text:
var isUseHTTPs = !(!!process.env.PORT || !!process.env.IP);

var server = require(isUseHTTPs ? 'https' : 'http'),
    url = require('url'),
    path = require('path'),
    fs = require('fs');

function serverHandler(request, response) {
    var uri = url.parse(request.url).pathname,
        filename = path.join(process.cwd(), uri);

    var stats;

    try {
        stats = fs.lstatSync(filename);
    } catch (e) {
        response.writeHead(404, {
            'Content-Type': 'text/plain'
        });
        response.write('404 Not Found: ' + path.join('/', uri) + '\n');
        response.end();
        return;
    }

    var contentType = {};

    if (fs.statSync(filename).isDirectory()) {
        filename += '/index.html';

        contentType = {
            'Content-Type': 'text/html'
        };
    }

    fs.readFile(filename, 'binary', function(err, file) {
        if (err) {
            response.writeHead(500, {
                'Content-Type': 'text/plain'
            });
            response.write('404 Not Found: ' + path.join('/', uri) + '\n');
            response.end();
            return;
        }

        response.writeHead(200, contentType);
        response.write(file, 'binary');
        response.end();
    });
}

var app;

if (isUseHTTPs) {
    var options = {
        key: fs.readFileSync(path.join(__dirname, 'fake-keys/privatekey.pem')),
        cert: fs.readFileSync(path.join(__dirname, 'fake-keys/certificate.pem'))
    };
    app = server.createServer(options, serverHandler);
} else app = server.createServer(serverHandler);

app = app.listen(process.env.PORT || 9001, process.env.IP || "0.0.0.0", function() {
    var addr = app.address();
    console.log("Server listening at", addr.address + ":" + addr.port);
});

var NodeJsRecordingHandler = require('./Nodejs-Recording-Handler.js');

var io = require('socket.io').listen(app, {
    log: false,
    origins: '*:*'
});

io.on('connection', NodeJsRecordingHandler);


text:
Teyana Taylor Plans To Shoot Music Videos For Every "K.T.S.E." Song
June 25, 2018 | 9:55 AM
by Kyle Eustice
Ser Baffo/Getty Images for BET
Teyana Taylor's new album Keep That Same Energy (K.T.S.E.) arrived on streaming platforms last week. According to a recent tweet, the G.O.O.D. Music signee is shooting a music video for all eight songs on the project.
When a fan requested a video for "Rose In Harlem," Taylor replied with, "I'm shooting a video for every song!"
I'm shooting a video for every song! ? https://t.co/SqTFeaSxS0
— TEYANA M.J. SHUMPERT (@TEYANATAYLOR) June 24, 2018
K.T.S.E. was unveiled at an album listening party in Los Angeles last Thursday (June 21). It marks the 27-year-old Harlem native's follow-up to 2014's VII.
It also puts an end cap on the five-project rollout from Kanye West, which included Pusha T's DAYTONA, Kids See Ghosts with Kid Cudi, West's ye and Nas' Nasir.
I really wanted to hear this on #RoseInHarlem ? @TEYANATAYLOR with those vocals ? She spazzed on this part! pic.twitter.com/LcCePpk7SU
— Lex. (@PEACE_XI_III) June 25, 2018

redpajama_set_name: RedPajamaCommonCrawl


So did you get the moon sand stuff and what is it exactly?
Congratulations! Oh, how HARD is the being patient (like . . . for YEARS (for the most part, everyone's human!)) . . . . . so when moments like these come, it seems almost unbelievable! You want to do a double take, and you do inside, but you (at least I!) all of a sudden feel very careful inside, trying not to over-do something and ruin the progress!
We DID get the Moon Sand -- it's a little like a cross between playdoh and sand.


Limebase » Is MySpace going to survive?
That is the multi-million dollar question… Should it survive? Not the way it is.
I was working on my MySpace profile the other day and it was such an annoyance. Did I want to drop it? Yes. Can I drop it? No. Why? Too many artists are still using it, damn it!
MySpace is part of the services I offer to artists. Setting up and designing their page, blog, friendship, comments and event management calendar – but I don't like using it. I would prefer to let it go. There is too much time spent struggling with the platform. Now that simplier social network platforms exist, MySpace is just dated and not cool at all to work with.
Being such an important player in the industry (are they still?), we would think that they would have embraced all the new web technologies to maintain and advance in the field. What went wrong?
Then, I read this article on Music Week, "MySpace losses increase". They keep saying that a major overhaul is on the way but is it going to be too late? I noticed that they have changed a few features for the artists page allowing them a bit more freedom for the layout but still, I don't think it is enough.
All artists out there, can you tell me why you are using it?


text:
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      <link href="css/eAF7sqpgb-jyGdIAFrMEaw__2.css" rel="stylesheet" type="text/css"/>
      <link href="css/theme.css" rel="stylesheet" type="text/css"/>
      <link href="css/optus_theme.css" rel="stylesheet" type="text/css"/>

                           Signed in as: kjhkjh(Read Only User)

                                 Main Menu

                                            View Rate Plans By Family

         <form name="viewRatePlans" method="post" action="./page2_files/page2.html" enctype="application/x-www-form-urlencoded">
            <input type="hidden" name="viewRatePlans" value="viewRatePlans"/>

                           Products

                              <select>
                                 <option value="noSelectionValue">Select a Product</option>
                                 <option value="0">Andy Test Product with $sign</option>
                              </select>

                           Rate Plan Family

                              <select name="viewRatePlans:ratePlanFamily" size="1" onchange="">
                                 <option value="noSelectionValue">Select a Family</option>
                              </select>

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         </form>

Rate Plans By Rate Plan Family

             @VERSION_NO@

redpajama_set_name: RedPajamaGithub


text:
Digitimes: iPhone 5 to Have 4-Inch Screen and A5 Processor
by Gary Ng – Mon, February 14, 2011
Digitimes is reporting that the next iPhone will sport a 4 inch screen, and an A5 processor. The rationale for a larger screen is to combat the larger displays of rival Android smartphones.
The component suppliers noted that the production lines for Apple's next generation iPhone have begun testing, and Apple is interesting in expanding the screen size to 4-inches to support the tablet PC market as the vendor only has a 9.7-inch iPad in the market.
Another report says Apple is reportedly outsourcing the production of its current A4 and next generation A5 chip to TSMC:
According to Digitimes Research, the iPad 2 will support an enhanced version of the A4 and the A5 will power the iPhone 5. TSMC (Taiwan Semiconductor Manufacturing Company) will initially produce the improved A4, and could likely become the exclusive manufacturer of the A5.
It's been a busy day full of rumours, and here are two more interesting ones. I can see A5 being in the next iPhone, but a larger screen for iPhone 5? It's possible, but the issue is having 300,000+ apps modified to support another iPhone model. It doesn't make sense, as developers have already had to deal with the iPad and the Mac App Store.
What do you think? Do you find your current iPhone screen too small, or is it just the right size?
[Digitimes, 2]
Rumour: iPhone 5 With Slide Out Keyboard? Hell No
Mon, February 14, 2011


"Super Spoke" 11.5 Rotors. Includes reducer for use with 2000-later or 99-earlier wheels. Front & rear 11.5 diameter rotors. Perfect match for Mammoth 52 Spoke wheels. Heat treated to relieve stress.
All items listed on outlawcycleproducts store are brand new and in their original packaging, unless otherwise clearly specified. Please include item number will all inquiries. Serious injury, death and property damage can result from the improper use, control, alteration, or maintenance of motorcycles. The dealer and dealers customers must exercise good judgment in the use, control, alteration, part selection and installation, and maintenance of motorcycles. Outlawcycleproducts has no control over the judgment of others and assumes no responsibility or liability of any nature for the failure of others to use good judgment.
It is your responsibility to make sure the part(s) you order, and receive, fit the application and that a qualified person installs the product. If we made a mistake and sent the wrong part, we will gladly accept it back as long as it is still in the original package and unused. Do not destroy the packaging or write on it. They can either replace or rebuild the part. The item "DNA BLACK STAINLESS 11.5 FRONT & REAR SUPER SPOKE BRAKE DISC ROTORS HARLEY" is in sale since Monday, October 1, 2018.
This item is in the category "eBay Motors\Parts & Accessories\Motorcycle Parts\Brakes & Suspension\Brake Rotors". The seller is "outlawcycleproducts" and is located in Tarzana, California.


text:
Q: rpy2 - how to save dataframe as RData file to disk? I am wondering how to save a pandas dataframe to an .RData file, How can I save to an RData from from a pandas dataframe?  I have everything up to the last step here:
import pandas as pd
import rpy2
from rpy2 import robjects
from rpy2.robjects import pandas2ri
pandas2ri.activate()

# load RData file
df = pandas2ri.ri2py(robjects.r['get'](robjects.r['load'](path_to_rdata_file)))

.... do some processing to df ...

# save df as RData file
r_df = pandas2ri.py2ri(df)
??????????

How can I save the pandas data to disk as an .RData file?

A: I finally figured out the answer, here is how you write to .RData file using a pandas dataframe:
First convert dataframe to R dataframe:
r_data = pandas2ri.py2ri(df)

Then we have to assign the dataframe to a variable in the "R workspace":
robjects.r.assign("my_df", r_data)

Finally, we can reference the variable by name in order to call the save command:
robjects.r("save(my_df, file='{}')".format(filename))

Here are 2 helper functions if you want to read/write RData files but work in python with pandas:
# read .RData file as a pandas dataframe
def load_rdata_file(filename):
    r_data = robjects.r['get'](robjects.r['load'](filename))
    df = pandas2ri.ri2py(r_data)
    return df

# write pandas dataframe to an .RData file
def save_rdata_file(df, filename):
    r_data = pandas2ri.py2ri(df)
    robjects.r.assign("my_df", r_data)
    robjects.r("save(my_df, file='{}')".format(filename))
    os.chmod(filename, 0o777)

redpajama_set_name: RedPajamaStackExchange


text:
MONOCLE SCENT TWO LAUREL Eau de Toilette
"We wanted to capture the same smell and sensation enjoyed while staying with friends in Batroun, Lebanon. It's warm, inviting and at times a little sharp - just like the country." says Monocle editor in chief Tyler Brûlé.
Yellow Lemon, Thyme, Grey Pepper, Cinnamon Leaves, Galbanum, Green Laurel, Violet, Patchouli, Oak, Cedar.


