Artigos de revistas sobre o tema "Probate Court (Union County)"

In Janus v. American Federation of State, County, and Municipal Employees, the U.S. Supreme Court will determine whether unions can compel non-union members to pay “fair share” fees to offset the cost of collective bargaining. Julie Underwood reviews past Supreme Court cases and state law involving union fees.

On January 7, 2003, Sydney Cowan, a healthy six-year-old girl, underwent skin harvesting, specifically to be used for her badly burned identical twin sister, Jennifer. A day earlier, the Probate Court of Jefferson County, Alabama, after considering whether a healthy minor twin sibling could serve as a skin donor for her severely burned sister, authorized parental consent to the surgery. More accurately, the court addressed whether Sydney could undergo surgical procedures that provided her with no physical benefit, but, rather, resulted in harmful effects, such as acute postoperative pain, permanent residua, and potential long-term emotional and psychological dysfunction.Although the transplants were extraordinarily successful, and the newspaper article depicted Sydney's participation in heroic terms, the harvesting of Sydney's skin was ethically problematic. Specifically, I assert that the use of an incompetent minor as a skin transplant donor, even if an identical twin, is not justified unless the transplant will save the recipient's life.

This paper is devoted to the legal analysis of CJEU Opinion 2/13 on European Union accession to the European Convention on Human Rights. The article examines the CJEU’s approach to the interpretation of Art. 267 and 344 of the Treaty on the Functioning of the European Union — in the light of Protocol No. 16 to the European Convention on Human Rights, as well as the previous case law of the Court of Justice (Mox Plant and Melki and Abdeli). The conclusions are drawn as to the manner in which Opinion 2/13 develops EU legal order autonomy doctrine and how it affects the future perspectives of EU accession to the European Convention on Human Rights. Firstly, while interpreting the content and purpose of Art. 344 TFEU, the CJEU gives a positive answer to the question as to whether the ECHR compliance system falls within the ambit of this Treaty provision. Secondly, the Court of Justice takes an extremely protective approach in giving its interpretation to the role of preliminary rulings procedure guaranteed by Art. 267 TFEU for the unity and efficiency of European law, making even the legal protection of individuals secondary to these purposes. It is quite probable that the accession will be delayed for an indefinite period of time — due to the likely impossibility of reaching a consensus on a new version of the Draft accession agreement with all members of the Council of Europe (such as Russia, Ukraine and Turkey) in the very near future. At the same time, European Union accession to the European Convention on Human Rights remains a legal duty in accordance with Art. 6 Treaty on the European Union (TEU), Declaration No. 2 on Article 6 (2) TEU and Protocol No. 8 to the Lisbon Treaty.

The complicated balance, including the formal system, that regulates patterns of psychotropic drug usage in the Nordic countries is under rapid change. The European Union is the main agent of change. The general public, the politicians, the administrators and health professionals all seem to agree that consumption is too high and the awareness of this problem has been rising in recent years. This coincides with the European integration process. It is suggested in the article that the Nordic tendencies to have a paternalistic “health” regulatory system will be replaced by a “market” organized system, emphasizing free competition, consumer rigths, legal decisions and industry interests. One result will be a larger and unpredictable assortment; another probable result is higher and more complicated structured usage patterns. The old system of national health authorities as the main regulatory actor will be seriously weakened. The challenge of solving the problem of managing and reducing consumption of addictive drugs is difficult, and social regulation must rely on new tools. Local and regional authorities and organizations will have a central role, as well as patient organizations and public and professional debate. The final outcome is unpredictable, but one thing is clear, it will be a significantly different structure.

School boards can enact rules about commenting at their public meetings, but they cannot impede someone’s right to speak, whether employees or the public. A recent federal district court case — Barrett v. Walker County School District (N.D. Ga. 2016) — raised this issue. Jim Barrett, a district employee and president of the local educators’ union, disagreed with the district’s new grading policy and tried to get on the school board agenda to share his concerns. The superintendent, who controlled access to the public comment portion of the meeting, did not approve his requests. The federal district court ruled that this violated Barrett’s First Amendments rights of free speech because it gave the superintendent unfettered discretion to approve, deny, or delay requests to speak before the board and limited the nature of issues that someone could take to the board.

This paper examines the experience of four major public sector unions in Wisconsin since the passage of Wisconsin Act 10 in 2011. The four unions are the American Federation of State, County and Municipal Employees (AFSCME), the American Federation of Teachers (AFT-Wisconsin), the Service Employees International Union (SEIU), and the Wisconsin Education Association Council (WEAC), an affiliate of the National Education Association. Wisconsin’s prior legal framework for public sector collective bargaining is explained and compared to the new highly restrictive framework established by Act 10. That new framework, established by state legislation, is analyzed, as are its impacts on the membership, revenues, structures, and practices of the four unions. In general, we find the impacts to have been very dramatic, with a loss of active union membership averaging approximately 70 percent overall, and concomitant dramatic losses in union revenues and power. These shocks have engendered the restructuring of two of the unions examined, the downsizing of the third, and the de facto exiting from the state’s public sector in another. There have also been significant changes in representation practices in one union, but less so in the others. We conclude by discussing best union practices based on this experience, as well as considering what the recent public sector union history in Wisconsin may portend for public worker union membership nationwide, since the issuing of the Janus Decision by the U.S. Supreme Court.

Research on victims' encounters with prosecutors suggests that victims' rights have had a limited effect on victims' satisfaction with the criminal justice system. This study examines the victim-prosecutor relationship with a focus on people who have lost a loved one to murder. The emotional tone dimension of Carol Heimer's case versus biography analysis proves helpful for explaining the gaps between prosecutors' responsibilities and victims' expectations. The data come from in-depth interviews with thirty-five participants, including twenty victims, three crime victims' advocates, and twelve criminal court professionals in Union County (pseudonym). The findings indicate that shared emotions (e.g., sadness, anger) represent a key mechanism for (1) connecting victims to prosecutors (and individuals to organizations) and (2) improving victims' experiences with the criminal justice system. Although victims' rights do not guarantee the opportunity for shared emotions, prosecutors often honored victims' desire for a close relationship and considered their input on case decisions.

On February 8, 2010, eleven student activists at the University of California–Irvine protested a speech by Michael Oren, Israel’s ambassador to the United States. The disruptive nature of the protest by these students—advocates of Palestinian de-occupation and members of the Muslim Student Union—led to disciplinary action against their student organization and criminal prosecution in the local county court for disturbing the peace. This essay offers the results of an interview-based study exploring the rhetorical education of five of these college activists. The interviews reveal the powerful influence of family histories of activism and thoughtful reflections on the rhetorical dynamics of the Middle East conflict within local, national, and international publics. They also show student awareness of the limitations of the liberal-deliberative rhetorics that underpin most college writing courses. That students reported only a tenuous sense of connection between college courses and self-sponsored activist education suggests that teachers and scholars of rhetoric and composition may need to give cocurricular activism more consideration in the next phase of the “social turn.”

The aim of this article is to study the activities of the Line Court of the Yenisei and then the East Siberian Basin in the period from the transformation of transport tribunals into line courts until the death of Joseph Stalin. Hence, the lower limit of the chronological framework of the article is determined by the year 1948, when transport justice authorities were demilitarized, and the upper limit by the end of the first quarter of 1953. The source base for the study was documents from collections of the State Archive of Krasnoyarsk Oblast and published research papers. Employees of water transport and related enterprises were under the jurisdiction of the Line Court. In the third quarter of 1948, 101 cases were received in the Line Court of the Yenisei Basin, 61 of them were initiated by the Decree of June 26, 1940. Line courts of water basins had to consider cases typical for water transport and cases typical for courts of general jurisdiction. This is shown by the judicial practice of the Line Court of the Yenisei Basin in the first and second quarters of 1949. The Line Court considered cases of theft of goods, which were initiated under the Decrees of June 4, 1947, On Criminal Liability for Theft of State and Public Property and On Strengthening the Protection of Citizens' Personal Property. From April 1, 1949, to April 1, 1950, the Line Court received 123 cases, including 9 cases of theft of personal property. From April 1, 1949, to April 1, 1950, the Line Court received 11 cases about accidents with 13 people, and 5 cases about other violations of discipline in transport for 6 people. All these crimes fell under Article 59-3 “b” of the Criminal Code of the Russian Soviet Federative Socialist Republic (violation of labor discipline by transport workers (violation of traffic rules, substandard repairs, etc.). The Line Court rarely had to consider cases of “counter-revolutionary” crimes. From April 1, 1949, to April 1, 1950, the Line Court received 8 cases initiated under Article 58 of the Criminal Code of the RSFSR. On the merits, 5 cases were considered, 5 people were convicted on them. Based on this research, the authors came to the conclusion that the peculiarity of linear courts was that these instances considered both cases that were in the jurisdiction of people's courts, and those of regional courts and courts of autonomous republics. Therefore, it was necessary to send cassation appeals on cases of the first category directly to the Supreme Court of the USSR, whereas sentences handed down by people's courts could undergo a long way through the county or regional court, the Supreme Court of the Union Republic and the Supreme Soviet of the USSR. This practice violated the rights of transport workers, since the possibility of reviewing the sentence was difficult for them.

