Recent developments in neuroscience have enabled technological advances to modulate cognitive functions of the brain. Despite ethical concerns about cognitive enhancement, both individuals and society as a whole can benefit greatly from these technologies, depending on how we regulate their use. To date, regulatory analyses of neuromodulation technologies have focused on a technology itself – for instance, the U.S. Food and Drug Administration regulation of a brain stimulation device – rather than the use of a technology, such as the use (...) of a brain stimulation device at work or school. Given that some forms of cognitive enhancement have already started to penetrate the general public’s everyday life, we should begin our discussion on potential regulatory issues regarding their use in various real-world situations. The goal of the article is to fill the gap by providing an analytic framework to examine these regulatory issues. More specifically, it aims to illustrate the issues around respecting autonomy and preventing coercive use of cognitive enhancement. The proposed framework categories the real-world settings where a neuromodulation technology can be used for cognitive enhancement based on two criteria – who is subjected to cognitive enhancement and who imposes cognitive enhancement. Based on this framework, the article analyzes regulatory issues arising out of every combination of subject/imposing party by taking one example case. Focusing on the regulations in the U.S., this analysis shows the current lack of adequate safeguards against the coercive use and calls for more attention from government agencies and researchers to develop sound policies regarding current and potentially more widespread use of cognitive enhancement. (shrink)

Advances in neurotechnologies, artificial intelligence (AI) and Big Data analytics are allowing interpretation of patterns from brain data to identify and even predict and manipulate mental states. Furthermore, there are avenues through which brain data can move into the consumer sphere, be reidentified and brokered. In response to these developments, there have been a number of approaches proposed to strengthen protections of brain data. To better understand the landscape of brain data protection discussions, we conducted a scoping review to identify (...) the rationales for establishing brain data protections and the proposals for protecting brain data offered in the ethics and neuroscience literature. To draw comparisons, we also surveyed the rationales given in the literature for the protection of sensitive behavioral inferences drawn from other types of personal data and associated approaches to achieving protection. This systematic examination of the rationale behind heightened protection for brain data should be useful to clarify the functional and conceptual bases given for brain data protection and to provide a better grounding for evaluating how the different approaches to brain data protection address these concerns. (shrink)

This letter replies to the letter “Colonial and Neocolonial Barriers to Companion Digital Humans in Africa,” by Luís Cordeiro‐Rodrigues, in the same, May‐June 2024, issue of the Hastings Center Report.

The essays in this volume present versions of feminism that are explicitly liberal, or versions of liberalism that are explicitly feminist. By bringing together some of the most respected and well-known scholars in mainstream political philosophy today, Amy R. Baehr challenges the reader to reconsider the dominant view that liberalism and feminism are 'incompatible.'.

It has become increasingly difficult for individuals to exercise meaningful control over the personal data they disclose to companies or to understand and track the ways in which that data is exchanged and used. These developments have led to an emerging consensus that existing privacy and data protection laws offer individuals insufficient protections against harms stemming from current data practices. However, an effective and ethically justified way forward remains elusive. To inform policy in this area, we propose the Ethical Data (...) Practices framework. The framework outlines six principles relevant to the collection and use of personal data—minimizing harm, fairly distributing benefits and burdens, respecting autonomy, transparency, accountability, and inclusion—and translates these principles into action-guiding practical imperatives for companies that process personal data. In addition to informing policy, the practical imperatives can be voluntarily adopted by companies to promote ethical data practices. (shrink)

Corporate America is institutionalizing ethics through a variety of structures, systems, and processes. This study sought to identify managerial perceptions regarding the institutionalization of ethics in organizations. Eighty-six corporate level marketing and human resource managers of American multi-national corporations responded to a mail survey regarding the various implicit and explicit ways by which corporations institutionalize ethics. The results revealed that managers found ethics to be good for the bottom line of the organizations, they did not perceive the need for additional (...) formalization of ethics, and that they perceived implicit forms of institutionalizing ethics (e.g., leadership, corporate culture, top management support) to be more effective than the explicit forms of institutionalizing ethics (e.g., ethics ombudspeople, ethics committees, ethics newsletters). Implications of the survey and future research directions conclude the paper. (shrink)