A full day course designed to take participants through how to do most operations in hand surgery with WALANT (Wide Awake Local Anesthesia No Tourniquet) in full detail. This will be the first American all day course on the subject, and will be able to get into much greater depth than the short 1 hour courses provided so far. We will explore tips and tricks for most operations, local injection techniques, safety issues, starting up WALANT, and many other areas with plenty of time for questions and discussion.
Explore tips and tricks for most operations, local injection techniques, safety issues, starting up WALANT, and many other areas.
Engage in discussion with speakers.
Gain knowledgeable tools to get WALANT surgery started in their facility.
The use of vascularized bone grafts for hand and wrist indications will be discussed. This will include applications of pedicled radius grafts, fibular flaps and femoral condyle periosteal, bone and osteoarticular flaps for a variety of indications.
This course will present the options for hand reconstruction with forearm-based flaps and will provide a decision making process to choose the right flap. The advantages and disadvantages of perforator-based and radial/ulnar artery-based flaps will be discussed. Technical issues with major flap types will be demonstrated. Finally, therapeutic concerns and management of complications will be discussed. At the conclusion of the course, participants will have a good working knowledge of forearm flap hand reconstruction.
This course will focus on various treatment options for brachial plexus injuries in both infants and adults. Topics discussed will include nerve procedures as well as secondary procedures. A theme throughout the discussion and cases presented will be the use of a team approach to optimize treatment. The faculty will include surgeons and therapists, all of whom work at brachial plexus referral centers.
Identify current treatment trends for brachial plexus injuries.
Discuss which components of a team are optimal when evaluating brachial plexus injuries.
Recognize how a team approach can optimize treatment outcomes in brachial plexus injuries.
The instructors will discuss technique and long term results of the CoCr/polyethylene-Prosthesis of the PIP joint as well as the new developments in PIP joint replacement, especially the technique and results of the new CapFlex Prosthesis. As an alternative to prostheses, the volar plate interposition arthroplasty will be offered.
Identify an indication of PIP-joint replacement.
Consider the volar plate interposition arthroplasty will be offered as an alternative to prostheses.
Elbow fractures are notorious bad actors, with many often resulting in poor outcomes despite seemingly proper management. This course presents a case oriented approach to the treatment of difficult fractures and failed surgery, with emphasis on avoiding pitfalls in surgical technique.
Recognize causes for failures of fixation and how to minimize the occurrence.
Consider options for salvaging difficult failures.
106 Current Concepts in Dupuytrens Disease: Removal of Affected Tissue or Treatment of Contracture?
Current concepts in minimal invasive and open treatment and after treatment of Dupuytrens Disease will be discussed.
Consider pros and cons of minimal invasive treatment.
Select the right treatment for the individual patient.
Identify appropriate concepts of after treatment.
The course, divided into three segments, will discuss the burned hand in both adults and children from acute injury and management through reconstruction to maximum return of function. With a recent increase in the number of surgeons participating in world missions, these sound principles can serve as the foundation for planning the complex reconstructions of the hand seen following long standing burn deformities.
Assess the depth of acute burn injury of the hand and create a treatment plan consistent with maximum functional return.
Coordinate hand therapy, timing of reconstructive surgery, and objective selection of procedures producing the best outcomes.
Identify deformities of long standing burn contracture of the extremity and be able to apply complex solutions in areas of the world with variable access to resources.
This panel is a case-based discussion of referrals with significant complications related to their initial care elsewhere. The expert panel will discuss their interpretation of the initial cause of the problems and their approach to management of these difficult problems.
Review the best ways to avoid complications of initial care in hand surgery patients.
Give examples of how to manage complications when they occur.
Provide options for the reconstruction of difficult complications.
Discuss how to deal with patients questions after referred to you from elsewhere.
This panel brings together four hand surgeon and hand therapist 'myth buster' teams challenged to present (and bust) their top myths related to the management of clinical conditions commonly seen in daily hand surgery and hand therapy practice. The clinical problems explored in this 'myth buster' panel are: Zone-2 flexor tendon injuries, Proximal phalangeal fractures, PIP joint injuries and Acute hand injuries. Each panel member has been challenged to bring their top five myths that they want to 'bust' in five minutes or less, with an opportunity to defend their rationale.
Analyze how many commonly accepted clinical practices ('myths') may or may not be influencing their own clinical practice decisions.
The presentation will highlight the critical contribution of various surgical and medical specialties, rehabilitation, and transplant immunology in achieving hand/arm transplantation with minimum immunosuppression. The functional outcome from transplantation at different amputation levels as well as complications will be reviewed. Finally, the prospect for achieving transplant tolerance and the remaining challenges in patient compliance will be discussed.
Determine the roles of different disciplines in a hand transplant program.
Discuss the potential risks and benefits of hand/arm transplantation.
Review the latest development in minimizing immunosuppression and inducing tolerance for vascularized composite allo-transplantation.
The AAHS Principles of Internal Fixation in the Wrist and Hand Workshop is a Surgeons Workshop designed to provide participants an opportunity to learn techniques for internal fixation and technical pearls in wrist and hand fractures from an international expert faculty panel and put them into practice in a hands-on sawbone workshop.
Recognize fracture patterns and plan reduction of distal radius and perform volar plating n a distal radius sawbone model.
Discuss surgical options for management of articular fractures and dislocations in the hand and perform them in sawbone model.
Explain indications and demonstrate technique for fixation of scaphoid fractures in a sawbone model.
Recent studies show that the lymphatic system plays a crucial role in managing interstitial fluid levels in the body, and is responsible for the majority of fluid reabsorption. Knowing how to activate the lymphatic system to quickly reduce edema can make all the difference to patients for pain reduction, increasing ROM, and return to function. This workshop will give a thorough understanding of the anatomy and fluid management function of the lymphatic system. Participants will identify the types of edema that affect patients, and develop an understanding of how a therapist can facilitate the action of the lymphatics to reduce both sub-acute and chronic edema in patients.
Review tissue response to trauma.
Explain the anatomic differences between the cardiovascular and lymphatic systems.
Recognize the lymphatic systems' role in fluid homeostasis (edema / swelling management).
Review the different types of edema: acute versus sub-acute versus chronic.
Understand manual edema mobilization (MEM) as a method that activates the lymphatic system.
Introduce the components of the MEM method which include gentle stimulation of the lymphatic system, usage of pump points, exercise, diaphragmatic breathing, compression/bandaging, chip bags, elastic taping and a self-management program.
This MOC Course is designed to go through the current principles of repair of flexor tendon injuries. The faculty will describe the fundamentalist of flexor tendon timing, repair, and rehabilitation.
Identify the fundamentals of flexor tendon repairs.
Discuss current post-operative rehabilitation therapies for flexor tendon repairs.
This course will focus on the use of small joint arthroscopy in the hand where there appears to be advantages to arthroscopic over open treatment. The faculty will describe the indications, technique and expected outcome for arthroscopic treatment of common conditions affecting the thumb CMC joint, MP and PIP joints.
Identify arthroscopic management of thumb CMC arthritis.
Discuss arthroscopic management of MP and PIP joint synovitis.
Discuss arthroscopic management of MP and PIP joint contractures.
There is little consensus about etiology, best management, surgical technique or indication for surgery in Raynaud syndrome patients. This course will explain why there is so little evidence-based data to answer these questions and will focus on the anatomic and clinical rationale for an "extended" periarterial sympathectomy technique in connective tissue patients, including the role of Botox injection for treatment and as an adjunctive topical at surgery. Clinical results will be reported from a 30-year-experience. This course will also review relevant hand therapy techniques and measurements that assist in the diagnosis and management of Raynaud syndrome, including nonoperative therapy treatment techniques, such as the "whirl arm" technique, induced vasodilatation and biofeedback therapy.
Identify why evidence-based data is lacking, and why there is such widespread discrepancy in technique and indications for this disorder.
Discuss anatomic and clinical rationale for an "extended" periarterial procedure in connective tissue patients, and the role injection and topical application of Botox can play.
Identify the important role hand therapy plays in the diagnosis, nonsurgical treatment, preoperative assessment and postoperative management and monitoring of Raynaud's patients.
Recognize indications for an extended periarterial sympathectomy versus a lesser sympathectomy or other vascular surgical procedure and to review expected clinical outcomes.
This instructional course will review the treatment options for severe compressive neuropathies in the extremities, including decompression, soft tissue flaps, and nerve transfers. This course will also address the role of intra-operative nerve stimulation and assessment to help with operative decision making.
Discuss the contemporary treatment options for severe compressive neuropathies.
Identify the role of intra-operative nerve studies to augment operative decision making.
Therapists and surgeons will discuss common PIP joint problems we all struggle with and provide useful, good solutions. PIP joint fractures, boutonniere injuries, extensor tendon lacerations and other problems will be addressed.
Develop new strategies that work when dealing with boutonniere closed and open injuries.
Improve outcomes with tough PIP fractures.
Recognize various solutions to tendon lacerations in the PIP joint.
As the career of a hand surgeon or a hand therapist develop, there are a number of procedures that he or she abandons. Scott's parabola predicts how often new technology is introduced, enthusiastically adopted, only to be discredited as controlled studies and complications arise. Advanced scientific knowledge and best evidence, improved technology, and Poor outcomes are some of the reasons these procedures are left behind. This course will focus on the lessons that can be learned from such disavowed techniques.
Discuss Scott's parabola as it applies to new procedures.
Identify the role that he plays in evaluating a procedure.
Recognize why specific procedures are no longer used.
Discuss procedures that have replaced the abandoned techniques.
Patients and referring providers expect that "everything possible will be done." This becomes even more apparent with a devastating injury such as a digital or partial limb amputation. Surgeons often err on trying to save everything with the rationale that technical or clinical failures can be dealt with later. As resources become tighter, this may not be a reasonable approach. Additionally, certain clinical scenarios and social situations may be better served with revision amputation at the initial presentation.
Review the absolute indications for finger replantation.
Evaluate the contraindications against replantation.
Explain the risk benefit ratio of replantation surgery.
Discuss how to counsel patients faced with the decision of whether or not to undergo replant surgery.
Discuss the fundamentals of teaching hand surgery.
Learn innovative approaches to teaching hand surgery.
In 2051, American will celebrate its 275th birthday. The current exponential growth of the world's population is creating an increased demand for water, food, and energy, which must be anticipated and met if American are to safely enjoy this celebration. Historically, severe food and water shortages create social and political instability and, if not corrected, eventually lead to conflict. In addition, changing weather patterns resulting in prolonged droughts, massive storms with flooding, and large hurricanes or monsoons with sustained winds over 100 mph are causing personal injury and property damage, but also are impacting farmers' ability to meet the world's demand for food. Dr. Russell will relate some milestones in human evolution leading to the present day, including the short-term evolution of hand, micro and plastic surgery, which has occurred during his career and then discuss the larger global climate, energy, food, and water challenges, which will affect our future.
Discuss the global climate in hand surgery.
Develop innovative ways to tackle challenges in hand surgery.
11:46 am - 11:48 am 16. Prospective Evaluation of Post-Operative Opioid Utilization after Upper Extremity Surgery: We are Over-Prescribing!
11:20 am - 11:22 am 25. Do Pre-Operative Antibiotics Reduce Bacterial Culture Growth from Hand Abscesses?
12:04 pm - 12:06 pm 39. Smartphone Based Thermal Imaging: A Valid New Modality For Tissue Temperature Measurement?
12:30 pm - 12:32 pm 66. Repeated Closed Reduction Attempts of Distal Radius Fractures in the Emergency Department - Are we Helping our Patients to Avoid Surgery?
12:44 pm - 12:46 pm 69. Using Hounsfield Units to Assess Osteoporotic Status on Wrist CT Scans: A Missed Opportunity?
These events are neither supported by nor endorsed by ASPS or AAHS.
Surgeons will have the opportunity for hands-on cadaver training utilizing the STRATOS endoscopic system for cubital and carpal tunnel release. Faculty will present on their clinical experience and surgical pearls prior to the lab. Space is limited. The STRATOS is an all-in-one, disposable (no other instrumentation needed) endoscopic system that features a static clear cannula for unparalleled views and protection of anatomy during endoscopic release.