AbstractIn this article, I examine how conflicts over transgender bathroom rights have ignited debates concerning the fundamental nature of transgender identity. Through an institutional and discursive analysis of North Carolina's House Bill 2 or “bathroom bill,” the Title IX case inGloucester County School Board v. G. G.,and similar federal court cases, I explore how and why forces both on the right and in the LGBTQ movement have come to rely on scientific expertise to legitimate their conceptions. As conservatives have marshaled evidence to challenge notions that transgender identity is innate, LGBTQ and transgender organizations as well as the American Civil Liberties Union have crafted a “born this way” biopolitical construction of transgender identity. I find that at their core, these conflicts are over the meanings of gender and sex in relation to transgender identity. Conservatives posit sex as biologically rooted and gender as a psychological phenomenon, whereas transgender advocates subsume gender identity into the definition of sex in arguing that constitutional and federal civil rights law must recognize gender identity as a biologically constitutive element of sex. I conclude by noting the limits of a liberal assimilationist and litigation-centric transgender politics and by exploring alternatives to this biopolitical form of transgender political identity.

On 29 April 2021, the Court of Justice of the European Union in Case C 383/19 passed a preliminary ruling on the interpretation of Article 3 of Directive 2009/103/EC of the European Parliament and of the Council of 16 September 2009 on insurance against civil liability in respect of the use of motor vehicles and the enforcement of the obligation to insure against such liability. This judgment is of key importance for Polish insurance industry, especially for maintaining the coherence of the compulsory insurance system of motor liability insurance for motor vehicle owners for damage caused by the use of their vehicles. The social function of this obligatory insurance is inextricably linked with the protection of third parties against the effects of frequent adverse incidents resulting from the use of motor vehicles in the modern world. What is more, a compulsory insurance contract ought not to be treated as a financial burden for vehicle owners, because it both protects possible perpetrators of motor accidents from serious financial charges and prevents an excessive depletion of their assets due to civil liability. The above-mentioned judgment concerns the confirmation of the principle that in the current Polish legal system there is no possibility of either ignoring the obligation to conclude a civil liability insurance contract or being exempt from such obligation, where the owner is not able to use the vehicle for some period owing to its technical condition.

The battles for the liberation of Oradia and Bihor from the Hortyst-German occupation involved a number Romanian Army divisions (the 3rd Mountain Brigade and Tudor Vladimirescu Brigade), as well as divisions of the Red Army and were particularly ferocious and long-lasting (5 September - 12 October 1944). Several offensives and counter-offensives of the Hungarian-German and Romanian-Soviet military divisions took place with the purpose of preserving/liberating the city of Oradea, the administrative centre of Bihor County, a critical land and air communications hub for the entire western region (roads, railways, airport). In the battles for Oradea, the region experienced several days of power vacuum, with the fascist troops retreating from the city in order to prepare for a counter-offensive, while the Romanian-Soviet troops were regrouping outside the city for a decisive offensive (25 September - 28 September). At the same time, three citizens of the city, i.e. Andrei Silviu – a Romanian ethnic, a former civil servant with the City Hall and reserve officer of the Romanian Army, who had a local Israeli wife, Nicolae Rajkovič - a Romanian citizen of Serbian origin who was a local barber, and Papp Tibor – a civil servant with the City Hall, a Romanian citizen of Hungarian origin, established a “civil guard” comprising 45 citizens of Oradea with different nationalities, who were armed with rifles from a City Hall warehouse. The role of the guard was to maintain peace in the city and to defend the life and property of the citizens, primarily the workshops and shops in the city against the lumpenproletariat who were prone to looting. The return of fascist occupiers in the city leads to the arrest of the three guard organisers. They are brought in front of a military court and sentenced to death for organising “partisan troops behind the front”. Andrei and Rajkovič are shot in the Oradia Fortress three days before (9 October) the liberation of the city (12 October), while Papp is saved by his family and sentenced to 15 years in prison, due to the fact that he was a Hungarian ethnic. Although historians and patriotic local councillors proposed (in 2007, 2013, 2015, and 2020) that the two murdered locals should be honoured as heroes of the city, the political parties or coalitions that held the majority in the Oradea City Council (the Democratic Party (PD) + the Democratic Union of Hungarians in Romania (UDMR), the National Liberal Party (PNL) + the Democratic Union of Hungarians in Romania (UDMR)) kept rejecting the initiative. This year, several cultural and patriotic organisations will bring up the proposal once again, since the idea behind it still makes a valid point.

The ideologised treatment of history in the Soviet period celebrated communists who had perished or been executed in the interwar Republic of Estonia as martyrs. They fit in to the narrative of class struggle and its victims. Monuments were erected in their memory and memorial articles appeared in the press on anniversaries of their birth. One such communist featured during the Soviet period was Hans Heidemann (1896–1925), a trade unionist and member of the parliament of the Republic of Estonia, and also an underground Estonian Communist Party activist. He was arrested as one of the ringleaders in the attempt to overthrow the government on 1 December 1924 and executed in 1925 as a spy for Soviet Russia by decision of a military district court. This article relies primarily on archival materials from the Estonian National Archives. It is an attempt to write a political biography of Hans Heidemann that for the first time aims to more closely examine the course of the life of this individual who has been ideologised many times over. His room for manoeuvring and his possible influences in the space in which he operated are reconstructed. The article examines how this man of modest background but with a relatively good education, a veteran of the Estonian War of Independence who served as a staff clerk, became an activist in the trade union movement, a communist, and eventually an organiser of a coup d’état. It also considers why Heidemann was the only one at the subsequent major trial of communists in 1925 to be sentenced to death. An important context for Heidemann’s rise in politics is the struggle for control in the trade unions that took place in the early 1920s among Estonia’s left-wing parties. While the communists dominated the trade unions of industrial workers in the cities, they had to compete with social democrats and independent socialists for control in unions of rural workers. Southern Estonia and the City of Tartu formed a more problematic operating region than the average district, as in 1920–21 the Security Police had liquidated many large communist networks there. Heidemann was a member of the Party of Independent Socialists but when in 1922 the party was taken over by its communist-oriented left wing, he started gravitating towards the underground communists. At that time, the communists needed able organisers in order to regain their positions in Southern Estonia and it seems that they pinned their hopes on Heidemann. In 1922 Heidemann rose to leading positions in the trade union organisations of both Tartu County and the City of Tartu, and also became one of the leaders of the left wing of the Party of Independent Socialists. It is not clear, however, whether Heidemann had officially joined the Estonian Communist Party, or functioned as its legal operative. In January of 1924, when the Security Police arrested many trade union leaders and political activists associated with the communists, Heidemann went underground. Over the next eight months, he attempted to obtain weapons for overthrowing the government and to form combat squads mainly on the basis of youth organisations. He was unable to participate in the attempted communist coup d’état on 1 December since he had been arrested two months earlier in Tartu. But his trial was held under changed conditions after the failed coup. By that time, the Protection of the System of Government Act had been passed and the communists had been expelled from parliament. Even though Heidemann had been charged with working as a leader of the local organisation of the underground Communist Party and forming combat squads for the planned coup, he was sentenced to death and executed on the grounds of the charge for which there was least evidence. According to this charge, he had allegedly gathered military information for the Soviet Union as a soldier in the War of Independence six years earlier. Different sources suggest that this charge was questionable and unconvincing. It seems that there was a wish to convict Heidemann as the head of the regional communist organisation no matter what, and to punish him as harshly as the actual participants in the failed coup were punished, which the other counts of indictment did not allow.

The article examines the peculiarities of the genesis and further development of constitutional and legal responsibility in the Ukrainian lands in the Lithuanian- Polish era. The author’s conviction that during the Lithuanian-Polish period in the Ukrainian lands the main administrative tendencies and sources of law of this period influenced the formation and development of the institution of constitutional and legal responsibility in the Ukrainian lands. To such features of the investigated type of responsibility, it is necessary to carry a number of features. The first of them was a combination of centralization and decentralization in the field of positive constitutional and legal responsibility and the implementation of state policy between the Grand Duke of Lithuania and local princes in the fourteenth century. In this case, the relationship between the Grand Duke and local princes were vassal. Local princes had broad autonomy in internal affairs, but, at the request of the Grand Duke, had to participate in military campaigns with his army and pay tribute. Thus, the centralizing tendencies of responsibility concerned the Grand Duke of Lithuania and were reduced to positive responsibility for the military-defence sphere and national taxes. As for the decentralization principles of responsibility, it was the sphere of local princes, which was reduced to broad internal powers in the lands under their control. The second significant feature was the centralization of power and the growing role of constitutional and legal responsibility of the Grand Duke during the fifteenth century with a simultaneous narrowing of the powers and responsibilities of local princes. In particular, the Privilege of 1434 finally consolidated the loss of state rights of local princes and turned them into subjects of the Grand Duke. The third feature was the redistribution of the principles of positive constitutional and legal responsibility based on caste-representative principles, the priority of collegial (collective) responsibility over individual. This was manifested in the fact that at the end of the fifteenth century. Century expanded the competence of the lords of the council, which was formed of the most influential vassals of the Grand Duke (princes, magnates, boyars, lords, including Ukrainian, church hierarchs) and acted initially as an advisory body. In particular, under the privilege of 1492, the prince decided the most important state affairs together with the gentlemen-advisers. This included issues of foreign policy, the issuance and repeal of laws, the appointment and dismissal of senior government officials, the implementation of expenditures from the state treasury, court decisions. The privilege of 1506 further strengthened the legal position of the council. Now, if the opinions of the gentlemen-advisers did not coincide with the views of the prince, the latter had to obey the council. In the absence of the Grand Duke, the council was to govern all domestic and foreign policy - with the right to declare war, inclusive. The Lithuanian Statute of 1529 recognized the Great Free Seimas as a state body. The formation of the Seimas, as a representative parliamentary body, lasted until the middle of the sixteenth century. If at first local administrators-govemors with several nobles came to the Diet, then from 1564 the nobility began to elect two representatives from the county to the Diet. The fourth feature of the period under study was the expansion of powers and constitutional liability of the Seim of the Commonwealth for legislative activities and international relations, while reducing the scope of such responsibility for the King of the Commonwealth under the Union of Lublin in 1569.

