The Unavoidable Ecclesiastical Collision in Virginia

Section 5 7-9(A) of the Code of Virginia is a statute that purports to resolve church property disputes. There is, however, a significant amount of controversy as to whether the statute encroaches on the free exercise rights of hierarchical churches located in Virginia and enmeshes Virginia courts in the ecclesiastical thicket. Given the debate surrounding Section 57-9(A) and the controversial shift of several mainstream denominations in matters of substantive church doctrine, Virginia is a fertile breeding ground for church property disputes. Accordingly, the Commonwealth is in the midst of an ecclesiastical crisis. The impact of the crisis is evidenced by the recent division within the Episcopal Church\u27s Diocese of Virginia and the subsequent church property litigation that ensued following the division. This Comment examines the constitutional standards surrounding various courses of action states may pursue to resolve church property disputes and provides a specific analysis of Virginia\u27s statutory scheme for doing so. Current Supreme Court of the United States precedent establishes that courts have three constitutional options they can rely on in resolving church property disputes. Courts may defer to the decision of the religious organization\u27s adjudicatory body, a method of resolution known as the deference approach. Courts may also decide the case on the basis of a neutral principle of law such as property law or contact law. Finally, states may enact special statutes to direct courts on how to resolve church property disputes. This article argues that Section 57-9(A) does not operate as a constitutional method of resolving church property disputes within the Supreme Court\u27s established framework for doing so. Accordingly, due to the constitutional issues with Section 57- 9(A), the law in Virginia regulating church property disputes is on a path leading to an unavoidable ecclesiastical collision

The Unavoidable Ecclesiastical Collision in Virginia

Section 5 7-9(A) of the Code of Virginia is a statute that purports to resolve church property disputes. There is, however, a significant amount of controversy as to whether the statute encroaches on the free exercise rights of hierarchical churches located in Virginia and enmeshes Virginia courts in the ecclesiastical thicket. Given the debate surrounding Section 57-9(A) and the controversial shift of several mainstream denominations in matters of substantive church doctrine, Virginia is a fertile breeding ground for church property disputes. Accordingly, the Commonwealth is in the midst of an ecclesiastical crisis. The impact of the crisis is evidenced by the recent division within the Episcopal Church\u27s Diocese of Virginia and the subsequent church property litigation that ensued following the division. This Comment examines the constitutional standards surrounding various courses of action states may pursue to resolve church property disputes and provides a specific analysis of Virginia\u27s statutory scheme for doing so. Current Supreme Court of the United States precedent establishes that courts have three constitutional options they can rely on in resolving church property disputes. Courts may defer to the decision of the religious organization\u27s adjudicatory body, a method of resolution known as the deference approach. Courts may also decide the case on the basis of a neutral principle of law such as property law or contact law. Finally, states may enact special statutes to direct courts on how to resolve church property disputes. This article argues that Section 57-9(A) does not operate as a constitutional method of resolving church property disputes within the Supreme Court\u27s established framework for doing so. Accordingly, due to the constitutional issues with Section 57- 9(A), the law in Virginia regulating church property disputes is on a path leading to an unavoidable ecclesiastical collision

The Unaviodable Ecclesiastical Collision in Virginia

Section 57-9(A) of the Code of Virginia is a statute that purports to resolve church property disputes. There is, however, a significant amount of controversy as to whether the statute encroaches on the free exercise rights of hierarchical churches located in Virginia and enmeshes Virginia courts in the ecclesiastical thicket. Given the debate surrounding Section 57-9(A) and the controversial shift of several mainstream denominations in matters of substantive church doctrine, Virginia is a fertile breeding ground for church property disputes. Accordingly, the Commonwealth is in the midst of an ecclesiastical crisis. The impact of the crisis is evidenced by the recent division within the Episcopal Church’s Diocese of Virginia and the subsequent church property litigation that ensued following the division. This Comment examines the constitutional standards surrounding various courses of action states may pursue to resolve church property disputes and provides a specific analysis of Virginia’s statutory scheme for doing so. Current Supreme Court of the United States precedent establishes that courts have three constitutional options they can rely on in resolving church property disputes. Courts may defer to the decision of the religious organization’s adjudicatory body, a method of resolution known as the deference approach. Courts may also decide the case on the basis of a neutral principle of law such as property law or contact law. Finally, states may enact special statutes to direct courts on how to resolve church property disputes. This article argues that Section 57-9(A) does not operate as a constitutional method of resolving church property disputes within the Supreme Court’s established framework for doing so. Accordingly, due to the constitutional issues with Section 57- 9(A), the law in Virginia regulating church property disputes is on a path leading to an unavoidable ecclesiastical collision

Representativeness of a digitally engaged population and a patient organisation population with rheumatoid arthritis and their willingness to participate in research: a cross-sectional study.

