C & A Carbone v. Clarkstown: A Wake-Up Call for the Dormant Commerce Clause

Introduction Garbage collection, transportation, and disposal have historically been the responsibility of individual towns and cities in the United States. 1 However, stringent environmental regulations, declining landfill capacity, and the implementation of costly source reduction and recycling programs have greatly increased the costs of waste management borne by towns. 2 For the past two decades, many local governments have relied on flow control ordinances to finance their solid waste management activities. 3 These ordinances designate where municipal solid waste generated within the community must be managed, stored, or disposed. 4 Recently, in C & A Carbone, Inc. v. Town of Clarkstown, 5 the U.S. Supreme Court ruled that such ordinances violate the Commerce Clause of the U.S. Constitution. In this decision, the Court misapplied the dormant Commerce Clause doctrine and thereby jeopardized the financial stability of local governments that have relied on flow control ordinances to finance their waste management programs. Flow control ordinances dictate where a community\u27s garbage must be processed or disposed. 6 By enabling a local government to control its garbage, flow control helps the town meet its environmental goals, such as ensuring that recyclable materials are properly separated. 7 Typically, garbage processing and disposal facilities charge a fee per ton of garbage handled, known as a tipping fee. 8 By requiring all municipal waste to be shipped to a designated facility, flow control guarantees a stream of revenue to that facility. 9 Local governments have relied on this revenue to fund ..

‘Hidden habitus’: a qualitative study of socio-ecological influences on drinking practices and social identity in mid-adolescence

This study explored mid-adolescents’ views and experiences of socio-ecological influences on their drinking practices in order to help inform the development of interventions to reduce alcohol-related risk. We conducted 31 in-depth interviews with young people aged 13–17 in North East England. Verbatim interview transcripts and field notes were coded systematically and analysed thematically, following the principles of constant comparison. We adopted Bourdieu’s idea of social game-playing and elements of his conceptual toolkit (particularly habitus, capital and field) during analysis. Analysis yielded three intersecting themes: (1) ‘drinking etiquette’: conveying taste and disgust; (2) ‘playing the drinking game’: demonstrating cultural competency; (3) ‘hidden habitus’—the role of alcohol marketing. Our work demonstrates that there is a nexus of influential factors which come together to help shape and reinforce mid-adolescents’ behaviour, norms and values in relation to alcohol consumption. Drinking practices are not just formed by friendships and family traditions, these are also subject to wider cultural shaping including by the alcohol industry which can encourage brand identification, and gear specific products to add ‘distinction’. However young people are not inactive players and they use aspects of capital and social games to help cement their identity and present themselves in particular ways which in turn are influenced by age, gender and social status. Guided by promising work in the tobacco field, interventions which focus on critical awareness of the framing of alcohol products by key stakeholders, such as policymakers, commercial industry and public health professionals, and by wider society may facilitate behaviour change among young people

Alternatives for Measuring Hazardous Waste Reduction

PTI Project number 233U-4913FRHWRIC Project Number 89006

Self reliant groups from India to Scotland: lessons from south to north

There is a move towards partnership working across the global north and south but there remain questions about how to do it most effectively. This paper reports on the findings from a project that built a partnership between women in Scotland and India in order to transfer knowledge about Indian Self Help Groups. By creating peer to peer relationships that challenged traditional roles of 'teacher' and 'learner', the project was effective in transferring learning from south to north and generating meaningful outcomes for those involved. Despite the contextual differences, the successful transfer of key components of the model, savings, and loans, has led to a sense of empowerment in the Scottish women that is comparable to their Indian counterparts. As the project continues, it will be important that the dialogue between the partners continues, so there is ongoing learning as the Scottish groups expand and develop

An evaluation study of an alternative middle school at-risk program

The entire dissertation/thesis text is included in the research.pdf file; the official abstract appears in the short.pdf file (which also appears in the research.pdf); a non-technical general description, or public abstract, appears in the public.pdf file.Title from title screen of research.pdf file (viewed on July 21, 2009)Thesis (Ed. D.) University of Missouri-Columbia 2008.The study examined the effectiveness of a middle school alternative program, titled academic recovery, in improving student scores on the state assessment and student outlook on education. The quantitative component of this study analyzed the growth of the test scores of the students in this program on the state assessment for one year in communication arts and mathematics. Additionally, the student's growth on the state assessment was compared to the growth of a similar group of students who qualified for the program but were not enrolled in the program. The qualitative component of the study examined student perceptions of their experiences in the academic recovery program. Students in the academic recovery program were found not to have statistically improved on the state assessment in communication arts and mathematics, and they did not statistically improve more on the state assessment in communication arts and mathematics than a similar group of their peers. Through the qualitative analysis it was found students had developed a positive connection with their teacher, had formed friendships at school, and had developed some interests at school. Nevertheless, the students were still struggling academically at school, angry at their non academic recovery teacher, uncertain of their future plans, and sometimes felt they were bullied by peers.Includes bibliographical reference

Financial Markets and the AT&T Antitrust Settlement

The 1984 Justice Department settlement with AT&T marked one of the largest antitrust action in the nation's history. At the end of the process major changes were made in the original settlement proposal. Investors in affected industries behaved as if they were assessing these changes. Portfolio values of AT&T, its direct competitors, and firms in fields AT&T would enter were affected. As the settlement was made final, financial markets evidence indicates changes in abnormal returns for affected firms.Financial Markets

Priority to end of life treatments? Views of the public in the Netherlands

Objectives:Recent debates in the Netherlands on health care priority setting have focused on the relative value of gains generated by life-extending medicines for people with a terminal illness, mostly new cancer drugs. These treatments are generally expensive, provide relatively small health gains, and therefore usually do not meet common cost per QALY thresholds. Nevertheless, these drugs may be provided under the assumption that there is public support for making a special case for treatments for people with a terminal illness. This study investigated the views of the public in the Netherlands on a range of equity and efficiency considerations relevant to priority setting and examines whether there is public support for making such a special case.Methods:Using Q methodology, three viewpoints on important principles for priority setting were identified. Data were collected through ranking exercises conducted by 46 members of the general public in the Netherlands, including 11 respondents with personal experience with cancer.Results:Viewpoint 1 emphasized that people have equal rights to healthcare and opposed priority setting on any ground. Viewpoint 2 emphasized that the care for terminal patients should at all times respect the patients’ quality of life, which sometimes means refraining from invasive treatments. Viewpoint 3 had a strong focus on effective and efficient care and had no moral objection against priority setting under certain circumstances.Conclusions:Overall, we found little public support for the assumption that health gains in terminally ill patients are more valuable than those in other patients. This implies that the assumption that society is prepared to pay more for health gains in people who have only a short period of lifetime left does not correspond with societal preferences in the Netherlands.<br/