Five days after the U.S. Supreme Court handed down its ruling in Endrew F. v. Douglas County School District, the U.S. Court of Appeals for the Ninth Circuit issued a decision in M.C. v. Antelope Valley Union High School District. This important decision involved a student who was being served under the Individuals with Disabilities Education Act (IDEA). The student was blind and required a high level of support in all academic areas. The case addressed important issues regarding parental participation throughout the Individualized Education Program (IEP) process and the school district’s obligation to implement the IEP. This column (a) examines this decision by providing the facts of the case, including the decisions at the due process hearing level, U.S. district court, and U.S. Court of Appeals; (b) explores the ruling by the court of appeals decision; and (c) discusses implications of this decision for special education administrators and teachers.

Background: Curiosity and need are the major forces driving invention and discoveries. The covid-19 said to originated from Wuhan of Hubei province in china have raised so many questions and doubts about origin and spread of disease and the controversy is still going on. The geographical location of Wuhan in relation to sea is of significant value in relation to covid-19 pandemic as observed in this research. The city of Wuhan is located on both banks of the Changjiang (the Great River, a.k.a the Yangtze River) about six hundred miles upstream from Shanghai and the Pacific Ocean. It is about four hundred miles upstream from Nanjing. Its location is supremely strategic, being where the Hanshui (Han River) joins the Changjiang. The Wuhan Huanan Seafood Wholesale Market was in news and highlighted by several media and news agency as probable source of origin of covid-19. The Huanan Seafood Market located in Wuhan was a live animal and seafood market in Jianghan District, Wuhan City, and the capital of Hubei Province in Central China. My research aimed to assess the impact of geographical locations particularly coastal influence on the total/average/maximum/minimum confirmed cases and deaths from COVID-19/SARS-CoV-2 pandemic in 36 states and union territories of India, during COVID-19 pandemic from the beginning of pandemic cases in January 2020 in India with special focus on coastal states and union territories of India. The coast is also known popularly as the coastline or seashore is the area where land meets the sea or ocean, or as a line that forms the boundary between the land and the ocean. The term coastal state and union territories is used to refer to a state where interactions of sea and land of states occur. The study also aims to find safest geographical location in covid-19 pandemic. Methods: The information on the number of cases and deaths due to COVID-19 pandemic in 36 states and union territories of India was obtained from Health Department, Ministry of Health and Family Welfare (MoHFW), Government of India, and data were matched and analyzed from online websites as well. The impact of geographical locations on the total/average/maximum/ minimum confirmed cases and deaths from COVID-19/SARS-CoV-2 pandemic in 36 states and union territories of India was analyzed with Microsoft office and stata 15.1 for windows (64bit) will be used with Microsoft office in next version-2 of article for epidemiological comparison by calculating incidence, prevalence, mortality rate and other indicators. The study for global correlation of this research is also under process by the author. For the purpose of research India is divided into four geographical areas, 1 Coastal states and union territories (total ten in numbers), 2 Island groups (three in numbers), 3 north eastern states and east area i.e. Laddakh 4 other states and union territories having plain areas (14 in numbers). Results: The findings showed that total numbers of death from covid-19 is highest in coastal states and union territories with a count of 240628 since beginning of the pandemic whereas the islands group reported the lowest total numbers of death from covid-19. The average death from covid-19 is highest in coastal states and union territories group with a count of 24062.8 followed by other states and union territories group with a count of 9754.07. The islands group reported the lowest average numbers of death from covid-19 with a count of 58.67. A similar trend was found for numbers of confirmed cases with coastal states on top having largest number of covid-19 cases. Conclusions: The research observation found that coastal states and union territories of India have larger number of daily cases of COVID-19 and mortality as compared to other geographical locations of the country. The observation also found that islands have least number of cases and deaths due to covid-19 pandemic. This study also gives rise to hypothesis that coastal locations are at greater risk of covid-19 infection and mortality whereas islands are safe places in covid-19 pandemics.