We appreciate the helpful commentaries on our paper, ‘AI and the falling sky: interrogating X-Risk’.1 We agree with many points commentators raise, which opened our eyes to concerns we had not previously considered. This reply focuses on the tension many commentators noted between AI’s existential risks (X-Risks) and justice here and now. In ‘Existential risk and the justice turn in bioethics’, Corsico frames the tension between AI X-Risk and justice here and now as part of a larger shift within bioethics.2 (...) They think the field is increasingly turning away from ‘big picture’ questions new technologies raise and focusing on narrower justice concerns of less significance. They compare our paper’s emphasis on justly transitioning to more AI-centred societies with the approach of environmentalists fretting about human protection against climate change while losing sight of the need to protect the planet and all living things. Corsico doubts there is much point to pressing for ‘justice on a dead planet’, so too Corsico questions our concern with just transitions. Presumably, that matters little if intelligent life on Earth is destroyed. Corsico’s recommends bioethicists return to big questions, like: ‘Should we develop AI at all, given AI X-Risk?’. Yet this question is increasingly moot. The genie is already out of the bottle. The Future of Life Institute’s 2023 call for a temporary pause on training AI systems more powerful than ChatGPT fell on deaf ears, in part because freely accessible source codes enable anyone to train systems and create AI applications.3 The focus now must be managing the genie. While we take AI X-Risk seriously, …. (shrink)

Drug Safety Communications are used by the Food and Drug Administration to inform health care providers, patients, caregivers, and the general public about safety issues related to FDA-approved drugs. To assess patient knowledge of the messaging contained in DSCs related to the sleep aids zolpidem and eszopiclone, we conducted a large, cross-sectional patient survey of 1,982 commercially insured patients selected by stratified random sampling from the Optum Research Database who had filled at least two prescriptions for either zolpidem or eszopiclone (...) between July 1, 2012 and June 30, 2013. Among the 594 respondents, two-thirds reported hearing generally about drug safety information prior to starting a new drug, with the remaining one-third “rarely” or “never” hearing such information. Providers and pharmacists were primary sources of drug safety information. Two-thirds of zolpidem users and half of eszopiclone users reported having heard about the related DSC messages, ability to accurately identify the major factual messages was limited. Respondents reacted to new drug safety information about their sleep aids by reporting that they would want to learn about alternative ways to help them sleep and seek out more information about the safety of their specific sleeping pill. Opportunities may exist for the FDA to work with providers and pharmacies to help ensure the DSC information is more widely received and is more fully understood by those taking the affected medications. (shrink)

The Buddhist Jātaka tells the tale of a hare lounging under a palm tree who becomes convinced the Earth is coming to an end when a ripe bael fruit falls on its head. Soon all the hares are running; other animals join them, forming a stampede of deer, boar, elk, buffalo, wild oxen, rhinoceros, tigers and elephants, loudly proclaiming the earth is ending.1 In the American retelling, the hare is ‘chicken little,’ and the exaggerated fear is that the sky is (...) falling. The story offers a cautionary tale for considering the trend towards calamity thinking in artificial intelligence (AI). A growing chorus of tech leaders has warned that AI poses existential risk (X-Risk) that could result in the extinction of the human species, the collapse of civilisation, or a colossal decline in human potential and culture. In 2014, Hawking told the Washington Post that AI, ‘could spell the end of the human race’.2 Musk has repeatedly warned about AI’s perils, calling AI, ‘more dangerous than nukes’, recommending colonising Mars to ensure ‘a bolt-hole if AI goes rogue and turns on humanity’,3 and donating 10 million dollars to the Future of Life Institute to jumpstart research on AI’s X-Risk. Gates has stated, ‘I am in the camp…concerned about super intelligence…I agree with … Musk and some others on this and don’t understand why some people are not concerned’.4 Altman, CEO of OpenAI, has fretted that technologies OpenAI was building could endanger humanity—‘even destroying the world as we know it’.5 This paper offers a critical appraisal of the rise of calamity thinking in the scholarly AI ethics literature. It cautions against viewing X-Risk in isolation and highlights ethical considerations sidelined when X-Risk takes centre stage. Section I introduces a working definition of X-Risk, considers its likelihood and …. (shrink)

