Category Discussion Questions

Mar 5 2010

Lonely Jessica

Three-year-old Jessica lives in the country where there are no other preschoolers nearby. Her parents wonder whether it is worth driving Jessica into town once a week to play with her 1-year-old cousin. Based on the readings we have done for this course, what advice would you give to Jessica’s parents and why?

I would tell Jessica’s parents that, in all likelihood, once a week is hardly enough. I would tell them that the first five years of a child’s life set patterns that are very reliable and persistent. I would tell them that stimulation is all important during this time. I would tell them kindly and forcefully that Jessica’s future will most likely be heavily influenced by their decisions and actions over the next several years.

  • I would quote Ramey & Ramey (2004), “children’s experiences prior to kindergarten entry are correlated with degree of cognitive development and school readiness as measured by standardized assessments of cognitive and linguistic performance.”
  • I would show them studies that show that “children enrolled in Head Start or other enriched preschool programs show a gain of about 10 IQ points during the year of the Head Start experience compared to similar children without such experience” (Bee & Boyd, 2007, p. 197).
  • I would point them to studies of imprinting and baby ducks (Bee & Boyd, 2007, p. 6).
  • I would introduce them to the concept of “programmed plasticity” and tell them “this period of maximum plasticity is also the period in which the child may be most vulnerable to major restrictions on intellectual stimulation—such as physical or emotional neglect—making these early years a kind of critical period for brain development” (Bee & Boyd, 2007, p. 95).
  • I would point them to Wikipedia articles on “Critical Period” (“Critical period”, 2010) and “Sensitive Period” (“Sensitive periods”, 2010).

However, balancing the needs of Jessica and their living situation I would give them this advice as well:

  • Fill her life with stimulation: varied play environments, toys, tastes, textures, smells, and experiences.
  • Fill her mind with life: read to her, play music for her, show her nature and art and beautiful things.
  • Give her your love and attention and make sure she knows that she has both.
  • Make her know that she is special by always treating her as special.
  • Find her friends to play with. Ideally, many of these friends would be around her age, but interactions with any caring human are better than fewer.
  • I’ll repeat it, because nothing compares to human interaction: find her kids to play with… often.
  • If there are times when the lack of stimulation can’t be helped, let her watch educational television like Sesame Street. But be selective, TV is more bad than good and only the finest and best designed shows can overcome this to supply a positive outcome.

Then I’d recap and tell them that her brain is learning and developing at unimaginable rates. She needs as much varied stimulation and human contact as possible. It is not optional. It is not “nice to have.” It is their moral obligation to provide stimulation, attention and love, just as it is to provide food and shelter.

References

Bee, H., & Boyd, B. (2007). The developing child (11th ed.). Boston, MA: Pearson Education, Inc.

Critical period. (2010). In Wikipedia. Retrieved March 5, 2010, from http://en.wikipedia.org/wiki/Critical_period

Ramey, C. T., & Ramey, S. L. (2004, October). Early learning and school readiness: Can early intervention make a difference?. Merrill-Palmer Quarterly, 50(4), 471-491. Retrieved from http://muse.jhu.edu/login?uri=/journals/merrill-palmer_quarterly/v050/50.4ramey.html

Sensitive periods. (2010). In Wikipedia. Retrieved March 5, 2010, from http://en.wikipedia.org/wiki/Sensitive_periods

Mar 3 2010

Media Violence

What is the influence of media on children’s development, including aggression, ethnic and gender stereotypes, consumerism, and academic learning?

Bee & Boyd (2007) puts the question in perspective very well: “Television… is an educational medium.  Children learn from what they watch” (p. 411).  One study after another demonstrates the effectiveness of visual media (e.g. television, video games, movies, etc) as a teaching tool.

If the media is Sesame Street or Mr. Roger’s Neighborhood or even positively themed but less intentionally educational media like Lassie, viewers benefit.  Whether fostering racial tolerance, kindness, helpfulness, vocabulary or school readiness, TV shows have been shown to be correlated with positive outcomes for viewing children (Bee & Boyd, 2007, p. 408-409).  On the other hand, violent TV shows have been shown to correlate concurrently and longitudinally with poorer grades, lower test scores and the less developed reading skills (Bee & Boyd, p. 409).  More disturbingly, TV has been show to correlate with emotional desensitization and increases in aggressive behavior.  One study found the incidence of aggressive acts immediately following viewing of a popular, violent children’s show increased sevenfold (Bee & Boyd, p. 410).  Another study links the watching of violent television at age eight with serious criminal behavior 20 years later (Bee & Boyd, p. 410).  There also seems to be a dangerous vicious circle as regards violence and media, “the more violent television programs children watch, the more violent video games they prefer, and the more aggressively they behave toward peers (Mediascope, 1999)” (Bee & Boyd, p. 412).   

