Congress Giveth, and the Courts Taketh Away: Is Restitutionary Recoupment of Federal Funds a Proper Remedy When Taxpayers Allege that an Expired Statute Violated the Establishment Clause?

The Seventh Circuit recently held in Laskowski v. Spellings that grantees of government funding can be forced by taxpayers to give grant money back to the federal government when the grant has allegedly violated the Establishment Clause - even when the grant statute expired years ago, the funds have long since been spent, and the government does not want the money back. Laskowski\u27s new remedy has the potential for widely impacting Establishment Clause jurisprudence, especially in the areas of government funding for sectarian schools and other religiously-affiliated groups. The ready availability of a recoupment remedy could also have far-reaching and detrimental effects on the cooperative relationship between government agencies and faith-based organizations to provide services to the needy. Whether the recoupment remedy is appropriate is not an easy question to answer. The values protected by the Establishment Clause have been recognized as fundamental since this country\u27s founding. On the other hand, the Constitution has framed our system of government so that each of the three branches of the federal government, including the judiciary, has limited powers and must stay within the boundaries set by the Constitution. This article will show that the restitutionary recoupment remedy allowed by the Seventh Circuit arguably violates Article III\u27s limits concerning mootness and standing, as well as general separation of powers principles. Although it is important for constitutional provisions to be obeyed by the legislative and executive branches, it is not right for the Courts also to violate the Constitution\u27s mandates in order to police the other branches\u27 every move. The Supreme Court has made clear that [i]f a dispute is not a proper case or controversy, the courts have no business deciding it, or expounding the law in the course of doing so. That principle is especially relevant here, where allowing the courts to order charitable organizations to repay grant funds to the federal treasury provides only a negligible or nonexistent gain to the plaintiff taxpayers, but may bankrupt the organizations that have spent the funds in providing services of benefit to the community. This equitable restitutionary remedy is anything but equitable, and there is a better way to ensure that the Constitution\u27s safeguards are obeyed. This article will begin with an examination of the Supreme Court\u27s precedent regarding standing and mootness, as well as the history of restitution in the Establishment Clause context. Next, the article will explain the circumstances surrounding Laskowski v. Spellings and address the holdings of both the district court and the Seventh Circuit. The next section will explore the developments that have unfolded following the Laskowski holding. Finally, in determining whether recoupment is a proper remedy in this context, this article will examine mootness, standing, and restitution separately and explain why the remedy is contrary to precedent in each of those areas of the law

A Social Marketing Plan for 7hills Homeless Center

7hills Homeless Center is located in Fayetteville, Arkansas and is committed to ending homelessness in Northwest Arkansas by developing and implementing innovative services to equip the near-homeless and homeless in leading healthy and productive lives through strategic community partnerships with citizens, business, and government agencies. This thesis offers 7hills Homeless Center a comprehensive social marketing plan. The goal is to increase awareness of homelessness in Northwest Arkansas and to increase donor and volunteer involvement with 7hills. In order to accomplish these goals, a social marketing plan was developed by researching target volunteer and donor audiences, homelessness, and successful campaigns from other homeless shelters. In addition, an online survey was conducted to test the effectiveness of a public service announcement (PSA) and gather information concerning 7hills’ operations and media interactions. The survey results were used to revise the PSA and make recommendations for the social marketing plan

An exploration of academic advising care groups at an Iowa private college

Care Group advising, as it was institutionally developed, is an academic advising method intended to improve the first year experience of undergraduate college students. The purpose of this study was to explore student perceptions of their participation in Care Group advising, as well as faculty and administrative perceptions. The overarching research question was: How are academic advising Care Groups perceived by students, faculty, and administrators? From the perspectives of students, faculty, and administrators, the following sub-questions served to guide this study: Are academic advising Care Groups serving their intended purpose? What are the perceived benefits of academic advising Care Groups, as identified by the participants? Are academic advising Care Groups contributing to student persistence and retention? This qualitative study utilized focus group interviews with existing academic advising Care Groups, and individual interviews with Care Group advisors and select college administrators. Seven groups of students, six Care Group advisors, and two college administrators were interviewed. Data analysis, with use of the constant comparative method, was ongoing throughout the data collection process. Data analysis revealed several themes relevant to academic advising. Although the implementation of academic advising Care Groups does carry some added responsibility and obligation to the institution and faculty, the benefits may outweigh the identified concerns. Implications for practice related to Care Group advising were also identified. While numerous benefits were recognized by participants, perhaps the most important finding of Care Group advising is that students come to understand that they matter to the College community

Human Anatomy and Physiology I

This Grants Collection for Human Anatomy and Physiology I was created under a Round Two ALG Textbook Transformation Grant. Affordable Learning Georgia Grants Collections are intended to provide faculty with the frameworks to quickly implement or revise the same materials as a Textbook Transformation Grants team, along with the aims and lessons learned from project teams during the implementation process. Documents are in .pdf format, with a separate .docx (Word) version available for download. Each collection contains the following materials: Linked Syllabus Initial Proposal Final Reporthttps://oer.galileo.usg.edu/biology-collections/1004/thumbnail.jp

A comparative post-secondary follow-up study of students served through general education and through special education