Photo by niu niu on Unsplash ABSTRACT Shackling prisoners has been implemented as standard procedure when transporting prisoners in labor and during childbirth. This procedure ensures the protection of both the public and healthcare workers. However, the act of shackling pregnant prisoners violates the principles of ethics that physicians are supposed to uphold. This paper will explore how shackling pregnant prisoners violates the principle of justice and beneficence, making the practice unethical. INTRODUCTION Some states allow shackling of incarcerated pregnant women during transport and while in the hospital for labor and delivery. Currently, only 22 states have legislation prohibiting the shackling of pregnant women.[1] Although many states have anti-shackling laws prohibiting restraints, these laws also contain an “extraordinary circumstances” loophole.[2] Under this exception, officers shackle prisoners if they pose a flight risk, have any history of violence, and are a threat to themselves or others.[3] Determining as to whether a prisoner is shackled is left solely to the correctional officer.[4] Yet even state restrictions on shackling are often disregarded. In shackling pregnant prisoners during childbirth, officers and institutions are interfering with the ability of incarcerated women to have safe childbirth experiences and fair treatment. Moreover, physicians cannot exercise various ethical duties as the law constrains them. In this article, I will discuss the physical and mental harms that result from the use of restraints under the backdrop of slavery and discrimination against women of color particularly. I argue that stereotypes feed into the phenomenon of shackling pregnant women, especially pregnant women of color. I further assert that shackling makes it difficult for medical professionals to be beneficent and promote justice. BACKGROUND Female incarceration rates in the United States have been fast growing since the 1980s.[5] With a 498 percent increase in the female incarceration population between 1981 and 2021, the rates of pregnancy and childbirth by incarcerated people have also climbed.[6],[7] In 2021, over 1.2 million women were incarcerated in the United States.[8] An estimated 55,000 pregnant women are admitted to jails each year.[9],[10] Many remain incarcerated throughout pregnancy and are transported to a hospital for labor and delivery. Although the exact number of restrained pregnant inmates is unclear, a study found that 83 percent of hospital prenatal nurses reported that their incarcerated patients were shackled.[11] I. Harms Caused by Shackling Shackling has caused many instances of physical and psychological harm. In the period before childbirth, shackled pregnant women are at high risk for falling.[12] The restraints shift pregnant women’s center of gravity, and wrist restraints prevent them from breaking a fall, increasing the risk of falling on their stomach and harming the fetus.[13] Another aspect inhibited by using restraints is testing and treating pregnancy complications. Delays in identifying and treating conditions such as hypertension, pre-eclampsia, appendicitis, kidney infection, preterm labor, and especially vaginal bleeding can threaten the lives of the mother and the fetus.[14] During labor and delivery, shackling prevents methods of alleviating severe labor pains and giving birth.[15] Usually, physicians recommend that women in labor walk or assume various positions to relieve labor pains and accelerate labor.[16] However, shackling prevents both solutions.[17] Shackling these women limits their mobility during labor, which may compromise the health of both the mother and the fetus.[18] Tracy Edwards, a former prisoner who filed a lawsuit for unlawful use of restraints during her pregnancy, was in labor for twelve hours. She was unable to move or adjust her position to lessen the pain and discomfort of labor.[19] The shackles also left the skin on her ankles red and bruised. Continued use of restraints also increases the risk of potentially life-threatening health issues associated with childbirth, such as blood clots.[20] It is imperative that pregnant women get treated rapidly, especially with the unpredictability of labor. Epidural administration can also become difficult, and in some cases, be denied due to the shackled woman’s inability to assume the proper position.[21] Time-sensitive medical care, including C-sections, could be delayed if permission from an officer is required, risking major health complications for both the fetus and the mother.[22] After childbirth, shackling impedes the recovery process. Shackling can result in post-delivery complications such as deep vein thrombosis.[23] Walking prevents such complications but is not an option for mothers shackled to their hospital beds.[24] Restraints also prevent bonding with the baby post-delivery and the safe handling of the baby while breast feeding.[25] The use of restraints can also result in psychological harm. Many prisoners feel as though care workers treat them like “animals,” with some women having multiple restraints at once— including ankles, wrists, and even waist restraints.[26] Benidalys Rivera describes the feeling of embarrassment as she was walking while handcuffed, with nurses and patients looking on, “Being in shackles, that make you be in stress…I about to have this baby, and I’m going to go back to jail. So it’s too much.”[27] Depression among pregnant prisoners is highly prevalent. The stress of imprisonment and the anticipation of being separated from their child is often overwhelming for these mothers.[28] The inhumane action has the potential to add more stress, anxiety, and sadness to the already emotionally demanding process of giving birth. Shackling pregnant prisoners displays indifference to the medical needs of the prisoner.[29] II. Safety as a Pretense While public safety is an argument for using shackles, several factors make escape or violence extremely unlikely and even impossible.[30] For example, administering epidural anesthesia causes numbness and eliminates flight risk.[31] Although cited as the main reason for using shackles, public safety is likely just an excuse and not the main motivator for shackling prisoners. I argue that underlying the shackling exemplifies the idea that these women should not have become pregnant. The shackling reflects a distinct discrimination: the lawmakers allowing it perhaps thought that people guilty of crimes would make bad mothers. Public safety is just a pretense. The language used to justify the use of restraint of Shawanna Nelson, the plaintiff in Nelson v. Correctional Medical Services, discussed below, included the word “aggressive.”[32] In her case, there was no evidence that she posed any danger or was objectively aggressive. Officer Turnesky, who supervised Nelson, testified that she never felt threatened by Nelson.[33] The lack of documented attempts of escape and violence from pregnant prisoners suggests that shackling for flight risk is a false pretense and perhaps merely based on stereotypes.[34] In 2011, an Amnesty International report noted that “Around the USA, it is common for restraints to be used on sick and pregnant incarcerated women when they are transported to and kept in hospital, regardless of whether they have a history of violence (which only a minority have) and regardless of whether they have ever absconded or attempted to escape (which few women have).”[35] In a 2020 survey of correctional officers in select midwestern prisons, 76 percent disagreed or strongly disagreed with restraining pregnant women during labor and delivery.[36] If a correctional officer shackles a pregnant prisoner, it is not because they pose a risk but because of a perception that they do. This mindset is attributed to select law enforcement, who have authority to use restraints.[37] In 2022, the Tennessee legislature passed a bill prohibiting the use of restraints on pregnant inmates. However, legislators amended the bill due to the Tennessee Sherriff Association’s belief that even pregnant inmates could pose a “threat.”[38] Subjecting all prisoners to the same “precautions” because a small percentage of individuals may pose such risks could reflect stereotyping or the assumption that all incarcerated people pose danger and flight risk. To quell the (unjustified) public safety concern, there are other options that do not cause physical or mental harm to pregnant women. For example, San Francisco General Hospital does not use shackles but has deputy sheriffs outside the pregnant women’s doors.[39] III. Historical Context and Race A. Slavery and Post-Civil War The treatment of female prisoners has striking similarities to that of enslaved women. Originally, shackling of female slaves was a mechanism of control and dehumanization.[40] This enabled physical and sexual abuses. During the process of intentionally dehumanizing slaves to facilitate subordination, slave owners stripped slave women of their feminine identity.[41] Slave women were unable to exhibit the Victorian model of “good mothering” and people thought they lacked maternal feelings for their children.[42] In turn, societal perception defeminized slave women, and barred them from utilizing the protections of womanhood and motherhood. During the post-Civil War era, black women were reversely depicted as sexually promiscuous and were arrested for prostitution more often than white women.[43] In turn, society excluded black women; they were seen as lacking what the “acceptable and good” women had.[44] Some argue that the historical act of labeling black women sexually deviant influences today’s perception of black women and may lead to labeling them bad mothers.[45] Over two-thirds of incarcerated women are women of color.[46] Many reports document sexual violence and misconduct against prisoners over the years.[47] Male guards have raped, sexually assaulted, and inappropriately touched female prisoners. Some attribute the physical abuse of black female prisoners to their being depicted or stereotyped as “aggressive, deviant, and domineering.”[48] Some expect black women to express stoicism and if they do not, people label them as dangerous, irresponsible, and aggressive.[49] The treatment of these prisoners mirrors the historical oppression endured by black women during and following the era of slavery. The act of shackling incarcerated pregnant women extends the inhumane treatment of these women from the prison setting into the hospital. One prisoner stated that during her thirty-hour labor, while being shackled, she “felt like a farm animal.”[50] Another pregnant prisoner describes her treatment by a guard stating: “a female guard grabbed me by the hair and was making me get up. She was screaming: ‘B***h, get up.’ Then she said, ‘That is what happens when you are a f***ing junkie. You shouldn’t be using drugs, or you wouldn’t be in here.”