Trust is central to the therapeutic relationship, but the epistemic asymmetries between the expert healthcare provider and the patient make the patient, the trustor, vulnerable to the provider, the trustee. The narratives of pain sufferers provide helpful insights into the experience of pain at the juncture of trust, expert knowledge, and the therapeutic relationship. While stories of pain sufferers having their testimonies dismissed are well documented, pain sufferers continue to experience their testimonies as being epistemically downgraded. This kind of epistemic (...) injustice has received limited treatment in bioethics. In this paper, we examine how a climate of distrust in pain management may facilitate what Fricker calls epistemic injustice. We critically interrogate the processes through which pain sufferers are vulnerable to specific kinds of epistemic injustice, such as testimonial injustice. We also examine how healthcare institutions and practices privilege some kinds of evidence and ways of knowing while excluding certain patient testimonies from epistemic consideration. We argue that providers ought to avoid epistemic injustice in pain management by striving toward epistemic humility. Epistemic humility, as a form of epistemic justice, may be the kind disposition required to correct the harmful prejudices that may arise through testimonial exchange in chronic pain management. (shrink)

Theories of language production propose that utterances are constructed by a mechanism that separates linguistic content from linguistic structure, Linguistic content is retrieved from the mental lexicon, and is then inserted into slots in linguistic structures or frames. Support for this kind of model at the phonological level comes from patterns of phonological speech errors. W present an alternative account of these patterns using a connectionist or parallel distributed proceesing (PDP) model that learns to produce sequences of phonological features. The (...) model's errors exhibit some of the properties of human speech errors, specifically, properties that have been attributed to the action of phonological rules, frames, or other structural generalizations. (shrink)

Artificial intelligence (AI) has garnered tremendous attention in health care, and many hope that AI can enhance our health system’s ability to care for people with chronic and degenerative conditions, including Parkinson’s Disease (PD). This paper reports the themes and lessons derived from a qualitative study with people living with PD, family caregivers, and health care providers regarding the ethical dimensions of using AI to monitor, assess, and predict PD symptoms and progression. Thematic analysis identified ethical concerns at four intersecting (...) levels: personal, interpersonal, professional/institutional, and societal levels. Reflecting on potential benefits of predictive algorithms that can continuously collect and process longitudinal data, participants expressed a desire for more timely, ongoing, and accurate information that could enhance management of day-to-day fluctuations and facilitate clinical and personal care as their disease progresses. Nonetheless, they voiced concerns about intersecting ethical questions around evolving illness identities, familial and professional care relationships, privacy, and data ownership/governance. The multi-layer analysis provides a helpful way to understand the ethics of using AI in monitoring and managing PD and other chronic/degenerative conditions. (shrink)

Our primary goal was to develop and validate a task that could provide evidence about how humans learn praxis gestures, such as those involving the use of tools. To that end, we created a video-based task in which subjects view a model performing novel, meaningless one-handed actions with kinematics similar to praxis gestures. Subjects then imitated the movements with their right hand. Trials were repeated 6 times to examine practice effects. EEG was recorded during the task. As a control, subjects (...) watched videos of a model performing a well-established (over learned) tool-use gesture. These gestures were also imitated 6 times. Demonstrating convergent validity, EEG measures of task-related cortical activation were similar in topography and frequency between the novel gesture task and the overlearned, praxis gesture task. As in studies assessing motor skill learning with simpler tasks, cortical activation during novel gesture learning decreased as the same gestures were repeated. In the control condition, repetition of overlearned tool-use gestures were also associated with reductions in activation, though to a lesser degree. Given that even overlearned, praxis gestures show constriction of EEG activity with repetition, it is possible that that attentional effects drive some of the repetition effects seen in EEG measures of activation during novel gesture repetition. (shrink)

Anita Chari revives the concept of reification from Marx and the Frankfurt School to spotlight the resistance to neoliberal capitalism now forming at the level of political economy and at the more sensate, experiential level of subjective transformation. Reading art by Oliver Ressler, Zanny Begg, Claire Fontaine, Jason Lazarus, and Mika Rottenberg, as well as the politics of Occupy Wall Street, Chari identifies practices through which artists and activists have challenged neoliberalism's social and political logics, exposing its inherent tensions (...) and contradictions. (shrink)

The COVID-19 pandemic has triggered much-needed reflection on family caregiver burden. This is unsurprising, given U.S. dependence on acute health care delivery and long-standing t...