This study examines the preparation during high school and post-secondary outcomes of students with disabilities. High school preparation consists of activities in which students participated during high school. Post-secondary outcomes relate to the current status of students following high school graduation in relation to the four major outcomes areas: (a) post-secondary education, (b) employment, (c) independent living, and (d) recreation and leisure. The target population included all students graduating from one school district in a mid-sized city in Texas. A stratified random sample of 228 students both with and without disabilities was selected. Post-secondary follow-up surveys, consisting of one survey administered prior to graduation and one survey administered six-months following graduation, were given to the participants. The response rate for the initial exit survey was 82.9% while the response rate for a post-school survey was 61.4%. Differences between groups were analyzed using loglinear analyses based upon educational setting, disability category, gender, ethnicity, and socio-economic status. In addition, a sub-study was completed to determine the level of agreement among students and teachers on a post-secondary readiness skill inventory. The findings indicated that differences among groups did exist in terms of both high school preparation and post-secondary outcomes. In terms of high school preparation, the participation among various groups produced few results that were significantly different. Statistically significant results occurred only with respect to extracurricular activity participation by educational setting and socio-economic status. Post-secondary outcome results produced more statistically significant findings than high school preparation. The variable of educational setting produced statistically significant post-secondary outcomes in the three areas of employment, post-secondary education, and recreation and leisure. Ethnicity was the next largest determinant to influence post-secondary outcomes, and statistically significant results were found for both post-secondary education and independent living. Socio-economic status produced statistically significant results for employment outcomes. The variable of gender produced no results that reached statistical significance. The last findings provided an analysis of the agreement between students and teachers in terms of a post-secondary readiness skill inventory. Overall students and teachers demonstrated a high level of congruency in which similar responses were indicated within 95% of the items

DCDT fast facts: Teacher hidden bias

A chief barrier hindering the inclusive practices of students with disabilities, specifically those from culturally and linguistically diverse populations (CLD), is the attitude of teachers instructing them (Mullen, 2001). Particularly, these attitudes refer to the hidden biases teachers associate to this population. Research suggests both schools and cultures are becoming more diverse; however, the racial and ethnicity gap is widening relative to teacher (i.e., White) and student (e.g., Black, Native American, Latino) populations (Dingus, 2008; Philip, 2011; Shim, 2018) in the school environment. A substantial body of literature exists examining the impact of White educators’ pedagogical practices perpetuating and supporting racial ideologies in their instruction (e.g., Galman, Pica-Smith, & Rosenberger, 2010; Picower, 2009). Therefore, a need exists for both pre-service, early-career, and veteran teachers to understand the “practical consequences of social, racial, economic and cultural hierarchies; concentrations of power and control; and oppression” (Shim, 2018, p. 127). Simply put, the internalized hidden biases of teachers are hindering the potential of students with disabilities from CLD populations. The purpose of this Division on Career Development and Transition (DCDT) Fast Facts is to illuminate a number of strategies to assist teachers of all backgrounds to overcome their hidden biases toward students with disabilities from CLD populations

Healing With Feeling: Addressing Substance Abuse in Teens During the Covid-19 Pandemic

In recent years, substance abuse among teenagers has steadily increased since the beginning of the Covid-19 pandemic in 2020. Teen substance abuse related deaths have only continued to rise since then; with nationwide substance abuse related deaths being 1,146 in 2021, a sharp increase from the 954 deaths in 2020 (UCLA health, 2022). Teen substance abuse is determined by many factors, such as mental health, home/school environment, etc. In order to cope with these difficult emotions, teenagers turn to drug use to numb the feeling. Studies have shown that art based therapy and afterschool programs are effective in mitigating the risk factors for teen substance abuse (OJJDP, 2016). In accordance with this research, we have decided to utilize the arts (writing, studio art, etc) to prevent adolescents from using drugs to cope with difficult emotions.https://hsrc.himmelfarb.gwu.edu/dchapp/1014/thumbnail.jp

Special Educators Speak Out on Co-Teaching Knowledge and Skills

This study explored practices and attitudes of special educators from various states around the country regarding what they consider to be the most important elements for effective co-teaching. Results indicated that co-planning, communication skills, and shared instruction were the most critical factors in effective co-teaching. Professional development was found to be the most common way that participants gained co-teaching knowledge and skill. Future implications for research suggest that teacher preparation programs and districts use e-learning to support pre-service and in-service programs and initiatives related to co-teaching. Future implications for research suggest that teacher preparation programs and districts use e-learning to support pre-service and inservice programs and initiatives related to co-teaching

Maximizing Access to Medications through Efficient Use of CARE Act Resources

HRSA\u27s HIV/AIDS Bureau (HAB) contracted with the George Washington University to conduct a series of studies regarding various aspects of HIV medications funding through the Ryan White Comprehensive AIDS Resources Emergency (CARE) Act, including the Title II-funded AIDS Drug Assistance Program and Title I-funded AIDS Pharmaceutical Assistance Programs. The goal of the studies was to inform HAB regarding (1) opportunities to promote more efficient use of scarce resources for HIV-related medications and (2) policy options that might ensure equitable access to life-saving therapies for low-income people living with HIV (PLWH). The three key issues addressed and the related study questions are shown in Table 1 on page 3. This report summarizes the methods, limitations, major findings, and recommendations of these studies. The contents of this report are solely the responsibility of the authors and do not necessarily represent the official views of HRSA