[51] Shackling goes beyond punishing by isolation from society – it is an additional punishment that is not justified. B. Reproductive Rights and “Bad Mothers” As with slaves not being seen as maternal, prisoners are not viewed as “real mothers.” A female prison guard said the following: “I’m a mother of two and I know what that impulse, that instinct, that mothering instinct feels like. It just takes over, you would never put your kids in harm’s way. . . . Women in here lack that. Something in their nature is not right, you know?”[52] This comment implies that incarcerated women lack maternal instinct. They are not in line with the standards of what society accepts as a “woman” and “mother” and are thought to have abandoned their roles as caretakers in pursuit of deviant behaviors. Without consideration of racial discrimination, poverty issues, trauma, and restricted access to the child right after delivery, these women are stereotyped as bad mothers simply because they are in prison. Reminiscent of the treatment of female black bodies post-civil war and the use of reproductive interventions (for example, Norplant and forced sterilization) in exchange for shorter sentences, I argue that shackles are a form of reproductive control. Justification for the use of shackles even includes their use as a “punitive instrument to remind the prisoner of their punishment.”[53] However, a prisoner’s pregnancy should have no relevance to their sentence.[54] Using shackles demonstrates to prisoners that society tolerates childbirth but does not support it.[55] The shackling is evidence that women are being punished “for bearing children, not for breaking the law.”[56] Physicians and healthcare workers, as a result, are responsible for providing care for the delivery and rectifying any physical problems associated with the restraints. The issues that arise from the use of restraints place physicians in a position more complex than they experience with regular healthy pregnancies. C. Discrimination In the case of Ferguson v. City of Charleston, a medical university subjected black woman to involuntary drug testing during pregnancy. In doing so, medical professionals collaborated with law enforcement to penalize black women for their use of drugs during pregnancy.[57] The Court held the drug tests were an unreasonable search and violated the Fourth Amendment. Ferguson v. City of Charleston further reveals an unjustified assumption: the medical and legal community seemed suspicious of black women and had perhaps predetermined them more likely to use drugs while pregnant. Their fitness to become mothers needed to be proven, while wealthy, white women were presumed fit.[58] The correctional community similarly denies pregnant prisoners’ medical attention. In the case of Staten v. Lackawanna County, an African American woman whose serious medical needs were treated indifferently by jail staff was forced to give birth in her cell.[59] This woman was punished for being pregnant in prison through the withholding of medical attention and empathy. IV. Failure to Follow Anti-Shackling Laws Despite 22 states having laws against shackling pregnant prisoners, officers do not always follow these laws. In 2015, the Correctional Association of New York reported that of the 27 women who gave birth under state custody, officers shackled 23 women in violation of the anti-shackling laws.[60] The lawyer of Tracy Edwards, an inmate who officers shackled unlawfully during her twelve-hour labor stated, “I don’t think we can assume that just because there’s a law passed, that’s automatically going to trickle down to the prison.”[61] Even with more restrictions on shackling, it may still occur, partly due to the stereotype that incarcerated women are aggressive and dangerous. V. Constitutionality The Eighth Amendment protects people from cruel and unusual punishment. In Brown vs. Plata, the court stated, “Prisoners retain the essence of human dignity inherent in all persons.”[62] In several cases, the legal community has held shackling to be unconstitutional as it violates the Eighth Amendment unless specifically justified. In the case of Nelson v. Correctional Medical Services, a pregnant woman was shackled for 12 hours of labor with a brief respite while she pushed, then re-shackled. The shackling caused her physical and emotional pain, including intense cramping that could not be relieved due to positioning and her inability to get up to use a toilet.[63] The court held that a clear security concern must justify shackling. The court cited a similar DC case and various precedents for using the Eighth Amendment to hold correctional facilities and hospitals accountable.[64] An Arkansas law similarly states that shackling must be justified by safety or risk of escape.[65] If the Thirteenth Amendment applied to those convicted of crimes, shackling pregnant incarcerated people would be unconstitutional under that amendment as well as the Eighth. In the Civil Rights Cases, Congress upheld the right “to enact all necessary and proper laws for the obliteration and prevention of slavery with all its badges and incidents.”[66] Section two of the Thirteenth Amendment condemns any trace or acts comparable to that of slavery. Shackling pregnant prisoners, stripping them of their dignity, and justification based on stereotypes all have origins in the treatment of black female slaves. Viewed through the lens of the Thirteenth Amendment, the act of shackling would be unconstitutional. Nonetheless, the Thirteenth Amendment explicitly excludes people convicted of a crime. VI. Justice As a result of the unconstitutional nature of shackling, physicians should have a legal obligation, in addition to their ethical duty, to protect their patients. The principle of justice requires physicians to take a stand against the discriminatory treatment of their patients, even under the eye of law enforcement.[67],[68] However, “badge and gun intimidation,” threats of noncompliance, and the fear of losing one’s license can impede a physician’s willingness to advocate for their patients. The American College of Obstetricians and Gynecologists (ACOG) finds the use of physical restraints interferes with the ability of clinicians to practice medicine safely.[69] ACOG, The American Medical Association, the National Commission on Correctional Health Care, and other organizations oppose using restraints on pregnant incarcerated people.[70] Yet, legislators can adopt shackling laws without consultation with physicians. The ACOG argues that “State legislators are taking it upon themselves to define complex medical concepts without reference to medical evidence. Some of the penalties [faced by OBGYNs] for violating these vague, unscientific laws include criminal sentences.”[71] Legislation that does not consider medical implications or discourages physicians’ input altogether is unjust. In nullifying the voice of a physician in matters pertaining to the patient’s treatment, physicians are prevented from fulfilling the principle of justice, making the act of shackling patients unethical. VII. Principle of Beneficence The principle of beneficence requires the prevention of harm, the removal of harm, and the promotion of good.[72] Beneficence demands the physician not only avoid harm but benefit patients and promote their welfare.[73] The American Board of Internal Medicine Foundation states that physicians must work with other professionals to increase patient safety and improve the quality of care.[74] In doing so, physicians can adequately treat patients with the goal of prevention and healing. It is difficult to do good when law enforcement imposes on doctors to work around shackles during labor and delivery. Law enforcement leaves physicians and healthcare workers responsible not only to provide care for the delivery, but also rectify any ailments associated with the restraints. The issues arising from using restraints place physicians in a position more complex than they experience with other pregnancies. Doctors cannot prevent the application of the shackles and can only request officers to take them off the patient.[75] Physicians who simply go along with shackling are arguably violating the principle of beneficence. However, for most, rather than violating the principle of beneficence overtly, physicians may simply have to compromise. Given the intricate nature of the situation, physicians are tasked with minimizing potential harm to the best of their abilities while adhering to legal obligations.[76] It is difficult to pin an ethics violation on the ones who do not like the shackles but are powerless to remove them. Some do argue that this inability causes physicians to violate the principle of beneficence.[77] However, promoting the well-being of their patients within the boundaries of the law limits their ability to exercise beneficence. For physicians to fulfill the principle of beneficence to the fullest capacity, they must have an influence on law. Protocols and assessments on flight risks made solely by the officers and law enforcement currently undermine the physician’s expertise. These decisions do not consider the health and well-being of the pregnant woman. As a result, law supersedes the influence of medicine and health care. CONCLUSION People expect physicians to uphold the four major principles of bioethics. However, their inability to override restraints compromises their ability to exercise beneficence. Although pledging to enforce these ethical principles, physicians have little opportunity to influence anti-shackling legislation. Instead of being included in conversations regarding medical complexities, legislation silences their voices. Policies must include the physician's voice as they affect their ability to treat patients. Officers should not dismiss a physician's request to remove shackles from a woman if they are causing health complications. A woman's labor should not harm her or her fetus because the officer will not remove her shackles.[78] A federal law could end shackling pregnant incarcerated people. Because other options are available to ensure the safety of the public and the prisoner, there is no ethical justification for shackling pregnant prisoners. An incarcerated person is a human being and must be treated with dignity and respect. To safeguard the well-being of incarcerated women and the public, it is essential for advocates of individual rights to join forces with medical professionals to establish an all-encompassing solution. - [1] Ferszt, G. G., Palmer, M., & McGrane, C. (2018). Where does your state stand on shackling of Pregnant Incarcerated Women? Nursing for Women’s Health, 22(1), 17–23. https://doi.org/10.1016/j.nwh.2017.12.005 [2] S983A, 2015-2016 Regular Sessions (N.Y. 2015). https://legislation.nysenate.gov/pdf/bills/2015/S983A [3] Chris DiNardo, Pregnancy in Confinement, Anti-Shackling Laws and the “Extraordinary Circumstances” Loophole, 25 Duke Journal of Gender Law & Policy 271-295 (2018) https://scholarship.law.duke.edu/djglp/vol25/iss2/5 [4] Chris DiNardo (2018) [5] U.S. Bureau of Justice Statistics. 