"Limiting Uncertainty in Total Wrist Arthroplasty" Scrub in alongside designing surgeons Dr Brian Adams and Dr Randy Bindra for a guided hands-on tour of the NEW Integra Freedom Wrist Arthroplasty system. Surgical pearls will be demonstrated in a lab setting as well as a discussion on patient selection and design rationale.
This concentrated two-hour cadaver-based bioskills course provides the training required to perform endoscopic carpal tunnel release surgery using MicroAire's SmartRelease® system. Surgeons will have the opportunity to observe the technique in-person as demonstrated on a cadaver specimen by a faculty surgeon. Additionally, participants will have the chance to perform the demonstrated technique on their own cadaver specimen as well as observe and assist at least two other surgeons.
Don't miss the opportunity to improve your nerve repair practice.
Arthritis of the metacarpal-trapezial joint of the thumb is one of the most common arthritic condition of the hand, affecting 10% of the population. Pathophysiology and treatment options will be discussed.
Describe the anatomy of the basal joint complex of the thumb.
Recognize the pathology that causes arthritis of the thumb.
Discuss non-operative approaches to basal joint arthritis pain.
Discuss surgical options for basal joint arthritis.
This course will highlight the expanding role of nerve transfers in peripheral nerve surgery. Once limited to preganglionic brachial plexus injuries, peripheral nerve surgeons are now using nerve transfers in innovative ways: these include at distal sites and in unusual clinical scenarios, such as in reconstruction following spinal cord injury or peripheral nerve tumors/lesions.
Highlight the principles and advantages/disadvantages of nerve transfers over other techniques, such as nerve grafts or tendon transfers.
Discuss new surgical techniques of distal nerve transfers and new indications for their use.
Summarize outcomes of common nerve transfers.
This hour long course will briefly discuss basics of diagnostic and interventional ultrasound as they apply to a hand surgery practice and include; ultrasound diagnosis of common hand, wrist and elbow disorders and basic interventional techniques, such as ultrasound guided injections.
Recognize basic terminology and technical considerations when performing diagnostic ultrasound.
Recognize normal anatomy and common pathology of the hand, wrist and elbow on ultrasound.
Identify ultrasound guided interventional techniques.
This course will discuss the management of distal radius fractures including how to prevent secondary dislocation, plate position, plate design and the management of failed surgery.
Recognize how to prevent secondary dislocation.
Discuss principles of plate position and plate design with regard to tendon ruptures.
Discuss the management of failed surgery.
The focus of this instructional course will be to discuss the basic techniques of targeted muscle reinnervation for the control of upper extremity prosthetic devices. We will examine the indications for targeted muscle reinnervation, the operative techniques to optimize functional outcome, and the various approaches for various amputation levels. We will also examine the role of targeted reinnervation to provide sensory feedback from prosthetic devices. The types of sensory feedback that can be provided with targeted reinnervation, and the benefits of this approach over sensory substitution approaches will be examined. Experts in the field of reconstructive surgery, physical medicine and rehabilitation, and recovery of function following limb loss will participate as panelists. This is sure to be a highly valuable instructional course which will not only discuss the current state-of-the-art but will also look into the future of targeted reinnervation to provide high fidelity motor control and sensory feedback.
Discuss the indications for targeted reinnervation, eligibility criteria, and operative approaches for targeted reinnervation inpatients sustaining upper extremity amputations.
Recognize the use of targeted reinnervation for recording efferent motor action potentials for prosthetic control.
Recognize the use of targeted reinnervation for stimulating afferent sensory action potentials for sensory feedback.
Identify challenges for restoration of function following limb loss and the role of targeted reinnervation to enhance that function.
Discuss the importance of sensory feedback to optimize functional recovery while using a prosthetic limb.
The Scratch Collapse Test has emerged as a useful adjunct in the clinical assessment of patients with compression neuropathy. This course will review the evolution and clinical applications of the Scratch Collapse Test, and will detail the many nuances of performing the test through demonstration. The use of the "hierarchical" Scratch Collapse Test for evaluating complex patients with multi-level compression neuropathy will also be covered.
Explain how the Scratch Collapse Test can help evaluate patients with compression neuropathy in relation to traditional tests, such as the Tinel's test.
Discuss technical nuances of performing the Scratch Collapse Test.
Describe the application of ethyl chloride, a topical anaesthetic, with the Scratch Collapse test to facilitate the clinical evaluation of complex patients with multi-level compression and diffuse pain.
Morrison (1996) argued that demography, economy, and technology drive the evolution of industries from a formative first generation state ("First Curve") to a radically different way of doing things ("Second Curve") requiring new strategies, skills, and partners. Second curve healthcare is marked by demand to serve more patients; at higher levels of service, safety, and quality; at lower cost; in systems of care that are less hospital-centric; and with value being defined by the customer-payer. This presentation will explore the forces of change shaping healthcare delivery systems, focusing on the deployment of lean six sigma quality improvement methodology as an adaptive framework for clinical service innovation, strategic integration, and leadership development.
Describe the features of First and Second Curve Healthcare.
Discuss the implications of Porter's Five Forces of Change.
Define limitations of current healthcare quality measurement systems.
Define the DMAIC elements of the Lean Six Sigma process improvement methodology.
10:38 am - 10:40 am 77. Can a Stener Lesion be Created During Physical Examination?
10:40 am - 10:42 am 78. Surgical Treatment of Scaphoid Fractures - Does Delayed Treatment Affect Union Rate?
10:54 am - 10:56 am 81. Is Insurance Status Associated with Development of Nonunion Following Scaphoid Fracture?
11:00 am - 11:02 am 84. Does Attempted Reduction of Isolated Small Finger Metacarpal Neck Fractures Reduce the Measured Angular Deformity at Final Follow-up?
10:34 am - 10:36 am 93. When Are Static/Moving Two Point Discrimination and Semmes-Weinstein Monofilament Tests Reliable in Children?
10:45 am - 10:47 am 96. Level I Evidence: How Much Volume of Local and How Long Should You Wait for an Effective Median Nerve Block?
During this course, the panelists will discuss the management of complications after peripheral nerve surgery procedures, including decompression, repair, and nerve transfers. The discussion will cover early recognition of complications as well as management strategies including watchful waiting, medical management, and finally, surgical management.
Name categories of symptoms of patients with failed peripheral nerve surgery.
Recognize failed nerve surgery and differentiate failure due to incorrect diagnosis versus improper surgical intervention (technical issues) and/or other reasons (patient related, therapy related, etc.).
Discuss evaluation and management strategies to both avoid and subsequently manage "failures".
Experienced faculty will deliver a review of commonly encountered hand and upper extremity conditions using a combination of case based presentations and lectures. They will cover principles of diagnosis and treatment, while providing an overview of conditions encountered on board examinations and resident in-training examinations. The course is ideal for residents, fellows and hand therapists who wish to increase depth of knowledge in hand surgery as well as surgeons in practice seeking a knowledge update or preparing for a MOC exam.
Have an understanding of the different treatment options available for disorders of the hand and upper extremity.
Recognize various uncommon and/or unusual clinical conditions of the hand and wrist including carpal and DRUJ conditions, peripheral nerve, tendon and other common problems. Compare different treatment methods to avoid complications and improve patient outcomes.
Show your kids what you do in surgery!
This MOC course will help satisfy the CME objectives and requirements for MOC in the carpal tunnel tracer module. It will provide an understanding of the pathogenesis, sensitivity and specificity of clinical evaluations and special tests; as well as the best evidence for treatment options. Finally, the course will evaluate treatment of some potential postoperative complications.
Discuss the pathogenesis of chronic nerve compression disorders.
Interpret the significance of clinical findings and electrodiagnostic tests, especially with regard to selection of patients for surgery.
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The advents of microsurgery, and more recently supermicrosurgery, have had a major impact on the evolution of physiologic procedures, such as vascularized lymph node transfer and LV bypass to treat lymphedema. We will discuss advances and new innovations in surgical techniques, patient selection, potential complications, and outcomes of these and other novel procedures to treat lymphedema.
Recognize the preoperative evaluation, intraoperative choices, and postoperative assessment of the patient with lymphedema.
This panel will describe current approaches to addressing injuries to the upper extremity. The topics will include triage, emergency care, stabilization, debridement, soft tissue coverage, functional recovery, and solutions to complications that may arise in the treatments of these patients.
Recognize the fundamentals of managing mangled extremities.
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Idnetigy possible solutions to complications of the mangled upper extremity.
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Discuss potential nerve transfer treatment options and list donor and recipient nerve combinations.
Recognize situations in which a sensory innervated free flap is needed.
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Discuss the morbidity of sural nerve harvest.
Examine the best way to reconstruct a gap in the patient's nerve.
Provide the best option for nerve reconstruction while avoiding favoritism.
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Read Los Angeles Magazine's May 2020 Issue
A note from Maer Roshan, Editor-in-Chief:
It's a little past 8 on a chilly March evening, and I am writing this from my office ten stories above Wilshire Boulevard, taking in the surreal scene below. Across the street the LACMA lights, usually overrun by Instagrammers and tourists, are hauntingly empty. At rush hour just a handful of cars speed by. The magazine's staff departed a week ago, leaving me alone in a cavernous warren of offices that I share with Penelope, my blind Chihuahua. Like everyone else we are working remotely now, trying to cobble together this issue even as the TV and the internet churn out a litany of calamity, warning of massive deaths and turmoil ahead.
L.A. has been racked by its fair share of biblical disasters over the years—fires and floods and riots and earthquakes. But this crisis seems different: We're held hostage by a virus that inhibits human contact at the very moment we need it the most. As always, Angelenos innovate: improvised drive-in movies, Zoom reading clubs, wine tastings via Skype. But virtual connections are a pale replacement for personal contact. At work daily collaboration has been replaced with video meetings during which someone inevitably has a TV blaring in the background and people talk over one another in nervous babble. In the parks— before they were closed—grandmothers are forced to greet their grandchildren from six feet away.
Yet as singular as this crisis is, it also feels eerily familiar. In the '90s, as editor of a gay weekly in New York, I chronicled the early days of the AIDS crisis, when another wily virus sent a generation of frightened young men to their early graves. Later, on 9/11, as editor of another magazine, I watched the World Trade Center towers crumble on the day the publication was supposed to go to the printer. Despite anthrax threats and predictions of further mayhem, we tore up the issue and created 40 new pages in a week, grateful to have a job that made a difference in some modest way. Then, as now, work was a welcome alternative to helpless existential angst.
Producing a magazine in a constantly churning climate can be a daunting challenge, but one we have worked hard to meet. In March Los Angeles was the first monthly in the country to devote a cover to the emerging pandemic. Since then, our website (lamag.com) has relentlessly tracked breaking news and developments in real time.
As I write this, 4,566 Angelenos have tested positive for the novel coronavirus. Eighty-nine of them have died. What the world will look like a month from now is anyone's guess. So rather than try to predict an unknowable future, we wanted to pause to reexamine the early days of the crisis, when the looming threat propelled a panicked city to action. For their cover story this month, Jason McGahan, Jon Regardie, and Merle Ginsberg interviewed more than 45 people who were on the front lines when the virus hit—from the mayor and his health commissioner to doctors and ambulance drivers and supermarket clerks. Together, and often at their personal peril, they have struggled to keep the city afloat. Their heroism is inspirational.
Elsewhere in this issue we've retooled our service sections, Eat, Shop, and Play, to focus on food, entertainment, and other essentials that you can access from your couch. Also a portfolio of dazzling Instagram photos reminds us of the L.A. that awaits us when this is over—electric, creative, alive. By the time you read this, the prognosis for our future will hopefully be less uncertain. But in any case, you can count on us to keep reporting the best information about this crisis, its impact on the city, and the people who make Los Angeles the best city in the world. Thank you for relying on us during this challenging time. It is an honor we don't take for granted.
Access the May 2020 digital edition of Los Angeles magazine
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Palsgraf v. Long Island R.R. Co., 248 N.Y. 339, 162 N.E. 99 (1928), is a leading case in American tort law on the question of liability to an unforeseeable plaintiff. The case was heard by the New York Court of Appeals, the highest state court in New York; its opinion was written by Chief Judge Benjamin Cardozo, a leading figure in the development of American common law and later a United States Supreme Court justice.