Bee & Boyd (2007) quote L.D. Eron’s testimony to Congress that makes an excellent summary of the subject: “There can no longer be any doubt that heavy exposure to televised violence is one of the causes of aggressive behavior, crime and violence in society.  The evidence comes from both the laboratory and real-life studies.  Television violence affects youngsters of all ages, of both genders, at all socioeconomic levels and all levels of intelligence.  The effect is not limited to children who are already disposed to being aggressive and is not restricted to this country. (Eron, 1992, p. S8539)” (p. 410-411).

Reference

Bee, H., & Boyd, B. (2007). The developing child (11th ed.). Boston, MA: Pearson Education, Inc.

Feb 25 2010

Gender Stereotypes

What are some examples of gender stereotypes?  Describe the development of gender stereotyping from early childhood into adolescence.

Gender stereotyping can occur in many forms and at many stages of development.  Studies show that gender stereotyped behavior can be increased by parental behavior in very early childhood.  As one example, children’s scores on sex role discrimination at age 4 were elevated in children whose parents had shown sex-typed toy preference at 18 months (Fagot & Leinbach, 1989).  Similarly, another study identified the emergence of gender labeling at about 18 months (Zosuls et al., 2009).  Another study showed that the use of gender in functional categories (e.g. “Good morning, boys and girls”) by teachers in elementary school led to subsequent increase in gender stereotyping among the students (Bigler, 1995).  Interestingly, from a developmental point of view, this increase in gender stereotyping was largest among students who had not yet developed multiple classification skill.  Susan Witt studied the relative influence of parents and peers and found that parents had the more profound influence on gender stereotypes. In addition, she argues, “Sex role stereotypes are well established in early childhood” (Witt, 1997, para. 11).  Other research shows gender stereotypes to be quite persistent, “The experimental intervention with elementary school children led to a reduction of occupational stereotyping.  Children’s own occupational aspirations were not, however, significantly affected” (Bigler & Liben, 1990).

Gender stereotypes can be created and reinforced in many ways.  They can be accidentally reinforced by the unspoken assumptions of caregivers and peers. Gender discriminated color choices (e.g. pink & blue), toy choices (Barbies & GI Joes) and even behavioral expectations (playing catch & playing house) are all examples of unconscious gender role differentiation.  More deliberately, boys are frequently expected to play sports, be tough and exhibit characteristics our culture associates with masculinity. Likewise, girls are directed towards dolls and more feminine behaviors and pursuits. Statements like “You hit like a girl” and “Boys don’t cry” make crystal clear the societal expectations for both genders.  As socialization and maturation progresses, peer pressure to conform can easily come to include gender stereotyped behaviors.  The enforced conformity of adolescence certainly adds to the stereotyping, but as we’ve seen above, gender stereotypes are well in place from very early on.

References

Bee, H., & Boyd, B. (2007). The developing child (11th ed.). Boston, MA: Pearson Education, Inc.

Bethus, I., Lemaire, V., Lhomme, M., & Goodall, G. (2005). Does prenatal stress affect latent inhibition? It depends on the gender. Behavioural Brain Research, 158(2), 331-338. Retrieved from http://www.sciencedirect.com/science?_ob=ArticleURL&_udi=B6SYP-4DK6CJD-2&_user=10&_coverDate=03%2F30%2F2005&_rdoc=1&_fmt=high&_orig=search&_sort=d&_docanchor=&view=c&_searchStrId=1222824518&_rerunOrigin=google&_acct=C000050221&_version=1&_urlVersion=0&_userid=10&md5=e7d13098aea78daa2a945fe5a7a14c84

Bigler, R. S. (1995, August). The role of classification skill in moderating environmental influences on children’s gender stereotyping: A study of the functional use of gender in the classroom. Child Development, 66(3), 1072-1087. doi: 10.1111/1467-8624.ep9509180275