1980. " Prisoners in 1980 – Statistical Tables”. Retrieved April 20, 2023 (https://bjs.ojp.gov/content/pub/pdf/p80.pdf). [6] U.S. Bureau of Justice Statistics. 2022. " Prisoners in 2021 – Statistical Tables”. Retrieved April 20, 2023 (https://bjs.ojp.gov/sites/g/files/xyckuh236/files/media/document/p21st.pdf). [7] U.S. Bureau of Justice Statistics (1980) [8] Sufrin C, Jones RK, Mosher WD, Beal L. Pregnancy Prevalence and Outcomes in U.S. Jails. Obstet Gynecol. 2020;135(5):1177-1183. doi:10.1097/AOG.0000000000003834 [9] Kramer, C., Thomas, K., Patil, A., Hayes, C. M., & Sufrin, C. B. (2022). Shackling and pregnancy care policies in US prisons and jails. Maternal and Child Health Journal, 27(1), 186–196. https://doi.org/10.1007/s10995-022-03526-y [10] House, K. T., Kelley, S., Sontag, D. N., & King, L. P. (2021). Ending restraint of incarcerated individuals giving birth. AMA Journal of Ethics, 23(4). https://doi.org/10.1001/amajethics.2021.364 [11] Goshin, L. S., Sissoko, D. R., Neumann, G., Sufrin, C., & Byrnes, L. (2019). Perinatal nurses’ experiences with and knowledge of the care of incarcerated women during pregnancy and the postpartum period. Journal of Obstetric, Gynecologic & Neonatal Nursing, 48(1), 27–36. https://doi.org/10.1016/j.jogn.2018.11.002 [12] Shackling and separation: Motherhood in prison. (2013). AMA Journal of Ethics, 15(9), 779–785. https://doi.org/10.1001/virtualmentor.2013.15.9.pfor2-1309 [13] King, L. (2018). Labor in chains: The shackling of pregnant inmates. Policy Perspectives, 25, 55–68. https://doi.org/10.4079/pp.v25i0.18348 [14] King, L. (2018). [15] AMA Journal of Ethics (2013) [16] Lawrence, A., Lewis, L., Hofmeyr, G. J., & Styles, C. (2013). Maternal positions and mobility during first stage labour. Cochrane database of systematic reviews, (8). [17] Association of Women’s Health, Obstetric and Neonatal Nurses. (2011). AWHONN position statement: Shackling incarcerated pregnant women. Journal of Obstetric, Gynecologic, & Neonatal Nursing, 40(6), 817–818. doi:10.1111/j.1552-6909.2011.01300.x [18] Ferszt, G. G., Palmer, M., & McGrane, C. (2018). Where does your state stand on shackling of Pregnant Incarcerated Women? Nursing for Women’s Health, 22(1), 17–23. https://doi.org/10.1016/j.nwh.2017.12.005 [19] Thompson, E. (2022, August 30). Woman sues NC state prison system for mistreatment while pregnant. North Carolina Health News. Retrieved March 12, 2023, from https://www.northcarolinahealthnews.org/2022/05/25/woman-sues-nc-state-prison-system-for-mistreatment-while-pregnant/ [20] CBS Interactive. (2019, March 13). Shackling pregnant inmates is still a practice in many states. CBS News. Retrieved March 12, 2023, from https://www.cbsnews.com/news/shackling-pregnant-inmates-is-still-a-practice-in-many-states/ [21] Griggs, Claire Louise. "Birthing Barbarism: The Unconstitutionality of Shackling Pregnant Prisoners." American University Journal of Gender Social Policy and Law 20, no. 1 (2011): 247-271. [22] American Civil Liberties Union. (2012, October 12). ACLU briefing paper: The shackling of pregnant women & girls in U.S ... American Civil Liberties Union (ACLU). https://www.aclu.org/wp-content/uploads/legal-documents/anti-shackling_briefing_paper_stand_alone.pdf [23] King.L (2018) [24] Griggs, Claire Louise (2011) [25] American Civil Liberties Union. (2012) [26] Clarke, J. G., & Simon, R. E. (2013). Shackling and separation: Motherhood in prison. AMA Journal of Ethics, 15(9), 779–785. https://doi.org/10.1001/virtualmentor.2013.15.9.pfor2-1309 [27] Berg, M. D. (2014, April 18). Pregnant prisoners are losing their shackles - The Boston Globe. BostonGlobe.com. Retrieved March 12, 2023, from https://www.bostonglobe.com/magazine/2014/04/18/taking-shackles-off-pregnant-prisoners/7t7r8yNBcegB8eEy1GqJwN/story.html [28] Levi, R., Kinakemakorn, N., Zohrabi, A., Afanasieff, E., & Edwards-Masuda, N. (2010). Creating the bad mother: How the U.S. approach to pregnancy in prisons violates the right to be a mother. UCLA Women's Law Journal, 18(1). https://doi.org/10.5070/l3181017816 [29] Chris DiNardo (2018) [30] Griggs, Claire Louise (2011). [31] Allen, J. E. (2010, October 21). Shackled: Women Behind Bars Deliver in Chains. ABC News. https://abcnews.go.com/Health/WomensHealth/pregnant-shackled-women-bars-deliver-chains/story?id=11933376&page=1 [32] Nelson v. Correctional, 533 F.3d 958 (8th Cir. 2009) [33] Nelson v. Correctional(2009) [34] House, K. T., Kelley, S., Sontag, D. N., & King, L. P. (2021). Ending restraint of incarcerated individuals giving birth. AMA Journal of Ethics, 23(4). https://doi.org/10.1001/amajethics.2021.364 [35] Amnesty International USA. (1999, March). “Not part of my sentence” Violations of the Human Rights of Women in Custody. Amnesty International USA. Retrieved March 12, 2023, from https://www.amnestyusa.org/reports/usa-not-part-of-my-sentence-violations-of-the-human-rights-of-women-in-custody/ [36] Pendleton, V., Saunders, J. B., & Shlafer, R. (2020). Corrections officers' knowledge and perspectives of maternal and child health policies and programs for pregnant women in prison. Health & justice, 8(1), 1. https://doi.org/10.1186/s40352-019-0102-0 [37] Elizabeth Alexander, Unshackling Shawanna: The Battle Over Chaining Women Prisoners during Labor and Delivery, 32 U. ARK. LITTLE ROCK L. REV. 435 (2010). Available at: https://lawrepository.ualr.edu/lawreview/vol32/iss4/1 [38] Hernandez, J. (2022, April 22). More states are restricting the shackling of pregnant inmates, but it still occurs. NPR. Retrieved March 12, 2023, from https://www.npr.org/2022/04/22/1093836514/shackle-pregnant-inmates-tennessee [39] Sufrin, C. (2012, June 24). End practice of shackling pregnant inmates. SFGATE. Retrieved March 12, 2023, from https://www.sfgate.com/opinion/openforum/article/End-practice-of-shackling-pregnant-inmates-3176987.php [40] Mullings, L. (1997). On our own terms: Race, class, and gender in the lives of African American women. Routledge [41] Ocen, Priscilla A., (2011). [42] Ladd-Taylor, M. (1998). "Bad" mothers: The politics of blame in Twentieth-century America. New York Univ. Press. [43] Hine, D. C. (1998). Hine Sight: Black women and the re-construction of American history. Indiana University Press. [44] Baldwin, L. (2019). Excluded from good motherhood and the impact of prison: Motherhood and Social Exclusion, 129–144. https://doi.org/10.2307/j.ctvk12qxr.13 [45] Ocen, Priscilla A., Punishing Pregnancy: Race, Incarceration, and the Shackling of Pregnant Prisoners (October 3, 2011). California Law Review, Vol. 100, 2012, Available at SSRN: https://ssrn.com/abstract=1937872 [46] Johnson, P. C. (2004). Inner lives: Voices of african american women in prison. New York University Press. [47] Thomas, D. Q. (1996). All too familiar: Sexual abuse of women in U.S. state prisons. Human Rights Watch. [48] Ocen, Priscilla A., (2011). [49] Ashley W. The angry black woman: the impact of pejorative stereotypes on psychotherapy with black women. Soc Work Public Health. 2014;29(1):27-34. doi: 10.1080/19371918.2011.619449. PMID: 24188294. [50] CBS Interactive. (2019, March 13). Shackling pregnant inmates is still a practice in many states. CBS News. Retrieved March 12, 2023, from https://www.cbsnews.com/news/shackling-pregnant-inmates-is-still-a-practice-in-many-states/ [51] Guardian News and Media. (2020, January 24). Pregnant and shackled: Why inmates are still giving birth cuffed and bound. The Guardian. Retrieved March 25, 2023, from https://www.theguardian.com/us-news/2020/jan/24/shackled-pregnant-women-prisoners-birth [52] Oparah, J. C. (2015). Birthing justice: Black women, pregnancy, and childbirth. Routledge. [53] Chris DiNardo (2018) [54] Griggs, Claire Louise (2011). [55] Chris DiNardo (2018) [56] Griggs, Claire Louise (2011). [57] Song, Ji Seon, Policing the Emergency Room (June 10, 2021). 134 Harvard Law Review 2646 (2021), Available at SSRN: https://ssrn.com/abstract=3864225 [58] Ocen, Priscilla A., (2011). [59] Staten v. Lackawanna Cnty., No. 4:07-CV-1329, 2008 WL 249988, at *2 (M.D. Pa. Jan. 29, 2008) [60] Lovett, K. (2018, April 9). Pregnant inmates at New York prisons will no longer be shackled under new law. New York Daily News. Retrieved March 12, 2023, from https://www.nydailynews.com/new-york/new-york-pregnant-inmates-no-longer-shackled-article-1.2474021 [61] Thompson, E. (2022, August 30). Woman sues NC state prison system for mistreatment while pregnant. North Carolina Health News. Retrieved March 12, 2023, from https://www.northcarolinahealthnews.org/2022/05/25/woman-sues-nc-state-prison-system-for-mistreatment-while-pregnant/ [62] Brown v. Plata, 563 U.S. 493 (2011) [63] Nelson v. Correctional Medical Serices, et al., Nelson v. Correctional Med. Servs, 583 F.3d 522 (8th Cir. 2009) [64] Nelson citing Women Prisoners of D.C. Dep't of Corr. v. District of Columbia, 877 F.Supp. 634, 668-69 (D.D.C. 1994), modified in part on other grounds, 899 F.Supp. 659 (D.D.C. 1995). [65] Ark. Dep't of Corr. Admin. Reg. 403 § V (1992) [66] Civil Rights Cases, 109 U.S. 3 (1883) [67] Physician charter. ABIM Foundation. (2022, October 18). Retrieved March 10, 2023, from https://abimfoundation.org/what-we-do/physician-charter#:~:text=Principle%20of%20social%20justice.&text=Physicians%20should%20work%20actively%20to,or%20any%20other%20social%20category. [68] Riddick FA Jr. The code of medical ethics of the american medical association. Ochsner J. 2003 Spring;5(2):6-10. PMID: 22826677; PMCID: PMC3399321. [69] American College of Obstetricians and Gynecologists’ Committee on Health Care for Underserved Women (2021). Reproductive Health Care for Incarcerated Pregnant, Postpartum, and Nonpregnant Individuals: ACOG Committee Opinion, Number 830. Obstetrics and gynecology, 138(1), e24–e34. https://doi.org/10.1097/AOG.0000000000004429 [70] American College of Obstetricians and Gynecologists’ Committee on Health Care for Underserved Women (2021). [71] American College of Obstetricians and Gynecologists’ Committee on Health Care for Underserved Women (2021). [72] Beauchamp, T. L., & Childress, J. F. (2019). Principles of Biomedical Ethics. Oxford University Press. [73] Varkey, B. (2020). Principles of clinical ethics and their application to practice. Medical Principles and Practice, 30(1), 17–28. https://doi.org/10.1159/000509119 [74] Medical professionalism in the new millennium: A physician charter. (2002). Annals of Internal Medicine, 136(3), 243. https://doi.org/10.7326/0003-4819-136-3-200202050-00012 [75] Allen, J. E. (2010, October 21). Shackled: Women Behind Bars Deliver in Chains. ABC News. https://abcnews.go.com/Health/WomensHealth/pregnant-shackled-women-bars-deliver-chains/story?id=11933376&page=1 [76] Jonsen, A. R. (2010). The Birth of Bioethics. Oxford University Press. [77] Beauchamp, T. L., & Childress, J. F. (2019). [78] Amnesty International USA. (1999, March). “Not part of my sentence” Violations of the Human Rights of Women in Custody. Amnesty International USA. Retrieved March 12, 2023, from https://www.amnestyusa.org/reports/usa-not-part-of-my-sentence-violations-of-the-human-rights-of-women-in-custody/