Objectives: To describe (1) the representativeness of (a) users of an online health community (HealthUnlocked.com (HU)) with rheumatoid arthritis (RA) and (b) paid members of an RA patient organisation, the National Rheumatoid Arthritis Society (NRAS), compared with the general RA population; and (2) the willingness of HU users with RA to participate in types of research (surveys, use of an app or activity tracker, and trials). Methods: A pop-up survey was embedded on HU to determine the characteristics of users and their willingness to participate in research. An anonymous data set of NRAS member characteristics was provided by the NRAS (N=2044). To represent the general RA population, characteristics of people with RA were identified from the Clinical Practice Research Datalink (CPRD) (N=20 594). Cross-sectional comparisons were made across the three groups. Results: Compared with CPRD, HU respondents (n=615) were significantly younger (49% aged below 55 years compared with 23% of CPRD patients), significantly more deprived (21% in the most deprived Townsend quintile compared with 12% of CPRD patients) and had more recent disease, with 62% diagnosed between 2010 and 2016 compared with 37% of CPRD patients. NRAS members were more similar to the CPRD, but significantly under-represented those aged 75 years or over and over-represented those aged 55-75 years compared with the CPRD. High proportions of HU users were willing to participate in future research of all types. Conclusions: NRAS members were broadly representative of the general RA population. HU users were younger, more deprived and more recently diagnosed. HU users were willing to participate in most types of research

Musculoskeletal pain is associated with a long-term increased risk of cancer and cardiovascular-related mortality

Objectives. To test the hypothesis that individuals with regional and widespread pain disorders have an increased risk of mortality

Evidence for strategies that improve recruitment and retention of adults aged 65 years and over in randomised trials and observational studies: a systematic review

Background: adults aged ≥65 years are often excluded from health research studies. Lack of representation reduces generalisability of treatments for this age group. Objective: to evaluate the effectiveness of strategies that improve recruitment and retention of adults aged ≥65 in observational studies and randomised controlled trials (RCTs). Methods: searches conducted in 10 databases for RCTs of recruitment and retention strategies in RCTs or observational studies. Two reviewers screened abstracts and full-text articles for eligibility and extracted data. Studies without separate data for adults aged ≥65 were discarded. Risk of bias assessed using the Cochrane Risk of Bias tool. Results were synthesised narratively. Results: thirty-two studies were included in the review (n = 75,444). Twelve studies had low risk of bias, of which 10 had successful strategies including: Opt-out versus opt-in increased recruitment (13.6% (n = 261)-18.7% (n = 36) difference; two studies); Advance notification increased retention (1.6% difference, OR 1.45; 95% CI 1.01, 2.10, one study (n = 2,686); 9.1% difference at 4 months, 1.44; 1.08, 1.92, one study (n = 753)); Hand-delivered versus postal surveys increased response (25.1% difference; X2 = 11.40, P < 0.01; one study (n = 139)); Open randomised design versus blinded RCT increased recruitment (1.56; 1.05, 2.33) and retention (13.9% difference; 3.1%, 24.6%) in one study (n = 538). Risk of bias was high/unclear for studies in which incentives or shorter length questionnaires increased response. Discussion: in low risk of bias studies, few of the strategies that improved participation in older adults had been tested in ≥1 study. Opt-out and advance notification strategies improved recruitment and retention, respectively, although an opt-out approach may have ethical limitations. Evidence from single studies limits the generalisability of other strategies

Insecure attachment style is associated with chronic widespread pain

Individuals with "insecure" adult attachment styles have been shown to experience more pain than people with secure attachment, though results of previous studies have been inconsistent. We performed a cross-sectional study on a large population-based sample to investigate whether, compared to pain free individuals, subjects with chronic widespread pain were more likely to report insecure adult attachment style. Subjects in a population-based cross-sectional study completed a self-rated assessment of adult attachment style. Attachment style was categorised as secure (i.e., normal attachment style); or preoccupied, dismissing or fearful (insecure attachment styles). Subjects completed a pain questionnaire from which three groups were identified: pain free; chronic widespread pain; and other pain. Subjects rated their pain intensity and pain-related disability on an 11 point Likert scale. Subjects (2509) returned a completed questionnaire (median age 49.9 years (IQR 41.2-50.0); 59.2% female). Subjects with CWP were more likely to report a preoccupied (RRR 2.6; 95%CI 1.8-3.7), dismissing (RRR 1.9; 95%CI 1.2-3.1) or fearful attachment style (RRR 1.4; 95%CI 1.1-1.8) than those free of pain. Among CWP subjects, insecure attachment style was associated with number of pain sites (Dismissing: RRR 2.8; 95%CI 1.2-2.3, Preoccupied: RRR=1.8, 95%CI 0.98-3.5) and degree of pain-related disability (Preoccupied: RRR=2.1, 95%CI 1.0-4.1), but not pain intensity. These findings suggest that treatment strategies based on knowledge of attachment style, possibly using support and education, may alleviate distress and disability in people at risk of, or affected by, chronic widespread pain