Burman, D., Biten, T., & Booth, J. (2008). Sex differences in neural processing of language among children. Neuropsychologia, 46(5), 1349-1362 . doi: 10.1016/j.neuropsychologia.2007.12.021

Fagot, B. I., & Leinbach, M. D. (1989, June). The young child’s gender schema: Environmental input, internal organization. Child Development, 60(3), 663-672. Retrieved from http://search.ebscohost.com.ezproxy.apollolibrary.com/login.aspx?direct=true&db=mnh&AN=2737015&site=ehost-live

Lenroot, R., Gogtay, N., Greenstein, D., Wells, E., Wallace, G., Clasen, L., Blumenthal, J., … Giedd, J. (2007, March 17). Sexual dimorphism of brain developmental trajectories during childhood and adolescence. NeuroImage, 36, 1065-1073. Retrieved from http://www.boysadrift.com/2007Giedd.pdf

ScienceDaily. (2008). Boys’ And girls’ brains Are different: Gender differences in language appear biological. Retrieved from http://www.sciencedaily.com/releases/2008/03/080303120346.htm

Witt, S. D. (1997, Summer). Parental influence on children’s socialization to gender roles. Adolescence. Retrieved from http://gozips.uakron.edu/~susan8/parinf.htm

Zosuls, K. M., Ruble, D. N., Tamis-LeMonda, C. S., Shrout, P. E., Bornstein, M. H., & Greulich, F. K. (2009, May). The acquisition of gender labels in infancy: Implications for gender-typed play. Developmental Psychology, 45(3), 688-701. Retrieved from http://search.ebscohost.com.ezproxy.apollolibrary.com/login.aspx?direct=true&db=a9h&AN=39568482&site=ehost-live

Feb 24 2010

Self-esteem

Parents and teachers want to know what they can do to promote a child’s self-esteem.  What advice would you give them and why?

According to Bee and Boyd (2007), self-esteem is a function of two factors.

First, children hold a vision of what they should be.  As they move out of childhood into adolescence, they increasingly compare their beliefs about who they really are against who they think they ought to be.  “When the discrepancy is large—when the child sees himself as failing to live up to his own goals or values—self-esteem is much lower” (Bee & Boyd, 2007, p. 287).  

There are at least three obvious actions parents and teachers can take to close this gap.  First, they can work with children to have realistic expectations of their “ideal self.”  By working with children to be fully in touch with their humanity, that ideal can be lowered and the gap reduced.  Second, children all have different areas of strength and weakness.  Typically, the ideals to which children compare themselves are in areas selected by peer group and environment.  This is particularly true in adolescence as the peer group assumes greater significance.  Still, parents can help children shift their comparisons to areas of relative competence.  Finally, children often do a poor job of evaluating themselves.  Frequently, children allow their peer group to define them.  All too often, they place far too little emphasis on their own true strengths and goals.  Parents and teachers can make sure that children see all their capabilities clearly and emphasize their areas of relative excellence.  By doing these three things, the gap between ideal and perceived reality can be reduced dramatically.

Second, self-esteem is dependent on “the overall sense of support the child feels from the important people around her, particularly parents and peers (Franco & Levitt, 1998)” (Bee & Boyd, 2007, p. 287).  In childhood and even in adolescence, children need the love and support of the significant adults in their lives.  Children need to know that they are held to standards, but they need to know that those standards are about the child achieving their own possibility.  They need to know that they are expected to strive and work for the very best they can achieve.  In addition, they need to know that failure is a part of being human, of learning, of evolving.  Mostly, children need to know that they are loved and appreciated.

It is easy to forget, especially with adolescents, but children look to their significant adults to find strength, courage, and direction.  It is up to those adults to provide those things with love and appreciation for all the challenges of youth.

Feb 18 2010

Human Development and Footballs

What do you think influences a child’s/adolescent’s development?

There are three major factors that influence human development.

The first is the common genetic inheritance of the species Homo sapiens. The general outline of development is contained in every human being’s DNA. From conception through birth and beyond, physiological development happens according to a common human blueprint. Synaptic development, myelination, and lateralization all occur on a schedule programmed into our common DNA (Bee & Boyd, 2007, p. 93-99). While experts cannot trace the exact physiological roots of behavioral development, it is clear that the increasing capacity of children parallels the increasing sophistication of the physiology of the body and brain.