The rise of expertise in the lives of women is a complex and prolonged process that began when the old networks through which women had learned from each other were being discredited or destroyed (Ehrenreich and English). Enclosed spaces of expert power formed separately from political control, market logistics and the pressures exerted by their subjects (Rose and Miller). This, however, was not a question of imposing expertise on women and forcing them to adhere to expert proclamations: “the experts could not have triumphed had not so many women welcomed them, sought them out, and … organised to promote their influence” (Ehrenreich and English 28). Women’s continuing enthusiasm for self-help books – and it is mainly women who buy them (Wood) – attests to the fact that they are still welcoming expertise into their lives. This paper argues that a major factor in the popularity of self-help is the reversal of the conventional ‘priestly’ relationship and ethic of confession, in a process of conversion that relies on the enthusiasm and active participation of the reader.Miller and Rose outline four ways in which human behaviour can be transformed: regulation (enmeshing people in a code of standards); captivation (seducing people with charm or charisma); education (training, convincing or persuading people); and conversion (transforming personhood, and ways of experiencing the world so that people understand themselves in fundamentally new ways). Of these four ways of acting upon others, it is conversion that is the most potent, because it changes people at the level of their own subjectivity – “personhood itself is remade” (Miller and Rose 35). While theories of conversion cannot be adequately discussed here, one aspect held in common by theories of religious conversion as well as those from psychological studies of ‘brainwashing’ is enthusiasm. Rambo’s analysis of the stages of religious conversion, for example, includes ‘questing’ in an active and engaged way, and a probable encounter with a passionately enthusiastic believer. Melia and Ryder, in their study of ‘brainwashing,’ state that two of the end stages of conversion are euphoria and proselytising – a point to which I will return in the conclusion. In order for a conversion to occur, then, the reader must be not only intellectually convinced of the truth, but must feel it is an important or vital truth, a truth she needs – in short, the reader must be enthused. The popularity of self-help books coincides with the rise of psy expertise more generally (Rose, "Identity"; Inventing), but self-help putatively offers escape from the experts, whilst simultaneously immersing its readers in expertise. Readers of self-help view themselves as reading sceptically (Simonds), interpretively (Rosenblatt) and resistingly (Fetterly, Rowe). They choose to read books as an educational activity (Dolby), rather than attending counselling or psychotherapy sessions in which they might be subject to manipulation, domination and control by a therapist (Simonds). I have discussed the nature of the advice in relationship manuals elsewhere (Hazleden, "Relationship"; "Pathology"), but the intention of this paper is to investigate the ways in which the authors attempt to enthuse and convert the reader.Best-Selling ExpertiseIn common with other best-selling genres, popular relationship manuals begin trying to enthuse the reader on the covers, which are intended to attract the reader, to establish the professional – or ‘priestly’ – credentials of the author and to assert the merit of the book, presenting the authors as experienced professionally-qualified experts, and advertising their bestseller status. These factors form part of the marketing ‘buzz’ or collective enthusiasm about a particular author or book.As part of the process of establishing themselves in the priestly role, the authors emphasise their professional qualifications and experience. Most authors use the title ‘Dr’ on the cover (Hendrix, McGraw, Forward, Gray, Cowan and Kinder, Schlessinger) or ‘PhD’ after their names (Vedral, DeAngelis, Spezzano). Further claims on the covers include assertions of the prominence of the authors in their field. Typical are DeAngelis’s claim to being “America’s foremost relationships expert,” and Hendrix’s claim to being “the world’s leading marital therapist.” Clinical and professional experience is mentioned, such as Spezzano’s “twenty-three years of counseling experience” (1) and Forward’s experience as “a consultant in many southern California Medical and psychiatric facilities” (iii). The cover of Spezzano’s book claims that he is a “therapist, seminar leader, author, lecturer and visionary leader.” McGraw emphasises his formal qualifications throughout his book, saying, “I had more degrees than a thermometer” (McGraw 6), and he refers to himself throughout as “Dr. Phil,” much like “Dr Laura” (Schlessinger). Facts and SecretsThe authors claim their ideas are based on clinical practice, research, and evidence. One author claims, “In this book, there is a wealth of tried and accurate information, which has worked for thousands of people in my therapeutic practice and seminars over the last two decades” (Spezzano 1). Another claims that he “worked with hundreds of couples in private practice and thousands more in workshops and seminars” and subsequently based his ideas on “research and clinical observations” (Hendrix xviii). Dowling refers to “four years of research … interviewing professionals who work with and study women.” She went to all this trouble because, she assures us, “I wanted facts” (Dowling, dust-jacket, 30).All this is in order to assure the reader of the relevance and build her enthusiasm about the importance of the book. McGraw (226) says he “reviewed case histories of literally thousands and thousands of couples” in order “to choose the right topics” for his book. Spezzano (7) claims that his psychological exercises come from clinical experience, but “more importantly, I have tested them all personally. Now I offer them to you.” This notion of being in possession of important new knowledge of which the reader is unaware is common, and expressed most succinctly by McGraw (15): “I have learned what you know and, more important, what you don't know.” This knowledge may be referred to as ‘secret’ (e.g. DeAngelis), or ‘hidden’ (e.g. Dowling) or as a recent discovery. Readers seem to accept this – they often assume that self-help books spring ‘naturally’ from clinical investigation as new information is ‘discovered’ about the human psyche (Lichterman 432).The Altruistic AuthorOn the assumption that readers will be familiar with other self-help books, some authors find it necessary to explain why they felt motivated to write one themselves. Usually these take the form of a kind of altruistic enthusiasm to share their great discoveries. Cowan and Kinder (xiv) claim that “one of the wonderful, intrinsic rewards of working with someone in individual psychotherapy is the rich and intense relationship that is established, [but] one of the frustrations of individual work is that in a whole lifetime it is impossible to touch more than a few people.” Morgan (26) assures us that “the results of applying certain principles to my marriage were so revolutionary that I had to pass them on in the four lesson Total Woman course, and now in this book.”The authors justify their own addition to an overcrowded genre by delineating what is distinctive about their own book, or what other “books, articles and surveys missed” (Dowling 30) or misinterpreted. Beattie (98-102) devotes several pages to a discussion of Dowling to assert that Dowling’s ‘Cinderella Complex’ is more accurately known as ‘codependency.’ The authors of another book admit that their ideas are not new, but claim to make a unique contribution because they are “writing from a much-needed male point of view” (Cowan and Kinder, back cover). Similarly, Gray suggests “many books are one-sided and unfortunately reinforce mistrust and resentment toward the opposite sex.” This meant that “a definitive guide was needed for understanding how healthy men and women are different,” and he promises “This book provides that vision” (Gray 4,7).Some authors are vehement in attacking other experts’ books as “gripe sessions,” “gobbledegook” (Schlessinger 51, 87), or “ridiculous” (Vedral 282). McGraw (9) writes “it is amazing to me how this country is overflowing with marital therapists, psychiatrists and psychologists, counselors, healers, advice columnists, and self-help authors – and their approach to relationships is usually so embarrassing that I want to turn my head in shame.” His own book, by contrast, will be quite different from anything the reader has heard before, because “it differs from what relationship ‘experts’ tell you” (McGraw 45).Confessions of an Author Because the authors are writing about intimate relationships, they are also keen to establish their credentials on a more personal level. “Loving, losing, learning the lessons, and reloving have been my path” (Carter-Scott 247-248), says one, and another asserts that, “It’s taken me a long time to understand men. It’s been a difficult and often painful journey and I’ve made a lot of mistakes along the way in my own relationships” (DeAngelis xvi). The authors are even keen to admit the mistakes they made in their previous relationships. Gray says, “In my previous relationships, I had become indifferent and unloving at difficult times … As a result, my first marriage had been very painful and difficult” (Gray 2). Others describe the feelings of disappointment with their marriages: We gradually changed. I was amazed to realize that Charlie had stopped talking. He had become distant and preoccupied. … Each evening, when Charlie walked in the front door after work, a cloud of gloom and tension floated in with him. That cloud was almost tangible. … this tension cloud permeated our home atmosphere … there was a barrier between us. (Morgan 18)Doyle (14) tells a similar tale: “While my intentions were good, I was clearly on the road to marital hell. … I was becoming estranged from the man who had once made me so happy. Our marriage was in serious trouble and it had only been four years since we’d taken our vows.” The authors relate the bewilderment they felt in these failing relationships: “My confusion about the psychology of love relationships was compounded when I began to have problems with my own marriage. … we gave our marriage eight years of intensive examination, working with numerous therapists. Nothing seemed to help” (Hendrix xvii).Even the process of writing the relationship manual itself can be uncomfortable: This was the hardest and most painful chapter for me to write, because it hit so close to home … I sat down at my computer, typed out the title of this chapter, and burst into tears. … It was the pain of my own broken heart. (DeAngelis 74)The Worthlessness of ExpertiseThus, the authors present their confessional tales in which they have learned important lessons through their own suffering, through the experience of life itself, and not through the intervention of any form of external or professional expertise. Furthermore, they highlight the failure of their professional training. Susan Forward (4) draws a comparison between her professional life as a relationship counsellor and the “Susan who went home at night and twisted herself into a pretzel trying to keep her husband from yelling at her.” McGraw tells of a time when he was counselling a couple, and: Suddenly all I could hear myself saying was blah, blah, blah. Blah, blah, blah, blah. As I sat there, I asked myself, ‘Has anybody noticed over the last fifty years that this crap doesn’t work? Has it occurred to anyone that the vast majority of these couples aren’t getting any better? (McGraw 6)The authors go to some lengths to demonstrate that their new-found knowledge is unlike anything else, and are even prepared to mention the apparent contradiction between the role the author already held as a relationship expert (before they made their important discoveries) and the failure of their own relationships (the implication being that these relationships failed because the authors themselves were not yet beneficiaries of the wisdom contained in their latest books). Gray, for example, talking about his “painful and difficult” first marriage (2), and DeAngelis, bemoaning her “mistakes” (xvi), allude to the failure of their marriage to each other, at a time when both were already well-known relationship experts. Hendrix (xvii) says: As I sat in the divorce court waiting to see the judge, I felt like a double failure, a failure as a husband and as a therapist. That very afternoon I was scheduled to teach a course on marriage and the family, and the next day, as usual, I had several couples to counsel. Despite my professional training, I felt just as confused and defeated as the other men and women who were sitting beside me.Thus the authors present the knowledge they have gained from their experiences as being unavailable through professional marital therapy, relationship counselling, and other self-help books. Rather, the advice they impart is presented as the hard-won outcome of a long and painful process of personal discovery.Peace and PassionOnce the uniqueness of the advice is established, the authors attempt to enthuse the reader by describing the effects of following it. Norwood (Women 4) says her programme led to “the most rewarding years of my life,” and Forward (10) says she “discovered enormous amounts of creativity and