Social isolation and loneliness are growing concerns around the globe that put people at increased risk of disease and early death. One much‐touted approach to addressing them is deploying artificially intelligent agents to serve as companions for socially isolated and lonely people. Focusing on digital humans, we consider evidence and ethical arguments for and against this approach. We set forth and defend public health policies that respond to concerns about replacing humans, establishing inferior relationships, algorithmic bias, distributive justice, and data (...) privacy. (shrink)

Healthcare ethics consultants in the Veterans Health Administration (VHA) document consults in an enterprise-wide web-based database entitled IEWeb, serving as a system of record for healthcare ethics documentation at 1300 VA facilities. The need arose to evolve the database from an ethics process training resource into a more streamlined documentation repository that captures essential consult elements. A VHA National Center for Ethics in Health Care (NCEHC) Improvement Team convened for three tasks: (1) Specify and prioritize IEWeb changes (occurred via six (...) focus groups composed of “new user” and “super user” cohorts with analysis of existing documentation patterns); (2) Pilot the changes regionally (via regional communication, training, and reviews of pre-post use patterns); and (3) Measure the impact of national change implementation on user perspectives (via pre-and post-change implementation polls). Focus groups identified six implementable priority areas for ethics consult documentation improvement, including the development of a usable consult summary note for ready conversion from IEWeb fields into the electronic health record. Post-IEWeb updates showed an increased number of consults documented, a reduction in “time to consult documentation closure” by a mean of 4.5 days, and a clinically-meaningful improvement in the quality of documentation (78% of ethics questions scored “above-bar” on the validation tool pre- vs. 89% scored “above-bar” post-IEWeb changes, n = 140). According to national survey findings, the number of consultants documenting “all” consults in IEWeb increased, satisfaction increased, and perception of documentation difficulty decreased. IEWeb simplification enabled ethics consultants to re-focus their documentation completion efforts by decreasing perception of documentation burden while improving documentation frequency and quality in a clinically-meaningful way. (shrink)

Depression is a widespread concern in the United States. Neuromodulation treatments are becoming more common but there is emerging concern for racial disparities in neuromodulation treatment utilization. This study focuses on Transcranial Magnetic Stimulation (TMS), a treatment for depression, and the structural and attitudinal barriers that racialized individuals face in accessing it. In January 2023 participants from the Twin Cities, Minnesota engaged in focus groups, coupled with an educational video intervention. Individuals self identified as non-white who had no previous TMS (...) exposure but had tried at least one treatment for their depression. Results revealed that the intervention did not notably change knowledge or stigma about TMS, but attitudes surrounding traveling for treatment changed. Notably, barriers like affordability, frequency of treatment, and lack of knowledge persist. Participants expressed a desire for more information, personal connection, and a tailored educational approach. The study suggests a need for multifaceted strategies to reduce disparities, focusing on education, community-based resources, and policy interventions. Immediate actions that can be taken include the creation of a TMS education program focused on patient engagement and awareness about TMS. (shrink)

The Gricean account of language is at the center of much current work in the philosophy of language and the philosophy of mind. Anita Avramides maintains that Grice's paradigm can be used to defend very different conceptions of mind and of meaning. In this clearly argued book she describes Grice's analysis of meaning and proposes two interpretations of it, one reductive and one nonreductive. Much current work in cognitive science assumes that the content of words and thoughts can be (...) explained in naturalistic terms. A leading idea (advanced mainly by Stephen Schiffer and Brian Loar) is that the naturalistic account of content will proceed in two stages: a reduction of the semantic features of word; to the contents of propositional attitudes and then a reduction of the latter to physical or functional notions. The appeal of Grice's work on meaning to this two stage reductionist strategy is that Gricean definitions seem to provide the only way of reducing the semantic to the psychological, a reduction that is required for a naturalistic account of intentionality. While Avramides defends the method of analysis as one suited to the concept of meaning, she rejects a reductive interpretation of the analysis. She argues that any attempt to reduce the semantic to the psychological leads to a mistaken conception of mind. She exposes the assumptions behind the reductive interpretation and offers fresh and original arguments for the antireductionist position. Against the reductive Gricean she defends the idea that there is a deep epistemological symmetry between semantic and propositional attitude notions, a result of which is that semantically characterized linguistic behavior is central to our concept of belief. Anita Avramides is Lecturer in Philosophy at The Queens College, The University of Oxfor. A Bradford Book. (shrink)