The second factor is the specific genetic inheritance of individual human beings. The forty-six chromosomes Influence everything from appearance to physical abilities to personality to mental abilities. This unique individual genetic inheritance creates and defines each living entity in its raw form.

However, neither our common or specific genetic inheritance is determinant. The third influence is environment. As described by Aslin’s Models of Development (Bee & Boyd, 2007, p. 9), different aspects of development are differently sensitive to environment. Some, like vision or language, have critical or at least highly sensitive periods where some base level of stimulus is essential to proper future functioning. Other aspects, like IQ, result from a complex interaction of different genetic and environmental influences. However, it is clear that proper diet, positive stimulation, loving attention, and emotional and physical safety provide significant modifiers to the core genetic programming.

Imagine that a human baby is a football thrown for a deep pass. The common genetic inheritance is the physical laws operating on the football: gravity, friction, rotational forces, etc. The specific inheritance is the football itself: the shape, the weight, the color, the material, the stitches, the individual variations of this particular football. The environment is its passage through the air to its reception: humidity, wind, temperature and, most importantly, the human(s) at the far end, adjusting their behavior to the flight of the ball to provide a safe landing into loving arms.

Reference

Bee, H., & Boyd, B. (2007). The developing child (11th ed.). Boston, MA: Pearson Education, Inc.

Feb 17 2010

IQ and Tiering Classes

Intelligence quotient (IQ) tests produce highly variable results. Do you think it is reasonable to base the placement of children in special classes, such as for the gifted, on the single score? Support your opinion.

Almost without exception, I do not support differentiating people based on any single measure. Human beings are simply too complex and measures of human attributes too unreliable to make such single factor decision making prudent. 

Having said that, there are definitely areas where IQ scores could reasonably be used as a significant factor in decision-making. To the extent that tiering students by ability in school is a goal (ignoring the question of whether such tiering is itself a good idea), IQ is most likely a useful tool. In the first place, it was designed to predict academic success and studies indicate that it does this reasonably well. As Bee & Boyd (2007) say, “Children with high IQ scores are more likely than their peers with average and low scores to be among the high achievers in school” (p. 191). Therefore, it should be clear that for this purpose, IQ scores are “valid.” Further, if IQ scores were to be used in this fashion, they would need to be “reliable,” which is to say that individuals’ results must be stable over time. According to Bee & Boyd, “IQ scores are, in fact, very stable” (p. 189). Finally, I would have ethical qualms if IQ were somehow misrepresenting predictive outcomes across social or ethnic groups. Not so, say Bee & Boyd: “These predictive relationships hold within each social class and ethnic group in the United States” (p. 192). Therefore, to the extent that faculty is attempting to differentiate students by likely educational performance, IQ can morally and practically be reasonably used as one consideration.

However, it is important to understand what IQ scores are not. They are not the sole determinant of likely success. Many factors influence educational outcomes, from culture to heredity to birth order to early childhood environment. As Bee & Boyd (2007) say, “Some children with high IQ scores don’t shine in school while some children with lower scores do” (p. 191). A much strong tool to use in placing students in gifted class would be actual prior educational outcomes, particularly those in the subject in question. IQ tests are also predictors of very specific measures of performance, academic performance. So depending on the type of class, IQ could be very misleading. For example, it would be unwise to use them to populate varsity sports team or the honors drama classes.

Finally, there are troubling correlations between IQ scores, ethnicity, and social class, among others. It is true that these factors correlate across the entire gamut of student achievement. However, given this, I would much prefer direct measures of capability (i.e. grades in prior similar classes) to be the main determinant in tiering classes.

Reference 

Bee, H., & Boyd, B. (2007). The developing child (11th ed.). Boston, MA: Pearson Education, Inc.

Feb 13 2010

Adolescence

What significant issues does puberty and adolescent development present in your classroom?
 