The plaintiff, Helen Palsgraf, was waiting at a Long Island Rail Road station in August 1924 while taking her daughters to the beach. Two men attempted to board the train before hers; one (aided by railroad employees) dropped a package that exploded, causing a large coin-operated scale on the platform to hit her. After the incident, she began to stammer, and subsequently sued the railroad, arguing that its employees had been negligent while assisting the man, and that she had been harmed by the neglect. In May 1927 she obtained a jury verdict of $6,000, which the railroad appealed. Palsgraf gained a 3–2 decision in the Appellate Division, and the railroad appealed again. Cardozo wrote for a 4–3 majority of the Court of Appeals, ruling that there was no negligence because the employees, in helping the man board, did not have a duty of care to Palsgraf as injury to her was not a foreseeable harm from aiding a man with a package. The original jury verdict was overturned, and the railroad won the case.

A number of factors, including the bizarre facts and Cardozo's outstanding reputation, made the case prominent in the legal profession, and it remains so, taught to most if not all American law students in torts class. Cardozo's conception, that tort liability can only occur when a defendant breaches a duty of care the defendant owes to a plaintiff, causing the injury sued for, has been widely accepted in American law. In dealing with proximate cause, many states have taken the approach championed by the Court of Appeals' dissenter in Palsgraf, Judge William S. Andrews.

Background
At the time of the 1928 New York Court of Appeals decision in Palsgraf, that state's case law followed a classical formation for negligence: the plaintiff had to show that the Long Island Railroad ("LIRR" or "the railroad") had a duty of care, and that she was injured through a breach of that duty. It was not required that she show that the duty owed was to her. Under New York precedent, the usual duty of utmost care that the railroad as a common carrier owed its customers did not apply to platforms and other parts of the station.

Facts

Sunday, August 24, 1924, was a warm summer day in Brooklyn, and Helen Palsgraf, a 40-year-old janitor and housekeeper, was taking her two daughters, Elizabeth and Lillian, aged 15 and 12, to Rockaway Beach. Having paid the necessary fare, they were on the platform at the East New York station of the LIRR on Atlantic Avenue in Brooklyn, when a train, not theirs, pulled in. As it began to move again, two men raced for the train, and one made it without incident, as the doors had not closed. The other, a man carrying a package, leapt aboard, with the help of a platform guard pushing him from behind as a member of the train's crew pulled him into the car. But in the process, the man lost the package, which dropped and exploded, for it apparently contained fireworks. Either the force of the explosion or the panicking of those on the platform caused a tall, coin-operated scale to topple onto Helen Palsgraf. No one was hurt enough to spend the night in the hospital, though several people, Palsgraf among them, were listed as injured.

Contemporaneous accounts and witnesses at trial described the man as Italian in appearance, and there was speculation that the package was being taken for use at an Italian-American celebration of some sort; no great effort was made to identify the owner. Palsgraf's injury was listed in The New York Times as shock; she also suffered bruising. The distance between Helen Palsgraf and the explosion was never made clear in the trial transcript, or in the opinions of the judges who ruled on the case, but the distance from the explosion to the scale was described in the Times as "more than ten feet away" (3 metres). Several days after the incident, she developed a bad stammer, and her doctor testified at trial that it was due to the trauma of the events at East New York station. She had not recovered from the stammer when the case came to court.

Trial
Palsgraf brought suit against the railroad in the Supreme Court of New York, Kings County, a trial-level court, in Brooklyn on October 2, 1924. The summons was served the following month, and the defendant filed its answer on December 3. The case was heard on May 24 and 25, 1927, with Justice Burt Jay Humphrey presiding. Humphrey had served for over twenty years on the county court in Queens before unexpectedly being nominated for election to the Supreme Court in 1925; he was noted for his courteous and friendly manner. Manhattan lawyers tried the Brooklyn case: Matthew W. Wood, who worked from 233 Broadway (the Woolworth Building) represented Palsgraf, while Joseph F. Keany, whose office was at Pennsylvania Station, was for the railroad, along with William McNamara. Wood was an experienced solo practitioner with two degrees from Ivy League schools; Keany had headed the LIRR's legal department for twenty years—McNamara, who tried the case, was one of the department's junior lawyers, who had advanced from clerk to counsel after graduation from law school. At trial, Palsgraf testified that she had been hit in the side by the scale, and had been treated at the scene, and then took a taxicab home. She testified to trembling then for several days, and then the stammering started. Her health forced her to give up her work in mid-1926. Wood called Herbert Gerhardt, an engraver, who had seen the man with the package hurry towards the train, and whose wife had been hit in the stomach in the man's rush. He testified that the scale had been "blown right to pieces".