Since the 1990s, numerous studies on the relationship between parents and their children have been reported on in the literature and implemented as a philosophy of care in most paediatric units. The purpose of this article is to understand the process of nurses' care for children in a paediatric setting by using Noddings's caring ethics theory. Noddings's theory is in part described from a theoretical perspective outlining the basic idea of the theory followed by a critique of her work. Important (...) conceptions in her theory are natural caring (reception, relation, engrossment, motivational displacement, reciprocity) and ethical caring (physical self, ethical self, and ethical ideal). As a nurse one holds a duty of care to patients and, in exercising this duty, the nurse must be able to develop a relationship with the patient including giving the patient total authenticity in a 'feeling with' the patient. Noddings's theory is analysed and described in three examples from the paediatrics. In the first example, the nurse cared for the patient in natural caring while in the second situation, the nurse strived for the ethical caring of the patient. In the third example, the nurse rejected the impulse to care and deliberately turned her back to ethics and abandoned her ethical caring. According to the Noddings's theory, caring for the patient enables the nurse to obtain ethical insights from the specific type of nursing care which forms an important contribution to an overall increase of an ethical consciousness in the nurse. (shrink)

To design effective strategies to improve ethics consultation (EC) practices, it is important to understand the views of ethics practitioners. Previous U.S. studies of ethics practitioners have overrepresented the views of academic bioethicists. To help inform EC improvement efforts, we surveyed a random stratified sample of U.S. hospitals, examining ethics practitioners’ opinions on EC in general, on their own EC service, on strategies to improve EC, and on ASBH practice standards. Respondents across all categories of hospitals had very positive perceptions (...) of their own ethics consultation service (ECS) and few concerns about quality. Our findings suggest that the ethics-related needs of small, rural, non-teaching hospitals may be very different from those of academic medical centers, and therefore, different approaches to addressing ethical issues might be warranted. (shrink)

The algebraic proof of Craig's interpolation lemma for m-valued logic was given by Rasiowa in [1]. We present here a constructive proof of this lemma, based on a Gentzen type formalization.

Ethics consultation has become an integral part of the fabric of U.S. health care delivery. This article summarizes the second edition of the Core Competencies for Health Care Ethics Consultation report of the American Society for Bioethics and Humanities. The core knowledge and skills competencies identified in the first edition of Core Competencies have been adopted by various ethics consultation services and education programs, providing evidence of their endorsement as health care ethics consultation (HCEC) standards. This revised report was prompted (...) by thinking in the field that has evolved since the original report. Patients, family members, and health care providers who encounter ethical questions or concerns that ethics consultants could help address deserve access to efficient, effective, and accountable HCEC services. All individuals providing such services should be held to the standards of competence and quality described in the revised report. (shrink)

A personal view made in light of the recent news article regarding a husband wanting to sue Addenbrooke's hospital over a Do Not Attempt Resuscitation decision. This article aims to highlight how the rolling out of cross boundary palliative care registers may be more at risk of infringing human rights.

Volume 19, Issue 10, October 2019, Page 52-54.

Medical researchers must continue to develop and test non-blood oxygen-transport products. Resources provided by the Jehovah's Witness Hospital Assistance Line must be consulted. Sickle cell researchers must continue to test non-blood treatment. Information about non-blood treatments must be disbursed. Ways to enhance parental comport as the laws further and further support children's best interest must be provided. Information regarding cultural diversity must be disseminated. Hospitals and healthcare agencies that have not done so must institute the use of ethics consulting or (...) ethics committees. Nurse ethicists must continue development of the role of educating staff; mediation, arbitration and negotiation; problem solving; obtaining legal opinion; providing patient, family, or staff advocacy; and helping to reduce suffering on the part of the providers. Difficult ethical decisions should continue to be debated.Were the staff at X Med Center correct in overriding parental wishes and breaking tenets of their faith? In the doctor's, nurse's lawyer's, and judge's view they were. The child, now eight years old, is alive and well. The stroke resolved, and imminent death averted. The parents' and child's views are not presently available. Whether the family is suffering from the child's loss of his relationship with God, or are secretly relieved in their hearts that they are not, like Rita Swan, mourning their dead son, is unknown. What is known, is that this was a difficult case for all involved, and that such cases will continue to present themselves in the future. (shrink)

As ambient assisted living technologies continue to evolve, ethics consultants should be prepared to address questions about their proper use. In this issue, we address a scenario in a dementia car...