Fortunately for me (but not accidentally) puberty and adolescence should not be a dominant factor at my chosen 5th grade level. However, with 5th grade students varying from ages nine to twelve, adolescent issues will occur in my classroom. In addition, puberty casts a long shadow, as does the culture we live in, exposing children to behavior models beyond their years.
One major aspect of adolescence that will occur in 5th grade will be the students’ struggle for independence. Unlike earlier grade levels, teacher leadership and mentoring will need to accommodate the students’ growing need to be seen as separate and self-sufficient. Accompanying this need will be a growing tendency to use peer group reflection to measure self-worth. Body issues, self-esteem issues, confusion about friendship and dating, and perhaps the beginnings of experimentation in adult risk behaviors (e.g. drugs, alcohol, cigarettes, sex) may occur. As individuation begins to bite at home, parents will become generally more disempowered. Thus, as adolescence accelerates, the relationship between student, teacher and parent will change. This will place increasing reliance on the direct relationship of teacher to student to drive academic performance.

 

Obviously, the first step for a teacher of young adolescence is to understand the nature of adolescence and its implications in the classroom. Beyond that, the opportunity exists to create positive outcomes by honoring adolescence as a life transition. The curriculum can be interwoven with literature, art, and history chosen to give the students a sense of continuity and kinship with a developmental experience common to all. Gentle transitions and opportunities to succeed should be the operating mode. Supporting self-esteem and acknowledging the challenges of puberty creates a safer environment in which to adapt to the rapidly occurring internal changes. Adolescence is a time where connectedness, meaningful learning, and emotional (and physical) safety are particularly helpful to students. The 5th grade teacher in many ways launches students on their journey of adolescent expansion. Accepting that and creating the transitions, understanding, and support to empower the experience are my intentions as regards adolescence in my classroom.

References

American Academy of Child and Adolescent Psychology. (2001). Normal adolescent development part I. Retrieved February 12, 2010, from http://www.aacap.org/cs/root/facts_for_families/normal_adolescent_development_part_i
Bee, H., & Boyd, B. (2007). The developing child (11th ed.). Boston, MA: Pearson Education, Inc.
Berliner, B. (1993). Adolescence, school transitions, and prevention: A research-based primer. Western Regional Center for Drug-Free Schools and Communities (ERIC Document Reproduction Service No. ED387746). Retrieved February 12, 2010 from EBSCOHost ERIC database, Portland, OR.
Esquith, R. (2003). There are no shortcuts. New York, NY: Pantheon Books.

Feb 11 2010

Critical Brain Growth

What factors must you consider for classroom instruction and management in relation to periods of critical brain growth?

There are a number of ways child development should impact classroom instruction and management strategies.

First, in some cases development is very difficult or even impossible to accomplish outside of a certain time frame (the “critical period”). This long observed phenomenon has been scientifically documented in humans or other animals in such varied areas as motor systems, visual systems, the auditory system, the somatosensory system, the taste/olfactory system. It also occurs in “multimodal functions” such as imprinting, stress and anxiety, sleep and language (Hensch, 2004). To the extent this is true, it is obviously essential to provide the appropriate stimulus at the appropriate time. Likewise, and more frequently, development may be most easily accomplished in certain time frames (the “sensitive period”). Again, teachers and curriculum designers need to be aware of current research and incorporate that knowledge into classroom stimulus.

Second, these critical periods of brain growth are reflected in major changes in capabilities (Bee & Boyd, 2007, p. 97). As a teacher or curriculum designer it is important to understand the developmental growth taking place in children of the relevant age. It is a kind of abuse to ask and expect children to perform tasks (educational or behavioral) which they simply lack the capability to perform. This knowledge is complicated by the fact that children enter these periods of growth at varying times. Also, the year or more age differences of children in the same grade further exacerbates this capability differentiation. Thus, some students may be fully capable of a task while others many not be. The ability to perform assigned tasks also has knock-on implications for the sense of self-worth of the students and their social status. Teachers need to be aware of these factors and monitor the classroom accordingly.

Finally, there is a nutritional component to many stages of growth (Bee & Boyd, 2007, p. 96-97). While there is a limit to what school officials can accomplish in this regard, giving students the knowledge, opportunity and support for proper nutrition is often overlooked and quite helpful.
 
Having said all that, I agree with Bee & Boyd, “Most neuroscientists agree that it is far too soon to form conclusions about how knowledge of brain development might inform ‘brain-based’ teaching strategies for students of different ages” (2007, p. 96). I think that thinking about ‘critical stages of growth’ and other neuro-biological concepts with regard to school aged children is best done in context with other developmental theories. It is absolutely essential for teachers to understand human development, especially as regards behavior and learning, but applying this knowledge in the classroom is best done with a very broad brush rather than a surgical scalpel. Observing each individual student and their learning experience, in the context of a wealth of developmental knowledge, is the way to help each child achieve full potential.

