenting, even under the highly deferential rational basis standard.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"1 1","pages":"691"},"PeriodicalIF":0.0,"publicationDate":"2012-06-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"90591577","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Impeachment as Judicial Selection","authors":"Tuan N. Samahon","doi":"10.2139/SSRN.1474773","DOIUrl":"https://doi.org/10.2139/SSRN.1474773","url":null,"abstract":"Ideological judicial selection encompasses more than the affirmative nominating, confirming, and appointing of judges who commit to particular legal interpretations and constructions of constitutional text. It may also include deselection, by way of impeachment and removal (or at least its threat), of those judges subscribing to interpretations and constructions of the Constitution that one disapproves. This negative tactic may be particularly effective when deployed against judges on closely divided collegial courts, such as the U.S. Supreme Court and the U.S. Courts of Appeals, where personnel determine voting majorities and, in turn, majorities determine case outcomes. The Pickering-Chase, Fortas-Douglas, and Christian Coalition impeachments and threats of impeachments illustrate that the use or threat of this tactic is more common than might be supposed. Indeed, recent calls for the removal of Circuit Judge Jay Bybee demonstrate the continuing allure of impeachment as judicial selection. This Article examines the phenomenon of impeachment as judicial selection through Professors Tushnet’s and Balkin’s framework of “constitutional hardball.” In the case of impeachment as judicial selection, Congress plays constitutional hardball by claiming that it is an appropriate tool for political control and a fraternal twin to the modern appointments process. This article details prior episodes of impeachment as judicial selection. It explains why the idea of impeaching as an ex post selection tool proves so tempting. It then considers those legal arguments that justify and contest the claims of this variety of constitutional hardball. Further, the Article makes the case that, contrary to conventional wisdom, constitutional and political developments make impeachment a closer alternative to transformative, affirmative selection than in the past. This relative feasibility heightens the fool’s gold allure of impeachment as judicial selection. Actually impeaching for judicial selection, however, would yield results that many would consider as untoward and unacceptably intruding on judicial independence and the rule of law. This Article briefly considers those significant costs.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"5 1","pages":"595"},"PeriodicalIF":0.0,"publicationDate":"2009-09-17","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"75903920","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"A Promise the Nation Cannot Keep: What Prevents the Application of the Thirteenth Amendment in Prison?","authors":"R. Raghunath","doi":"10.2139/SSRN.1452892","DOIUrl":"https://doi.org/10.2139/SSRN.1452892","url":null,"abstract":"The walls of the prison are not solely physical. The doctrine of judicial deference to prison officials, which compels courts to defer to the discretion of those officials in almost all instances, obstructs the effective scrutiny of modern practices of punishment. Since its ratification, the Thirteenth Amendment - which prohibits slavery or involuntary servitude anywhere within the United States or its jurisdiction, except where imposed 'as a punishment for crime whereof the party shall have been duly convicted' - has been seen by courts as one brick in this wall. This article makes the novel argument that, properly read, the amendment should instead function as a breach in this wall - one of sufficient size to allow some needed light to shine within.Although in some states inmates may still be sentenced to hard labor, in most systems today they labor under a more general requirement that, if they are able-bodied, they must work. Reading the word 'punishment' in the Thirteenth Amendment in a manner consistent with the way that same word is used in the Eighth Amendment, and is understood in the rest of the Constitution, reveals that only those inmates who are forced to work because they have been so sentenced - which is not the vast majority of inmates compelled to work in the present day - should be exempted from the general ban on involuntary servitude. In addition to examining the jurisprudence of the Eighth and Fifth Amendments as it relates to this question, this article also details the history of forced labor programs as punishment, and how courts’ reading of the punishment exception is not supported by either the circumstances surrounding ratification of the Thirteenth Amendment, or the ways that courts have construed it as a whole since that time. This article argues that the reason courts have broadened of the meaning of 'punishment' in the Thirteenth Amendment, while simultaneously narrowing it in the Eighth Amendment, is because these directly contradictory acts of constitutional interpretation both serve the same end of judicial deference to the actions of prison officials, which has resulted in the general abdication by courts of their constitutional obligations to oversee those officials’ actions. This article also theorizes about the potential outcomes of interpreting the Thirteenth Amendment properly with respect to prison labor, and suggests that the resulting recognition of the punitive purposes that have always driven our prison labor programs may actually lead to an improvement in the overall well-being of prisoners, and perhaps of society as a whole.","PeriodicalId":83315,"journal":{"name":"The William and Mary Bill of Rights journal : a student publication of the Marshall-Wythe School of Law","volume":"42 1","pages":"395"},"PeriodicalIF":0.0,"publicationDate":"2009-08-14","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"87462681","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}