energy in myself that hadn't been available to me before.” Gray (268) asserts that, following his discoveries “I personally experienced this inner transformation,” and DeAngelis (126) claims “I am compassionate where I used to be critical; I am patient where I used to be judgmental.” Doyle (23) says, “practicing the principles described in this book has transformed my marriage into a passionate, romantic union.” Similarly, in discussing the effects of her ideas on her marriage, Morgan (26) speaks of “This brand new love between us” that “has given us a brand new life together.” Having established the success of their ideas and techniques on their own lives, the authors go on to relate stories about their successful application to the lives and relationships of their clients. One author writes that “When I began implementing my ideas … The divorce rate in my practice sharply declined, and the couples … reported a much deeper satisfaction in their marriages” (Hendrix xix). Another claims “Repeatedly I have heard people say that they have benefited more from this new understanding of relationships than from years of therapy” (Gray 7). Morgan, describing the effects of her ‘Total Woman’ classes, says: Attending one of the first classes in Miami were wives of the Miami Dolphin football players … it is interesting to note that their team won every game that next season and became the world champions! … Gals, I wouldn’t dream of taking credit for the Superbowl … (Morgan 188)In case we are still unconvinced, the authors include praise and thanks from their inspired clients: “My life has become exciting and wonderful. Thank you,” writes one (Vedral 308). Gray (6) talks of the “thousands of inspirational comments that people have shared” about his advice. Vedral (307) says “I have received thousands of letters from women … thanking me for shining a beam of light on their situations.” If these clients have transformed their lives, the authors claim, so can the reader. They promise that the future will be “exceptional” (Friedman 242) and “wonderful” (Norwood, Women 257). It will consist of “self fulfilment, love, and joy” (Norwood, Women 26), “peace and joy” (Hendrix xx), “freedom and a lifetime of healing, hope and happiness” (Beattie), “peace, relief, joy, and passion that you will never find any other way” (Doyle 62) – in short, “happiness for the rest of your life” (Spezzano 77).SummaryIn order to effect the conversion of their readers, the authors seek to create enthusiasm about their books. First, they appeal to the modern tradition of credentialism, making claims about their formal professional qualifications and experience. This establishes them as credible ‘priests.’ Then they make calculable, factual, evidence-based claims concerning the number of books they have sold, and appeal to the epistemological authority of the methodology involved in establishing the findings of their books. They provide evidence of the efficacy of their own unique methods by relating the success of their ideas when applied to their own lives and relationships, and those of their clients and their readers. The authors also go to some lengths to establish that they have personal experience of relationship problems, especially those the reader is currently presumed to be experiencing. This establishes the ‘empathy’ essential to Rogerian therapy (Rogers), and an informal claim to lay knowledge or insight. In telling their own personal stories, the authors establish an ethic of confession, in which the truth of oneself is sought, unearthed and revealed in “the infinite task of extracting from the depths of oneself, in between the words, a truth which the very form of the confession holds out like a shimmering mirage” (Foucault, History 59). At the same time, by claiming that their qualifications were not helpful in solving these personal difficulties, the authors assert that much of their professional training was useless or even harmful, suggesting that they are aware of a general scepticism towards experts (cf. Beck, Giddens), and share these doubts. By implying that it is other experts who are perhaps not to be trusted, they distinguish their own work from anything offered by other relationship experts, thereby circumventing “the paradox of self-help books’ existence” (Cheery) and proliferation. Thus, the authors present their motives as altruistic, whilst perhaps questioning the motives of others. Their own book, they promise, will be the one (finally) that brings a future of peace, passion and joy. Conversion, Enthusiasm and the Reversal of the Priestly RelationshipAlthough power relations between authors and readers are complex, self-help is evidence of power in one of its most efficacious forms – that of conversion. This is a relationship into which one enters voluntarily and enthusiastically, in the name of oneself, for the benefit of oneself. Such power enthuses, persuades, incites, invites, provokes and entices, and it is therefore a strongly subjectifying power, and most especially so because the relationship of the reader to the author is one of choice. Because the reader can choose between authors, and skip or skim sections, she can concentrate on the parts of the therapeutic diagnosis that she believes specifically apply to her. For example, Grodin (414) found it was common for a reader to attach excerpts from a book to a bathroom mirror or kitchen cabinet, and to re-read and underline sections of a book that seemed most relevant. In this way, through her enthusiastic participation, the reader becomes her own expert, her own therapist, in control of certain aspects of the encounter, which nonetheless must always take place on psy terms.In many conversion studies, the final stage involves the assimilation and embodiment of new practices (e.g. Paloutzian et al. 1072), whereby the convert employs or utilises her new truths. I argue that in self-help books, this stage occurs in the reversal of the ‘priestly’ relationship. The ‘priestly’ relationship between client and therapist, is one in which in which the therapist remains mysterious while the client confesses and is known (Rose, "Power"). In the self-help book, however, this relationship is reversed. The authors confess their own ‘sins’ and imperfections, by relating their own disastrous experiences in relationships and wrong-thinking. They are, of course, themselves enthusiastic converts, who are enmeshed within the power that they exercise (cf. Foucault History; Discipline), as these confessions illustrate. The reader is encouraged to go through this process of confession as well, but she is expected to do so privately, and to play the role of priest and confessor to herself. Thus, in a reversal of the priestly relationship, the person who ‘is knowledge’ within the book itself is the author. It is only if the reader takes up the invitation to perform for herself the priestly role that she will become an object of knowledge – and even then, only to herself, albeit through a psy diagnostic gaze provided for her. Of course, this instance of confession to the self still places the individual “in a network of relations of power with those who claim to be able to extract the truth of these confessions through their possession of the keys to interpretation” (Dreyfus and Rabinow 174), but the keys to interpretation are provided to the reader by the author, and left with her for her own safekeeping and future use. As mentioned in the introduction, conversion involves questing in an active and engaged way, and may involve joy and proselytising. Because the relationship must be one of active participation, the enthusiasm of the reader to apply these truths to her own self-understanding is critical. Indeed, the convert is, by her very nature, an enthusiast.ConclusionSelf-help books seek to bring about a transformation of subjectivity from powerlessness to active goal-setting, personal improvement and achievement. This is achieved by a process of conversion that produces particular choices and types of identity, new subjectivities remade through the production of new ethical truths. Self-help discourses endow individuals with new enthusiasms, aptitudes and qualities – and these can then be passed on to others. Indeed, the self-help reader is invited, by means of the author’s confessions, to become, in a limited way, the author’s own therapist – ie, she is invited to perform an examination of the author’s (past) mistakes, to diagnose the author’s (past) condition and to prescribe an appropriate (retrospective) cure for this condition. Through the process of diagnosing the author and the author’s clients, using the psy gaze provided by the author, the reader is rendered an expert in therapeutic wisdom and is converted to a new belief system in which she will become an enthusiastic participant in her own subjectification. ReferencesBeattie, M. Codependent No More: How to Stop Controlling Others and Start Caring for Yourself. Minnesota: Hazelden, 1992.Beck, U. Risk Society: Towards a New Modernity. Trans. M. Ritter. London: Sage, 1992.Carter-Scott, C. If Love Is a Game, These Are the Rules. London: Vermilion, 2000.Cheery, S. "The Ontology of a Self-Help Book: A Paradox of Its Own Existence." Social Semiotics 18.3 (2008): 337-348.Cowan, C., and M. Kinder. Smart Women, Foolish Choices: Finding the Right Men and Avoiding the Wrong Ones. New York: Signet, 1986.DeAngelis, B. Secrets about Men Every Woman Should Know. London: Thirsons, 1990.Dolby, S. Self-Help Books: Why Americans Keep Reading Them. Chicago: U of Illinois P, 2005.Dowling, C. The Cinderella Complex: Women’s Hidden Fear of Independence. New York: Summit Books, 1981.Doyle, L. The Surrendered Wife: A Step by Step Guide to Finding Intimacy, Passion and Peace with a Man. London: Simon and Schuster, 2000.Dreyfus, H.L., and P. Rabinow. Beyond Structuralism and Hermeneutics. Chicago: U of Chicago P, 1982.Ehrenreich, B., and D. English. For Her Own Good: 150 Years of the Experts’ Advice to Women. London: Pluto, 1988.Foucault, M. Discipline and Punish: The Birth of the Prison. Trans. A. Sheridan. New York: Vintage, 1979.———. The History of Sexuality Volume 1: An Introduction. Trans. R. Hurley. Harmondsworth: Penguin, 1978.Giddens, A. Modernity and Self-Identity: Self and Society in the Late Modern Age. Oxford: Polity, 1991.Gray, J. Men Are from Mars, Women Are from Venus: A Practical Guide for Improving Communication and Getting What You Want in Your Relationships. London: HarperCollins, 1993.Grodin, D. “The Interpreting Audience: The Therapeutics of Self-Help Book Reading.” Critical Studies in Mass Communication 8.4 (1991): 404-420.Hamson, S. “Are Men Really from Mars and Women From Venus?” In R. Francoeur and W. Taverner, eds. Taking Sides: Clashing Views on Controversial Issues in Human Sexuality. 7th ed. Conneticut: McGraw-Hill, 2000.Hazleden, R. “The Pathology of Love in Contemporary Relationship Manuals.” Sociological Review 52.2 (2004). ———. “The Relationship of the Self with Itself in Contemporary Relationship Manuals.” Journal of Sociology 39.4 (Dec. 2003). Hendrix, H. Getting the Love You Want: A Guide for Couples. New York: Pocket Books, 1997.Lichterman, Paul. "Self-Help Reading as a Thin Culture." Media, Culture and Society 14.3 (1992): 421-447. Melia, T., and N. Ryder. Lucifer State: A Novel Approach to Rhetoric. Kendall/Hunt Publishing, 1983.Miller, P., and N. Rose. “On Therapeutic Authority: Psychoanalytical Expertise under Advanced Liberalism.” History of the Human Sciences 7.3 (1994): 29-64. McGraw, P. Relationship Rescue: Don’t Make Excuses! Start Repairing Your Relationship Today. London: Vermilion, 2001.Morgan, M. The Total Woman. London: Harper Collins, 1973.Norwood, R. Letters From Women Who Love Too Much. New York: Pocket Books, 1988. ———. Women Who Love Too Much: When You Keep Wishing and Hoping He’ll Change. New York: Pocket Books, 1986.Paloutzian, R., J. Richardson, and L. Rambo. “Religious Conversion and Personality Change.” Journal of Personality 67.6 (1999).Ricoeur, P. Oneself as Another. Trans. K. Blamey. Chicago: Chicago UP, 1990.Rambo, L. Understanding Conversion. Yale UP, 1993.Rogers, C. On Becoming a Person. Boston: Houghton Mifflin, 1961.Rosenblatt, L. Literature as Exploration. 5th ed. New York: MLA, 1995.Rose, N. “Identity, Genealogy, History.” In S. Hall and Paul du Gay, eds. Questions of Cultural Identity. London: Sage, 1995.———. Inventing Our Selves: Psychology, Power and Personhood. Cambridge: Cambridge UP, 1998.———. “Power and Subjectivity: Critical History and Psychology.” Academy for the Study of the Psychoanalytic Arts. 2000. < http://www.academyanalyticarts.org >.———., and P. Miller. “Political Power beyond the State: Problematics of Government.” British Journal of Sociology 43.2 (1992): 173-205.Rowe, Y. “Beyond the Vulnerable Self: The 'Resisting Reader' of Marriage Manuals for Heterosexual Women.” In Kate Bennett, Maryam Jamarani, and Laura Tolton. Rhizomes: Re-Visioning Boundaries conference papers, University of Queensland, 24-25 Feb. 2006.Schlessinger, L. The Proper Care and Feeding of Husbands. New York, HarperCollins, 2004.Simonds, W. Women and Self-Help Culture: Reading between the Lines. New Jersey: Rutgers UP, 1992.Spezzano, C. 30 Days to Find Your Perfect Mate: The Step by Step Guide to Happiness and Fulfilment. London: Random House, 1994.Starker, S. Oracle at the Supermarket: The American Preoccupation with Self-Help Books. Oxford: Transaction, 1989.Vedral, J. Get Rid of Him! New York: Warner Books, 1994.Wood, L. “The Gallup Survey: Self-Help Buying Trends.” Publishers Weekly 234 (1988): 33.