References
Bee, H., & Boyd, B. (2007). The developing child (11th ed.). Boston, MA: Pearson Education, Inc.
Hensch, T. K. (2004). Critical period regulation. Annual Review Of Neuroscience, 27, 549-579. Retrieved from http://search.ebscohost.com/login.aspx?direct=true&db=mnh&AN=15217343&site=ehost-live
Wikipedia. (2009). Critical period. Retrieved February 11, 2010, from http://en.wikipedia.org/wiki/Critical_period

Jan 30 2010

Caring

 Is caring more important at some educational levels (e.g., elementary versus secondary) than others? Why or why not?

Caring is important at all educational levels. People of whatever age benefit from connection, support and compassion. Young students need caring even more. They are still developing physiologically and neurologically until well into high school and usually beyond. They are also developing emotionally at the same time and benefit strongly from a safe, supportive, even loving environment. Learning is about strengths, weaknesses, success and failure. It is also very much about resilience. Resilience is fueled by unconditional love and support. Caring is the foundation of healthy learning.

Different ages (and different children of the same age) will need different kinds of support and caring. But each child will benefit from being ‘seen’ and being cared for. In many cases, sending a message that the outcomes at school matter to the teacher might be the only positive messages about school success the student receives. It might be the only message of the student receives that they matter. Fortunately, this is not usually the case, but it is difficult to imagine that anyone wouldn’t benefit from knowing one more person cares about them.

Of course, children of different ages will respond differently and will need to be cared for differently (as will each individual regardless of age). Elementary students are more likely to be open to overt affection and caring. Moving into adolescence, there will a tendency to posture an independence, a growing up. But the need will remain and the caring will be received and honored so long as it doesn’t compete with the student’s need to individuate. I have less recent experience with and knowledge of high school behavior but from what I can remember peer group becomes the dominant factor. I’d imagine that the caring needs to be reshaped into a subject driven relationship. This is to say that teachers care for high school students by caring for their work and, by extension, caring for them as creative individuals.

Caring is essential for teachers and for all of us. It’s a cold rock we live on. Caring is all we really have.

Jan 30 2010

Demographic Hiring

What are the pros and cons of making hiring decisions based on demographic needs (e.g., the shortage of males in elementary school, females in social studies)?

This is a tricky question.

As a society, we are correctly uncomfortable making decisions which place more importance on a demographic fact over the personal qualities embodied in an individual. I agree with Chief Justice Roberts that “the way to stop discrimination on the basis of race is to stop discriminating on the basis of race” (Cato Institute, 2009) but I would change “race” to “impersonal demographics”. If we study the individual, we will have access to all the demographic information as well. Demographic information should not be lost or ignored but it should be placed in the context of a unique human being.

So, for example, I would not be in favor of establishing arbitrary ratios of teachers to students by demographic. However, it’s easy to see how teachers who share demographics can be more effective, all things being equal. There are cultural behaviors, beliefs and communication styles that can be more easily understood and integrated by a person of similar culture. There are experiences, impulses and characteristics that may well be best understood by a person of the same gender. For each category of demographics there are synergies. In each demographic, there is a corresponding possible benefit.

Likewise, merely providing solid role models in familiar demographic packages could be a more powerful example than one of dissimilar demographics.

There’s also no question that a mix of things is always educational. We learn more from our differences, from new things and in a comfortable environment. So demographic diversity amongst teachers is powerfully good.

So, the pros are that teachers of similar demographics can possibly reach students more effectively and provide more powerful role models. The cons are that it’s the person, not the demographic, that teaches. To be blind to the person behind the demographic is to potentially reduce the quality of the education and harm the cultural fabric by perpetuating discrimination.

In conclusion, a teacher’s (or student’s) demographic information is important and useful. But it needs to be consider integrally with the whole picture of that person; their strengths, weaknesses, experiences, skills, character and passions. Giving the children the teacher who will be most effective with them is the goal. Demographics is part, but only part, of that.

Reference

Cato Institute . (2009). The way to stop discrimination on the basis of race Is to stop discriminating on the Basis of Race. Retrieved January 28, 2010 from http://www.cato-at-liberty.org/2009/04/22/ricci-v-destafano/