On the second day of the trial, Wood called Dr. Karl A. Parshall, Palsgraf's physician. He testified that he had treated Palsgraf occasionally for minor ailments before the incident at East New York, but on the day after found her shaken and bruised. He gave it as his opinion that Palsgraf's ills were caused by the accident. Grace Gerhardt, Herbert's wife, was the next witness. She testified to being hit by one of "the two young Italian fellows" who were racing to make the train, and how one made it unaided and the other only with the help of two LIRR employees. She had nothing to say about the scale or Palsgraf, having seen neither. Elizabeth and Lillian Palsgraf, the elder and younger daughter of the plaintiff, were next to testify and spoke of what they had seen. Wood indicated his only remaining witness was a neurologist, an expert witness, and McNamara for the LIRR moved to dismiss the case on the ground that Palsgraf had failed to present evidence of negligence, but Justice Humphrey denied it. The neurologist, Graeme M. Hammond of Manhattan, had examined Palsgraf two days before, observing her stammering, speaking only with difficulty. She told him of depression and headaches. He diagnosed her with traumatic hysteria, for which the explosion was a plausible cause, and said the hysteria was likely to continue as long as the litigation did, for only once it was resolved were the worries connected with it likely to vanish.

Wood rested his case on behalf of the plaintiff; McNamara offered no evidence but again moved to dismiss, which Humphrey denied. The judge told the all-male jury that if the LIRR employees "omitted to do the things which prudent and careful trainmen do for the safety of those who are boarding their trains, as well as the safety of those who are standing upon the platform waiting for other trains, and that the failure resulted in the plaintiff's injury, then the defendant would be liable." The jury was out for two hours and 35 minutes, including the lunch hour, and they awarded Palsgraf $6,000 ($ today). Pursuant to statute, she also recovered costs of $142, an amount added to the verdict. A motion for a new trial was denied on May 27, 1927 by Justice Humphrey, who did not issue a written opinion, and a judgment was entered on the verdict on May 31, from which the LIRR appealed on June 14. Once Palsgraf had gotten her jury verdict, the Gerhardts also sued the railroad, with Wood as their counsel.

William H. Manz, in his article on the facts in Palsgraf, suggested that neither side spent much time preparing for trial. Wood did not contact his fact witnesses, the Gerhardts, until shortly before the trial, and Palsgraf was examined by Dr. Hammond the day before the trial started. McNamara, one of the most junior members of the LIRR's legal team, called no witnesses, and Manz suggested the entire defense strategy was to get the judge to dismiss the case. In his later book, Judge Richard Posner indicated that the much-sued LIRR did not present a better case than the first-time plaintiff: "it put on a bargain-basement defense".

Initial appeal
The LIRR's appeal took the case to the Appellate Division of the New York Supreme Court, for the Second Department, the state's intermediate appeals court. In its briefs before the Appellate Division, the LIRR argued that the verdict had been contrary to the law and the evidence. It stressed that it had no foreknowledge that the package was dangerous, and that no law required it to search the contents of passenger luggage. The brief stated that given this, there was no negligence in helping a man make a train, and even if there was, that negligence was not the proximate cause of Palsgraf's injuries. Wood, for Palsgraf, argued that the jury verdict finding negligence was supported by undisputed facts, and should not be questioned by the appellate courts. The plaintiff's brief also suggested that the failure of the railroad to call as witnesses the employees who had aided the man should decide any inferences of negligence against it. Wood deemed the trainmen guilty of a "dereliction of duty", misconduct that was the proximate cause of Palsgraf's injuries.

The lawyers argued the case before the Appellate Division in Brooklyn on October 21, 1927. On December 9, the Appellate Division affirmed the trial court's judgment, 3–2. Albert H. F. Seeger wrote the majority opinion for the five justices hearing the case, and was joined by Justices William F. Hagarty and William B. Carswell. Seeger had been born in Stuttgart and came to the United States as a child; he had been elected to the Supreme Court in 1917 and was elevated to the Appellate Division by Governor Al Smith in 1926. Aged 68 at the time of Palsgraf, he could serve only two more years before mandatory retirement. Justice Seeger ruled that the finding of negligence by the jury was supported by the evidence, and speculated that the jury might have found that helping a passenger board a moving train was a negligent act. He wrote that while the set of facts might be novel, the case was no different in principle from well-known court decisions on causation, such as the Squib case, in which an explosive (a squib) was lit and thrown, then was hurled away repeatedly by people not wanting to be hurt until it exploded near the plaintiff, injuring him; his suit against the man who had set the squib in motion was upheld. The majority also focused on the high degree of duty of care that the LIRR owed to Palsgraf, one of its customers.

Presiding Justice Edward Lazansky (joined by Justice J. Addison Young) wrote a dissent. Lazansky, the son of Czech immigrants, had been elected New York Secretary of State as a Democrat in 1910. Elected to the Supreme Court in 1917, he had been designated presiding justice of the Second Department by Governor Smith earlier in 1927. Lazansky did not question the jury finding of negligence, but felt that the employees' conduct was not the proximate cause of Palsgraf's injuries, since the man's conduct in bringing a package that might explode to a crowded passenger station was an independent act of negligence, rendering the neglect by the railroad too remote in causation for there to be liability.

Court of Appeals

The LIRR was entitled by law to take the case to the New York Court of Appeals (the state's highest court) as there had been a dissent in the Appellate Division, and it did. The railroad argued again that Palsgraf had failed to establish that she had come to harm through the railroad's negligence: that there was no negligence, and even if there was, that neglect had not harmed Palsgraf, since such injury was not "a natural and probable consequence of assisting a man to board a train". Its brief alleged that the trainmen could not have stopped the man from boarding, and once he had flung himself onto the train, had little choice but to help him, "faced with such an emergency they cannot be charged with negligence because they elected to assist the man rather than stand idly by and leave him to his fate." Wood, for his part, argued that negligence had been found by the jury, and by both majority and dissenting justices in the Appellate Division. He wrote that there were many facts from which the jury could have found negligence, including the fact that the train had not shut its doors as it departed (though whether this was to allow latecomers to board or because it was a summer day is uncertain). The case was argued before the Court of Appeals in Albany on February 24, 1928.

Cardozo's majority opinion

The Chief Judge of the Court of Appeals, Benjamin N. Cardozo, was a judge who was greatly respected; he later became a justice of the U.S. Supreme Court. After a standout legal career, Cardozo had been elected to the trial-level Supreme Court in 1913, but was quickly designated by the governor for service on the Court of Appeals. He was in 1917 appointed a judge of that court, and in 1926 was elected chief judge by the voters. In Palsgraf, Cardozo wrote for a 4–3 majority of the Court of Appeals, reversing the appellate judgment and directing that the case be decided for the defendant, the LIRR. Cardozo was joined by Judges Cuthbert W. Pound,  Irving Lehman and Henry Kellogg.

Despite being the longest statement of the facts in any of the four appellate opinions generated by the case, Cardozo's was described by Posner as "elliptical and slanted". It has also been deemed "highly abstract". According to Professor Walter O. Weyrauch in his 1978 journal article, "Cardozo's famous opinion reduced the complicated facts of the case to a bare minimum. Mrs. Palsgraf was transformed into a 'plaintiff' without age, family status, or occupation. The opinion omitted the nature of her injury, the amount of damages that she sought, and the size of the jury award." For example, Cardozo describes Palsgraf (whom he does not name, nor mention her daughters) as standing on the LIRR's platform, rather than waiting for a train, thus downplaying her status as a customer entitled to a high degree of care by the railroad. The explosive package is described as small, though the witnesses had described it as large. The scales are described as being "at the other end of the platform, many feet away" from the explosion, but the record does not support this statement. This characterization may have been based on testimony by Lillian Palsgraf, who had gone to buy a paper from a newsstand "at the other end of the platform", but who was yet close enough to see the package fall. Cardozo's characterization of distance would be challenged by the plaintiff in her motion for reargument, which would be denied with the rejoinder that however close she was to the explosion, she was not so close as to bring her within the zone of foreseeable risk.

After the fact pattern, Cardozo began his discussion of the law with "the conduct of the defendant's guard, if a wrong in its relation to the holder of the package, was not a wrong in its relation to the plaintiff, standing far away. Relative to her it was not negligence at all." Cardozo quoted Pollock on Torts and cited several cases for the proposition that "proof of negligence in the air, so to speak, will not do." Only if there is a duty to the injured plaintiff, the breach of which causes injury, can there be liability. He defended his decision, "a different conclusion will involve us, and swiftly too, in a maze of contradictions." Cardozo posed hypothetical situations: if a railway guard stumbles over a bundle of newspapers, and there are explosives within, will there be liability to an injured passenger at the other end of the platform? Will the result be different if the object containing the explosives is a valise instead? If there was negligence that day, Cardozo argued, it was only negligence that resulted in the fall and destruction of the package, and there was no wrong done by the railroad to Palsgraf for personal injury, "the diversity of incidents emphasizes the futility of the effort to build the plaintiff's right upon the basis of a wrong to some one else." The chief judge instructed, "The risk reasonably to be perceived defines the duty to be obeyed". Cardozo did not absolve the defendant who knowingly unleashes a destructive force, such as by shooting a gun, just because the bullet takes an unexpected path. This is not such a case, Cardozo held: even if the railway guard had thrown down the package intentionally, without knowing the contents he could not knowingly risk harm to Palsgraf, and would not be liable. Negligence cannot impose liability where an intentional act would not.