The Spring 1999 issue of CambridgeQuarterly adds to the growing body of academic inquiry into the goals of neonatal intensive care practices. Muraskas and colleagues thoughtfully presented the possibility of nontreatment for neonates born at or under 24 weeks gestation. Jain, Thomasma, and Ragas explained that quality of future life must not be ignored in clinical deliberation. And Hefferman and Heilig described once again the dilemmas nurses face when caring for potentially devastated neonates kept alive by technology. These authors take (...) brave steps by publicly questioning the trend of intensive medical support for most every American-born product of conception. But many questions addressing the goals of neonatal intensive care remain, and few authors have actually tried to distill these goals. (shrink)

'Anita L. Allen breaks new ground...A stunning indictment of women's status in contemporary society, her book provides vital original scholarly research and insight.' |s-NEW DIRECTIONS FOR WOMEN.

Liberalism welcomes diversity in substantive ideas of the good but not in the process whereby these ideas are formed. Ideas of the good acquire weight on the presumption that each is a person's own, formed independently. But people differ in their capacities to conceptualize. Some, appropriately characterized as cerebral, are proficient in and profoundly involved with conceptualizing. Others, labeled cognitively disabled, range from individuals with mild limitations to those so unable to express themselves that we cannot be sure whether their (...) behavior is mediated by concepts at all. Constricted cognitive capacities have been thought to prevent participation in the prescribed process for forming personalized ideas of the good. So liberal theory, when formulating principles and practices of justice, often disregards cognitively disabled peoples' perspectives. We put aside metaphysically driven notions about personhood and show how interpersonal processes of “prosthetic” thinking (different from surrogacy) can satisfy liberalism's standards, positioning cognitively disabled individuals as fully participating subjects of justice. (shrink)

Autism spectrum disorders (ASD) are thought to result in part from altered cortical excitatory-inhibitory balance; this pathophysiology may impact the generation of oscillations on EEG. We investigated premotor-parietal cortical physiology associated with praxis, which has strong theoretical and empirical associations with ASD symptomatology. 25 children with high-functioning ASD (HFA) and 33 controls performed a praxis task involving the pantomiming of tool use, while EEG was recorded. We assessed task-related modulation of signal power in alpha and beta frequency bands. Compared with (...) controls, subjects with HFA showed 27% less left central (motor/premotor) beta (18-22 Hz) event-related desynchronization (ERD) (p = 0.030), as well as 24% less left parietal alpha (7-13 Hz) ERD (p = 0.046). Within the HFA group, blunting of central ERD attenuation was associated with impairments in clinical measures of praxis imitation (r = -0.4; p = 0.04) and increased autism severity (r = 0.48; p = 0.016). The modulation of central beta activity is associated, among other things, with motor imagery, which may be necessary for imitation. Impaired imitation has been associated with core features of ASD. Altered modulation of oscillatory activity may be mechanistically involved in those aspects of motor network function that relate to the core symptoms of ASD. (shrink)

The French astronomer La Condamine, sent to Perú to measure an arc of the meridian in 1736, decided to return to France by way of the River Amazon, mapping the river and collecting observations of all sorts. This intention was over-optimistic and the circumstances of the journey prevented La Condamine from gathering much new information or undertaking the necessary observations to improve existing maps. He published three popular versions of the journey but witheld most of the observations that he did (...) make for a later report which was never written. His journals are now lost, but his aims and achievements can be assessed from contemporary documents and the collation of his three accounts. (shrink)

Privacy and technology clash in the courts. I elaborate the example of Puttaswamy v Union of India (2017), an example from the High Court of India, whose sweeping and inclusive jurisprudential style raises starkly the question of the influence that academic philosophers and other scholars have over how legitimate societal interests in exploiting information technology and protecting personal privacy are “balanced” by the courts. Philosophers will be satisfied to see that their theories are acknowledged in a landmark national decision finding (...) that India’s 1.3 billion people have a constitutional, fundamental right to privacy that constrains a challenged government biometric identification system. Some scholars will appreciate the inclusive definition of privacy, which included decisional privacy, combined with the treatment of privacy as a paramount human good meriting the protection of fundamental rights. But some academic philosophers are potentially disappointed that the Court synthesizes rather than differentiates among their competing theories, concepts, and definitions, and, in the end, relies upon liberal Enlightenment ideals that some scholars have argued are singularly ill-suited for the twenty-first century. (shrink)