Restorative sleep predicts the resolution of chronic widespread pain: results from the EPIFUND study

PublishedJournal ArticleMulticenter StudyResearch Support, Non-U.S. Gov'tVersion of record of article published in Rheumatology (Oxford). 2008 Dec; 47(12): 1809–1813. Published online 2008 Oct 7. doi: 10.1093/rheumatology/ken389OBJECTIVES: Poor sleep is associated with chronic widespread pain (CWP). Conversely, good-quality sleep may play a role in the resolution of pain symptoms. Sleep is a multidimensional construct, comprising a number of diverse components. The aims of the current study were to examine the hypotheses that: (i) good sleep quality would predict the resolution of CWP, (ii) restorative sleep would predict the resolution of CWP and (iii) that these relationships would be independent of confounding psychological factors. METHODS: Subjects in a population-based prospective study completed a pain questionnaire at baseline from which subjects with CWP were identified. Baseline sleep was measured using the Estimation of Sleep Problems Scale which measures sleep onset, maintenance, early wakening and restorative sleep. The questionnaire also contained scales examining psychosocial status. Subjects were followed up 15 months later and pain status was assessed. RESULTS: A total of 1061 subjects reported CWP at baseline of whom 679 (75% of eligible subjects) responded at follow-up. Of those, a total of 300 (44%) no longer satisfied criteria for CWP. Univariate analysis revealed that three of the four sleep components were associated with the resolution of CWP: rapid sleep onset, odds ratio (OR) = 1.7, 95% CI 1.2, 2.5; absence of early wakening, OR = 1.6, 95% CI 1.1, 2.4; and restorative sleep, OR = 2.7, 95% CI 1.5, 4.8. After adjusting for the effect of psychosocial factors, which may have confounded the relationship, only restorative sleep (OR = 2.0, 95% CI 1.02, 3.8) was associated. CONCLUSIONS: Self-reported restorative sleep was independently associated with the resolution of CWP and return to musculoskeletal health.This study was funded by the Arthritis Research Campaign, Grant number: 1755

Widespread pain and depression are key modifiable risk factors associated with reduced social participation in older adults: A prospective cohort study in primary care.

In older adults, reduced social participation increases the risk of poor health-related quality of life, increased levels of inflammatory markers and cardiovascular disease, and increased mortality. Older adults frequently present to primary care, which offers the potential to deliver interventions at the point of care to increase social participation. The aim of this prospective study was to identify the key modifiable exposures that were associated with reduced social participation in a primary care population of older adults.The study was a population-based prospective cohort study. Participants (n = 1991) were those aged ≥65 years who had completed questionnaires at baseline, and 3 and 6-year follow-ups. Generalized linear mixed modeling framework was used to test for associations between exposures and decreasing social participation over 6 years.At baseline, 44% of participants reported reduced social participation, increasing to 49% and 55% at 3 and 6-year follow-up. Widespread pain and depression had the strongest independent association with reduced social participation over the 6-year follow-up period. The prevalence of reduced social participation for those with widespread pain was 106% (adjusted incidence rate ratio 2.06, 95% confidence interval 1.72, 2.46), higher than for those with no pain. Those with depression had an increased prevalence of 82% (adjusted incidence rate ratio 1.82, 95% confidence interval 1.62, 2.06). These associations persisted in multivariate analysis.Population ageing will be accompanied by increasing numbers of older adults with pain and depression. Future trials should assess whether screening for widespread pain and depression, and targeting appropriate treatment in primary care, increase social participation in older people

The onset of widespread musculoskeletal pain is associated with a decrease in healthy ageing in older people: a population-based prospective study

OBJECTIVE: Chronic musculoskeletal pain is common in older adults but the nature of its relationship with ageing is unclear. The objective for this study was to test the hypothesis that the onset of widespread pain would be associated with a decrease in healthy ageing. METHODS: Population-based prospective cohort study. A "healthy ageing" index was constructed across biomedical, physical, psychosocial and lay components. Analysis was performed with 2949 adults aged 50 years and over who had complete index scores at baseline, 3 and 6-year follow-ups. RESULTS: At three and six year follow-up, 365 (16.8%) and 259 (14.3%) experienced the onset of widespread pain. The onset of widespread pain during the six-year period was associated with a 25% and a 46% decrease in healthy ageing index scores; this decrease was independent of age, sex, education, social networks, smoking status, alcohol consumption and physical inactivity. The decrease in healthy ageing attenuated to 20% and 39% following adjustment for diagnosed musculoskeletal conditions and analgesic and non-steroidal use. CONCLUSIONS: The onset of widespread pain was associated with a decrease in healthy ageing throughout the six-year period. When pain increased over time, the markers of unhealthy ageing increased also. Strong analgesia was associated with unhealthy ageing. Research could now usefully test whether early identification, improved treatment and prevention of pain prior to old age may facilitate healthy ageing