Negligence, Cardozo emphasized, derives from human relations, not in the abstract. Negligence that does no one harm is not a tort. It is not enough, he found, to prove negligence by the defendant and damage to the plaintiff; there must be a breach of duty owed to the plaintiff by the defendant. He traced the history of the law of negligence, a concept not known in medieval times, and noted that it evolved as an offshoot of the law of trespass, and one could not sue for trespass to another. Had the railroad been negligent towards Palsgraf, it might have been liable, but "the consequences to be followed must first be rooted in a wrong", and there was no legal wrong done by the railroad to Palsgraf. Thus, the lower courts were incorrect, and must be reversed, and the case dismissed, with Palsgraf to bear the costs of suit.

Dissent by Andrews
William S. Andrews of Syracuse was a 69-year-old judge, noted for his scholarship, who had been on the Court of Appeals since 1917. The son of Charles Andrews, a former Chief Judge of the Court of Appeals, William Andrews is best remembered today because he wrote an opinion in Palsgraf. In that dissent, he was joined by Judges Frederick E. Crane and John F. O'Brien. Andrews began with a brief recitation of facts: that a railroad employee had negligently dislodged the package, the contents of which the trainman was unaware, and the subsequent explosion broke the scale and injured the plaintiff, "an intending passenger". Andrews noted the fundamental difference among the judges concerning the law of negligence: whether there must be a duty to the plaintiff, the breach of which injured her, and whether, when there is an act that is a threat to the safety of others, the doer of it should be "liable for all its proximate consequences, even where they result in injury to one who would generally be thought to be outside the radius of danger". Andrews believed that if there was a negligent act, the proximate cause of injury to the plaintiff, that should establish liability.

Andrews found Cardozo's reasoning too narrow, and felt that the focus should be on the unreasonable act: driving down Broadway at high speed is negligent whether or not an accident occurs. Such an act is wrong to the public at large, not only to those who might be injured. "Due care is a duty imposed on each one of us to protect society from unnecessary danger, not to protect A, B or C alone ... In an empty world, negligence would not exist. It does involve a relationship between man and his fellows. But not merely a relationship between man and those whom he might reasonably expect his act would injure. Rather, a relationship between him and those whom he does in fact injure. If his act has a tendency to harm some one, it harms him a mile away as surely as it does those on the scene."

Andrews pointed out that the law allows plaintiffs to recover from defendants who had no duty towards them: orphans may recover for their negligently killed parents; a bereaved person may recover for negligence in the death of a spouse. An insurance company may sue in subrogation and recover the sum paid out from the person who started the fire. "Behind the cloud of words is the fact they hide, that the act, wrongful as to the insured, has also harmed the company."

An event may have many causes, Andrews noted, and only some may be deemed proximate. Liability for negligence may only be found where that proximate cause exists, a term that the judge admitted was inexact. He suggested the analogy of a river, made up of water from many sources, and by the time it wound to sea, fully intermixed. But for a time, after water from a muddy swamp or a clayey bed joins, its origin may be traced. Beyond a certain point, it cannot be traced, and such is proximate cause, "because of convenience, of public policy, of a rough sense of justice, the law arbitrarily declines to trace a series of events beyond a certain point. This is not logic. It is practical politics."

That point, beyond which there is no proximate cause, is drawn differently by different judges, and by different courts, Andrews explained. He listed factors that courts might consider, such as remoteness in time or space, and discussed some hypotheticals, such as a chauffeur who causes an accident, the noise of which startles a nursemaid into dropping a child, then returned to the case being decided,

Given that, Andrews concluded, the jury verdict should be upheld. "Under these circumstances I cannot say as a matter of law that the plaintiff's injuries were not the proximate result of the negligence. That is all we have before us."

Subsequent events
Wood, Palsgraf's lawyer, moved the Court of Appeals to allow reargument of the case, alleging that Cardozo had confused the position of Palsgraf with that of her daughter Lillian (at the newsstand), and complained about the chief judge's use of such terms as "distant" and "far away". Wood warned that the decision could have far-reaching adverse effects on innocent passengers. The court denied the motion with a one-sentence statement likely written by Cardozo, "If we assume that the plaintiff was nearer the scene of the explosion than the prevailing opinion would suggest, she was not so near that injury from a falling package, not known to contain explosives, would be within the range of reasonable prevision." Costs of $559.60 were due from Palsgraf to the railroad under Cardozo's order. Posner doubted the sum was ever collected, noting that Palsgraf's family spoke to legal scholars and periodicals about the case in later years, and never mentioned an attempt to collect what would have been about a year's salary for the disabled former janitor.

Helen Palsgraf remained embittered about the loss of her case. She became mute, and suffered from other health problems prior to her death on October 27, 1945, at the age of 61. At the time of her death, Palsgraf was living in Richmond Hill, Queens with her daughter Elizabeth. Her former attorney, Wood, maintained a law office in the Woolworth Building until his death in 1972 at age 96. His opposing trial counsel, McNamara, remained with the LIRR's legal department until his retirement in 1959, while McNamara's superior and counsel of record, Keany, continued as the railroad's general solicitor until he died in 1935. Justice Humphrey retired in 1936, a year after he gained notoriety for presiding over the marriage of heiress Doris Duke; he died in 1940. Andrews retired at the end of 1928, having reached the mandatory retirement age of 70; he died in 1936. Cardozo was appointed to the U.S. Supreme Court in 1932 by President Herbert Hoover and served there until his death in 1938.

After the Palsgraf case became prominent among lawyers, having been taught to many of them in law school, members of the family sometimes encountered startled reactions when lawyers learned their last name. Frank Palsgraf, Helen's grandson, told in 1978 of "being treated like a celebrity" by a prosecutor when called for jury duty, and causing the judge to reminisce about hard nights studying the case in law school. Nevertheless, the prosecutor struck him from the jury. According to Posner, the later coverage of the family "makes it clear that, with the exception of Mrs. Palsgraf, the Palsgraf family was thrilled by its association with a famous case, notwithstanding the outcome". In 1991, that association became closer, as Lisa Newell, first cousin four times removed of Judge Cardozo, married Palsgraf's great-grandson, J. Scott Garvey.

Prominence
Palsgraf came to the attention of the legal world quickly. William L. Prosser of the University of California Law School wrote that the Appellate Division's decision fell into the hands of Francis H. Bohlen of the University of Pennsylvania Law School. Bohlen was at that time the reporter compiling the first Restatement of Torts for the American Law Institute (ALI), and Cardozo was informally one of the advisers. In that task, Bohlen was having difficulty dealing with the concept of duty of care in negligence, especially involving unforeseeable plaintiffs, and Prosser related that Cardozo was treated to a learned discussion by the other advisers of a case that might come before his court and, convinced by the arguments, used them to decide Palsgraf. Kaufman doubted this story, which was told to Prosser by Dean Young B. Smith of Columbia, noting that the only meeting of the advisers between the two appeal decisions in Palsgraf took place in New York on December 12–13, 1927, beginning only three days after the Appellate Division ruled, and the notes reveal that Cardozo was absent; the chief judge was hearing arguments all that week in Albany. Nevertheless, the discussions and materials from the Restatement compilation likely influenced Cardozo in his decision.

Bohlen dwelt heavily upon Cardozo's opinion in Palsgraf in presenting the Tentative Draft of the Restatement to the ALI's annual meeting, which approved the section citing Palsgraf with little discussion. Palsgraf quickly became well known in the legal community, and was cited in many cases, some of dubious relevance. According to Kaufman, "the bizarre facts, Cardozo's spin on the legal issue, the case's timing in relation to the Restatement project, its adaptability for law-school teaching, the policy-oriented dissent by Andrews, Cardozo's rhetoric, and Cardozo's name—all these factors combined to make Palsgraf a legal landmark." According to Prosser, writing in his hornbook for law students, "what the Palsgraf case actually did was submit to the nation's most excellent state court a law professor's dream of an examination question". But Professor (later Judge) John T. Noonan saw more than this, noting that Cardozo was then the nation's most prominent state-court judge: "The excitement of Palsgraf was not merely that it was a brilliant examination question; it was an examination question answered by Cardozo."

The first mentions of Palsgraf in law reviews were case notes written by law students, appearing over the course of the year following the decision by the Court of Appeals. Professor Robert L. Goodhart, in the Yale Law Journal in 1930, was at the front of an avalanche of commentary to such an extent that by 1938, Louisiana State University professor Thomas A. Cowan deemed Palsgraf "a legal institution". The case entered the standard legal casebooks, from which law students learn, in the early 1930s, usually to illustrate the necessary connection between defendant's misconduct and plaintiff's injury in negligence cases. According to Posner, writing in 1990, "Palsgraf is now the subject of a large scholarly literature, and is, I believe, the only case reprinted in all American casebooks on tort law." Manz wrote, "everyone who has sat in an American law school torts class can recall the basic facts—the crowded railroad platform, the running men, the dropped package, the explosion, and the falling scale. Palsgraf has become a sort of legal 'urban legend'—an allegedly true, but improbable, tale told and retold to each new class of law students." Professor W. Jonathan Cardi noted, "in law school classrooms, 'Palsgraf Day' is often celebrated with food and drink, dramatic reenactments, interpretive poems, and even mock duels between Judges Cardozo and Andrews".

Palsgraf was soon adopted by some state courts, at times in different contexts: Though some state courts outside New York approved it, others did not, sometimes feeling that foreseeability was an issue for the jury to consider. According to Posner, writing in 1990, Cardozo's holding that there is no liability to a plaintiff who could not have been foreseen "has been followed by a number of states besides New York, but it remains the minority rule. Most states continue to muddle along with the nebulous 'proximate cause' approach, which emphasizes the proximity in time and space of the defendant's careless act to the plaintiff's injury; that was the approach taken by Judge Andrews's dissent in Palsgraf."

The overwhelming majority of state courts accept that there must be a duty of care for there to be liability: the courts of Wisconsin, though, have stated that they have adopted Andrews' approach, and impose liability when there was a duty to any person, whether or not that person is the plaintiff. The Restatement (Second) of Torts (1965) amended the earlier formulation only slightly, but the third Restatement (2009), takes an approach closer to that of Andrews in focusing on whether the defendant engaged in an activity that carried a risk of harm to another (not necessarily the plaintiff), and on whether the defendant exercised reasonable care. The new formulation makes foreseeability, or the scope of the risk, not a hurdle that must be overcome, as in Palsgraf, but a factor to be weighed with others when determining whether there was negligence. Thus, according to law professor David Owen in his 2009 article, "the Restatement (Third) discards Judge Cardozo's elemental work in Palsgraf so long ago. And ... also rejects Judge Andrew's  valuable insight that juries should be offered a wide range of fairness factors, beginning with foreseeability, in figuring how far responsibility should extend".

Discussion
According to Posner, "Cardozo's 'bottom line' is that there is no liability to an unforeseeable plaintiff". Don Herzog, in his 2017 book, deemed the Palsgraf principle to mean that "if anyone was wronged here, it was the man with the parcel. The guards' wronging him happened to harm Mrs. Palsgraf. But that doesn't mean they wronged Mrs. Palsgraf. And if they didn't wrong her, she can't conceivably prevail in a tort action. Cardozo is not thinking that if he were on the jury, he wouldn't find the railroad liable. He is saying it was a legal error to let the jury finding stand." This is because "the crucial fact for Cardozo is that the parcel of explosives was unmarked. So reasonably careful conductors worry only that if they make it fall, it will break ... They have no reason to worry about the welfare of Mrs. Palsgraf."

Cardozo has been praised for his style of writing in Palsgraf. Posner noted that in the facts of the case Cardozo "saw instantiated the basic principles of negligence law and was able to articulate them in prose of striking freshness, clarity, and vividness", in an opinion mostly written in short sentences and lacking footnotes or block quotes. University of Pennsylvania Law School Professor Kim Lane Scheppele noted that the opinion was "written by Judge Benjamin Cardozo at the height of his formidable powers". Richard Polenberg, in his study of that jurist, stated, "Cardozo had a genius for making it seem that the results he reached were logical, inevitable, and legally unassailable". Prosser stated, "with due respect to the superlative style in which both [Cardozo's and Andrews' opinions] are written, neither of them wears well on long acquaintance. Both of them beg the question shamelessly, stating dogmatic propositions without reason or explanation." Herzog was also less enthusiastic, noting that "the majority opinion is unfortunately written in the curious idiolect I sometimes call Cardozo-speak."

From its early days, there has been criticism of Palsgraf, and more recently, of Cardozo for authoring it. Cowan, writing in 1938, described its holding as limited to its facts, that given the identical circumstances recurring, the railroad would breach no duty to the new plaintiff by assisting a man with such a package in boarding. Prosser in his 1953 article wondered "how can any rule as to the 'scope of the risk' evolved from two guards, a package of fireworks and a scale aid in the slightest degree in the solution of this question? Is it proper, in Palsgraf itself, so utterly to ignore the fact that the plaintiff was a passenger[?] ... until the question is decided, is Palsgraf really definite authority even for Palsgraf ?"

Noonan's 1976 book chronicled the unwillingness by legal scholars to utilize the "multitude of legal facts not mentioned by Cardozo and Andrews", even though the lower-court record in Palsgraf was reproduced in a civil procedure casebook in the 1950s. Noonan criticized Cardozo for not taking Palsgraf's circumstances into account when making his decision, and listed factors that may have influenced Cardozo against the plaintiff, including that he was a lifelong bachelor who did not have Palsgraf's experience of caring for children, and he may have frowned upon Wood's representation of Palsgraf (likely on a contingent fee, something not favored at the time). Posner, writing in 1990, disagreed with Noonan and with feminist critics following him, noting that judges take an oath to do equal justice to rich and poor, "so the fact that Mrs. Palsgraf was poor would not have been a principled ground for bending the rules in her favor". Noonan had considered unjust the award of court costs against Palsgraf, and in her 2016 book, law professor Cathleen Kaveny agreed, "the penalty imposed on Palsgraf for seeking justice through the courts was to deprive her, a single mother, of the ability to support her children ... All judges, however can develop empathy. And in telling the story of Helen Palsgraf, Judge Noonan makes a good case for why they should."

In 2011, Cardi analyzed the present-day influence that Palsgraf has had on state courts. He found that neither Cardozo nor Andrews has won on the question of how duty of care is formulated, with courts applying policy analyses. "As to the proper doctrinal home for plaintiff-foreseeability, Cardozo has undoubtedly prevailed. Although a clear majority of jurisdictions state that duty is the proper home for plaintiff-foreseeability, Cardozo's vision of foreseeability as a categorical determination has not been widely adopted." But, he noted, "Andrews may have found a back door to victory. Arguably the most important consequence of the Palsgraf decision, the resolution of the judge/jury question, appears to lean in Andrews' direction. A majority of courts prefer to leave foreseeability—even as a part of duty—to the jury."

Scheppele put Palsgraf in social context, noting that 108 passengers were killed in railroad operations on the LIRR in 1924, a typical figure for it in the 1920s.

Notes

References

Sources

Primary

Books and journals

Further reading

External links

 Text of the decision
The Case of What's in the Box? (LegalEagle's Real True Crime) – Coverage of the case by YouTube channel LegalEagle.

New York (state) state case law
United States tort case law
1928 in United States case law
Negligence case law
Railway litigation in 1928
Legal history of New York (state)
Accidents and incidents involving Long Island Rail Road
1928 in New York (state)

redpajama_set_name: RedPajamaWikipedia


text:
Jun 30: Capitalists and Psychopaths!
Jun 29th, 2012 by Sam
The Samantha Clemens Show, Saturday mornings at 10 am EDT on AM1510 in Boston, streaming live at www.samanthaclemens.com.
Part 1: Commentary and interview with Bill Deresiewicz about the pathology of capitalism (interview begins at about 7:40) Listen now.
Part 2: Commentary about right-wing reaction to Supreme Court decision on the Affordable Care Act. Listen now.
Are all capitalists bloodsucking vampire-like psychopaths who are slowly trying to destroy the economy for their own gain?
Of course not…but what's wg with a little hyperbole to add to the political outrage (here's looking at you FOX and MSNBC)?
We'll be talking with essayist Bill Deresiewicz about the economy and those who want to wreck it for their own gain…
Maybe Justice Roberts ain't so bad after all…
Call 617 237 1234 and say what's on your mind.
Commentary, Radio shows, Shows with guests
May 5: "99 to 1" author Chuck Collins!
May 4th, 2012 by Sam
Part 1: Commentary on jobs 2012-05-05-samantha-clemens-p1-commentary-jobs.mp3
Part 2: Chuck Collins 2012-05-05-samantha-clemens-p2-chuck-collins-99to1.mp3
Part 3: Commentary on inequality 2012-05-05-samantha-clemens-p3-commentary-inequality.mp3
Have you been wondering about how wealth inequality is wrecking the world and what you can do about it?
Then you should join Samantha Clemens on The Samantha Clemens Show this Saturday at 10am as she welcomes Chuck Collins of the Institute for Policy Studies.
He is the author of the new book, "99 to 1: How Wealth Inequality is Wrecking the World and What We Can Do About It."
Chuck Collins directs IPS's Program on Inequality and the Common Good. He is an expert on U.S. inequality and author of several books, including Economic Apartheid in America: A Primer on Economic Inequality and Insecurity, co-authored with Felice Yeskel. (New Press, 2005). He co-authored with Bill Gates Sr. Wealth and Our Commonwealth, (Beacon Press, 2003), a case for taxing inherited fortunes. He is co-author with Mary Wright of The Moral Measure of the Economy, a book about Christian ethics and economic life.
He is co-founder of Wealth for the Common Good, a network of business leaders, high-income households and partners working together to promote shared prosperity and fair taxation.
In 1995, he co-founded United for a Fair Economy (UFE) to raise the profile of the inequality issue and support popular education and organizing efforts to address inequality. He was Executive Director of UFE from 1995-2001 and Program Director until 2005.
Join Samantha and Chuck as they discuss his new book, the future of the country, the Occupy movement, and how to fix our economy.
Radio shows, Shows with guests
99%, chuck collins, inequality, institute for policy studies, wealth
Apr 27: A Women's Place is in the House (of Representatives)
Apr 27th, 2012 by Sam
On the show:
Paul Brandus, White House Bureau Chief and founder of the West Wing Report, will give us the latest about about the presidential race and the impact of the latest bad economic news on the campaigns. We'll also touch on why Obama went to Colombia and whether he was successful.
Then —
Are women politicians in America oppressed or is American politics better left for the boys? The United States is currently tied for 79th in the world with liberal powerhouse Turkmenistan for percentage of women in national government. Who is number 1? Rwanda. Who's number 3? Cuba.
To get a clearer picture of where American women stand in The Land of the Free, we'll talk with Siobhan "Sam" Bennett, President/CEO of She Should Run and Women's Campaign Fund will join to discuss America's dismal position in the world for women in politics.
Call in at 617 237 1234 to join the conversation.
colombia, Economy, obama, paul brandus, romney, west wing rpresident
Apr 21: Shareholders Revolt(ed) against Citibank Exec Pay
Sam commentary: 2012-04-21-samantha-clemens-p1-commentary.mp3
Todd Wallack: 2012-04-21-samantha-clemens-p2-todd-wallack-liberty-mutual.mp3
Paul Dorf: 2012-04-21-samantha-clemens-p3-paul-dorf-exec-comp.mp3
Is a sleeping giant waking up??
"Citigroup's shareholders recently took advantage of the new "say-on-pay" provisions of the Dodd-Frank law to vote DOWN CEO Vikram Pandit's $15 million pay package."
And here in Boston, the Liberty Mutual CEO has been under fire for collecting $50 million A YEAR for his job…. When rates are set by the state! Is he really that good??
Todd Wallack, reporter from the Boston Globe, will give us the inside scoop on Liberty Mutual.
who approves the pay
is this a CEO affirmative action?
is the fox watching the chicken coop?
Paul Dworf, Managing Director of Compensation Resources Inc, is an expert in Executive Compensation. We'll talk about:
how these guys set executive compensation levels,
how they measure success,
how they hire these guys in the first place,
how compensation and the attitude of the execs has changed over time,
what the effect of tax increases would have
and whether more money is really an incentive for these guys.
My question: Just how is it that the free market can't get these wages DOWN instead of up in a down economy? Are there more of these guys on the streets – more supply of executive labor than demand? What's going on?
Call in: 617 237 1234!
Commentary, Radio shows, Shows with guests, Upcoming shows
banks, executive compensation, frank-dodd, free market, insurance, liberty mutual, paul dworf, todd wallack
Apr 14: Death of the Death Penalty in CT
Audio coming soon…
Hope you can join us for The Samantha Clemens Show Saturday morning at 10 am EDT on AM1510 in Boston, streaming live at www.samanthaclemens.com.
Guest: Professor James Alan Fox, Northeastern University criminology professor AND Boston.com Community Voices blogger
Connecticut's legislature has voted to abolish the death penalty in the Nutmeg state and George Zimmerman has been charged with 2nd degree murder in the Sunshine State….
But what are the ramifications?
Connecticut has only has one execution since 1976, will it make a difference? In the last few years a number of states have voted to abolish the penalty…will the trend continue?
Was Mr. Zimmermann "overcharged" or "undercharged"?
Is the second degree murder charge appropriate? Would have even been charged if there wasn't such a national outcry?
What about life without parole for juvenile offenders??
Join Samantha on as she welcomes Professor James Alan Fox!
The two will discuss these legal topics and more.
Be sure to call the studio line to get your comments heard and your questions asked! The studio number is 617 237 1234!
Best of, Radio shows, Shows with guests
boston.com community voices, criminal justice, criminology, death penalty, george zimmerman, james alan fox, juveniile offenders, murder, parole, trayvon martin
Apr 7: Chris Mooney on The Republican Brain
Apr 7th, 2012 by Sam
On the Samantha Clemens Show, Saturday morning from 10 to 11am, Samantha welcomes Chris Mooney to talk about his new book "The Republican Brain: The Science of Why They Deny the Science — and Reality"
2012-04-17-samantha-clemens-chris-mooney.mp3
Best selling author Chris Mooney uses cutting-edge research to explain the psychology behind why today's Republicans reject reality—it's just part of who they are.
From climate change to evolution, the rejection of mainstream science among Republicans is growing, as is the denial of expert consensus on the economy, American history, foreign policy and much more. Why won't Republicans accept things that most experts agree on? Why are they constantly fighting against the facts?
Science writer Chris Mooney explores brain scans, polls, and psychology experiments to explain why conservatives today believe more wrong things; appear more likely than Democrats to oppose new ideas and less likely to change their beliefs in the face of new facts; and sometimes respond to compelling evidence by doubling down on their current beliefs.
Goes beyond the standard claims about ignorance or corporate malfeasance to discover the real, scientific reasons why Republicans reject the widely accepted findings of mainstream science, economics, and history—as well as many undeniable policy facts (e.g., there were no "death panels" in the health care bill).
Explains that the political parties reflect personality traits and psychological needs—with Republicans more wedded to certainty, Democrats to novelty—and this is the root of our divide over reality.
Written by the author of The Republican War on Science, which was the first and still the most influential book to look at conservative rejection of scientific evidence. But the rejection of science is just the beginning…
Certain to spark discussion and debate, The Republican Brain also promises to add to the lengthy list of persuasive scientific findings that Republicans reject and deny.
chris mooney, climate change, conservatives, democrats, liberals, nuclear power, republicans, Science, vaccines, weapons of mass destruction
Mar 31: Presidential candidate Governor Buddy Roemer on campaign finance
Mar 31st, 2012 by Sam
Samantha on the Supreme Court hearing on Obamacare 2012-03-31-samantha-clemens.mp3
Presidential candidate Governor Buddy Roemer on why he's running, why he's focused on campaign finance reform, and why he's the best candidate. He recently dropped out of the Republican primary and is now a declared candidate with Americans Elect 2012: 2012-03-31-samantha-clemens-gov-buddy-roemer.mp3
The proposed MA 'stand your ground' legislation with Lawrence Harmon, editorial writer and columnist for the Boston Globe 2012-03-31-samantha-clemens-lawrence-harmon.mp3
americanselect, buddy roemer, campaign financing, republicans
Mar 24: 99 Problems but this book ain't one…
Mar 24th, 2012 by Sam
2012-03-24-samantha-clemens-chris-faraone.mp3
Chris Faraone joined Samantha to talk about his new book "99 Nights with the 99%," a compilation of Chris' articles for The Boston Phoenix and other unpublished material he wrote as he traveled the country late last year from Occupation to Occupation.
The discussion ranged from the occupy movement to how down and dirty should liberals should get when arguing with conservatives to the Treyvon Martin shooting and 'stand your ground' laws in Florida and proposed bill here in Massachusetts.
Interesting conversation with an interesting guy…
99%, boston phoenix, chris faraone, occupy, occupyboston, occupywallstreet
Mar 17: Can Elephants and Donkeys agree on anything?
First half hour:
Can't we all get along? Can't liberals persuade conservatives with facts, logic, the merit of our agreements? Can't conservatives convince liberals of the superior morality of their position?
Well, according to Jonathan Haidt, psychologist at the University of Virginia and author of "The Righteous Mind: Why Good People are Divided by Politics and Religion," we will never persuade each other because our believes are intuitive and irrational…
Joshua Rothman is columnist for the Boston Globe's Sunday Ideas section who had a chance to catch up with Haidt on his book tour.
Second half hour:
New Hampshire State Rep Seth Cohn says he'll introduce a bill to bar left-handed people from marrying each other.
In a tongue-in-cheek proposal to a gay marriage repeal bill, Rep. Cohn plans to offer the ban-on-lefty marriages amendment Wednesday, when the gay marriage repeal bill is debated. LOVE IT!
Seth will tell us all about it!
Photo: (Greg Klee/Globe Staff)
jonathan haidt, joshua rothman, seth cohn
Mar 10: Don't know much about…education!
In case you missed the show:
Part 1: Samantha commentary on education 2012-03-10-samantha-clemens-p1.mp3
Part 2: James Burnett, Boston Globe 2012-03-10-samantha-clemens-p2-james-burnett-globe.mp3
Do American Schools need help? (yes)
Is college for snobs? (No)
Should all who want higher education have the opportunity to advance themselves? (yes)
Do Republicans want an educated populace? (Apparently not)
Join Samantha this Saturday, March 10, 2012 as she discusses the Republicans' war on education.
"But what about people like Mr. Romney? Don't they have a stake in America's future economic success, which is endangered by the crusade against education? Maybe not as much as you think.
"After all, over the past 30 years, there has been a stunning disconnect between huge income gains at the top and the struggles of ordinary workers. You can make the case that the self-interest of America's elite is best served by making sure that this disconnect continues, which means keeping taxes on high incomes low at all costs, never mind the consequences in terms of poor infrastructure and an undertrained work force.
"And if underfunding public education leaves many children of the less affluent shut out from upward mobility, well, did you really believe that stuff about creating equality of opportunity?
"So whenever you hear Republicans say that they are the party of traditional values, bear in mind that they have actually made a radical break with America's tradition of valuing education. And they have made this break because they believe that what you don't know can't hurt them. "
Ignorance Is Strength, Paul Krugman
"Consider the fact that SAT scores (a big factor in college admissions) correlate closely with family wealth. The total average SAT score of students from families earning more than $100,000 per year is more than 100 points higher than for students in the income range of $50,000 to $60,000. Or consider that a mere 3 percent of students in the top 150 colleges, as defined by The Chronicle of Higher Education, come from families in the bottom income quartile of American society. Only a very dogmatic Social Darwinist would conclude from these facts that intelligence closely tracks how much money one's parents make. A better explanation is that students from affluent families have many advantages — test-prep tutors, high schools with good college counseling, parents with college savvy and so on."
Colleges and Elitism, Andrew Delblanco
"What's more, Mr. Santorum's family background shows the profound value of education in lifting the disadvantaged into the middle class and beyond. The campaign likes to leave the impression that he grew up in the coal fields of Pennsylvania, but young Rick actually came of age in a home where the father earned a doctorate and worked as a clinical psychologist while the mother toiled outside the house as a well-credentialed administrative nurse; it was his immigrant grandfather who worked the coal mines."
Michael Medved: Meet the Republicans, Education Bashers
Samantha also welcomes James Burnett, writer for The Boston Globe. The two will discuss the Somerville Music Progam…a program that brings the wonders of music to low income children.
"Gee whiz! Poor kids learning how to play music – discipline, teamwork, and beauty – what's not to love?"
In era of cuts, students in Somerville play on – The Boston Globe
education, james burnette, newt gingrich, obama, republicans, rick santorum, snob, somerville


It is particularly fitting that there now be re-issued (it was first published in 1964) this seminal work by one of America's most distinguished journalists, economists and philosophers. Henry Hazlitt is as far as one can get from that breed of "instant" analyzers and accepters of current modes, which is merely another way of saying he thinks — thinks things through. And in these times, when at long last great numbers of our people are beginning to question the so-called "new morality" (which is neither new nor moral), his book could provide a needed buttress for that questioning. Besides, it will outlast by many decades the screeds of the "instant thinkers."
Gordon, Rosalie, "Codes to Live By," America's Future 15 (April 27, 1973): 16–17; Bettina Bien Greaves, "The Foundations of Morality," The Freeman (June 1973): 380–84.