Legal Update for Police Psychologists |
International Association
of Chiefs of Police, Inc.
Police Psychological Services Section
http://www.theiacp.org/div_sec_com/sections/psych.htm
Annual Conference Philadelphia, PA
October, 2003
Compiled by
Wayne W. Schmidt
AELE Law Enforcement Legal Center
Contents
I. Tort Liability
Critical Incident Negotiations Suicide
Critical Incident Negotiations Shooting
Duty to Care for Ill or Injured Employees
Psychotherapy Suicidal Patient
Prisoner Classification Suicidal Inmate
II. Employment Law
Psychological Exams ADA Impairment
Psychological Exams Retaliation
Fitness for Continued Duty
Stress-Related Claims and Defenses
Whistleblower Protection Laws
III. Selected Articles (List)
Part One Tort Liability
Critical Incident Negotiations No Liability for Suicide
Tenth Circuit rejects a malpractice suit against Tulsa and a police psychologist who assisted the SWAT team in negotiation with a mentally disturbed young man who eventually fatally shot himself.
A family sued the City of Tulsa, the Chief of Police, a police psychologist (Douglas Gentz, Ph.D.), and his psychological services firm following the death of a 23 year-old male. The deceased was tasking medication and was under treatment for Attention Deficit Hyperactivity and Oppositional Defiant Disorder.
A woman reported that her husband was armed with a loaded .38 caliber pistol and AK 47 and had threatened to kill her and then kill himself.
The young man told arriving officers that he had armor piercing ammunition for the AK 47 and that he was going to start shooting and that the police have just entered into a war. The Special Operations Team was activated and Douglas Gentz, Ph.D., assisted in the negotiations.
Dr. Gentz generated a psychological profile of the young man, who announced that that he wanted to kill himself and that he was not coming out of there alive. He threatened to shoot anyone who tried to enter the apartment and to kill himself if anyone attempted to enter the apartment.
Throughout the standoff, the young man was drinking and viewing websites relating to negotiating with suicidal individuals. After eight hours, officers instructed the phone company to re-assign a new number to prevent third parties from calling and interrupting negotiations and to keep the youth from using the Internet to obtain information on suicide negotiations.
The officers concluded that the youth was no longer negotiating in good faith and at 5:15 p.m. they launched a rubber baton to breach a rear window. A few seconds later officers heard a single gunshot. On entering the home, officers found a suicide note; the youth expired on the following day.
The deceaseds psychiatrist gave a pretrial affidavit, which stated:
[1] By Gentz dissuading me from making contact with [Christiansen], it became more likely that [Christiansen] would not obtain medical advice and treatment during the standoff.
[2] Gentzs interferences of [sic] my contact with [Christiansen] increased the likelihood that [Christiansen] would attempt to harm or kill himself.
[3] In my professional opinion, cutting off [Christiansen] from his doctor and his mother was reckless.
[4] It is my professional opinion that Sean Christiansen could probably have been helped by me or by Seans mother because his suicidal ideation was an issue which I had handled and addressed with [him] and which his mother had handled and addressed with him.
The District Court refused to allow the affidavit. That holding was upheld by the Tenth Circuit:
Dr. Crass statements regarding what might have happened had he been allowed to intervene are pure speculation. Further, as we noted earlier, during the standoff, the TPD asked Christiansen whether he wanted to see Dr. Crass, and Christiansen never responded to these inquiries. Finally, insofar as Dr. Crass did not convey this information to defendants at the time of the events in question, it has little, if any, probative value. Accordingly, the district court did not abuse its discretion in excluding Dr. Crass affidavit.
The panel concluded that the plaintiffs failed to allege facts sufficient to give rise to a constitutional violation under the Fifth and Fourteenth Amendments.
Christiansen v. City of Tulsa, # 02-5135, 332 F.3d 1270 (10th Cir. 2003).
Click here to read the decision on the Internet.
Click here to view the Tulsa Police Dept. Special Operations Team Policy directive.
Critical Incident Negotiations Shooting
A divided Fifth Circuit finds no liability for shooting a youth, armed with a sword, when he advanced on police officers. The fact that no psychologist was on the scene is irrelevant ...
After the shooting death of her son in a confrontation with police, a woman brought suit under 42 U.S.C. 1983 against the City of Palestine, Texas and the police chief. She claimed that excessive force was used and, after shooting her son, police were deliberately indifferent to her son's need for medical attention.
At the time, the deceased was inside a mobile home with the door open, yelling, cursing, brandishing an eighteen to twenty inch sword and breaking windows. Blood was on his hands and on the broken windows. The officers, with weapons drawn, told him to drop the sword.
The chief told the boy to drop the sword and not to advance on the officers. He offered to take him to see a doctor or psychologist. While the chief was talking to the youth, he exited the mobile home, brandishing the sword. When he turned and raised the sword toward the officers, the chief shot him in his right arm, causing him to drop the sword.
Two judges on the Court of Appeals found no liability; a third judge disagreed. The majority said:
The dissent makes much of the fact that no psychologist was called to the scene, although we do note that an ambulance had been called. We think that the fact that no psychologist was on the scene is irrelevant to this case.
Mace v. City of Palestine, #02-40335, 333 F.3d 621, 2003 U.S. App. Lexis 12811 (5th Cir. 2003).
Click here to read the decision on AELEs website.
Duty to Care for Ill or Injured Employees
Federal appeals court holds that the widow of a prison employee, who became sick at work, and then was fatally injured in a collision while driving home, is not entitled to collect damages from the employer.
A three-judge appeals panel said that the question how far an employer should go in providing medical assistance for employees who become ill at work involves an exercise of judgment, rather than the application of tort law.
Although prison management had sometimes accommodated the needs of a sick employee by providing him with transportation home or to a hospital, this did not create a contractual duty or a reasonable expectation that a hypoglycemic employee would be restrained against his wishes from driving home.
The deceased, a diabetic, was adamant that he wanted to go home and intended to do so the same way that he had arrived at work, by driving his pickup truck. Stockberger v. U.S., # 02-3651, 332 F.3d 479, 20 IER Cases (BNA) 8, 2003 U.S. App. Lexis 11601 (7th Cir. 2003).
Click here to view the opinion on the Internet. [PDF]
Psychotherapy - Improper Assessment of Suicidal Patient
Oklahoma jury awards $1.5 million to the estate of a man who killed himself after being discharged from the mental health facility.
The deceased was taken to the clinic after police found him dazed and holding a gun in public. The deceaseds daughter alleged that the defendants had failed to adequately assess him for suicidal tendencies and improperly released him. Wall v. Chisholm Trail Counseling Services, # CJ 2001-296 (Grady Co. Dist. Ct. May 17, 2002).
Research Note: A court in Alachua County, Florida, granted a summary judgment for a psychotherapist who was sued for negligence after a patient killed himself. On appeal, the panel said that the only evidence of negligence was the opinion of expert, hired by the plaintiff, stating that the suicide might have been foreseeable.
However, testimony from the decedents ex-wife and others who knew him at the time of treatment showed that the decedent had no indication of suicidal tendencies, there were no prior suicide attempts, and a jail screening done a few months prior revealed no risk of suicide. Summary judgment was proper. Lawlor v. Orlando, # 1D00-1887, 795 So. 2d 147 (Fla. App. 2d Dist. 2001).
In California, an appeals court reversed a summary judgment for a psychiatrist, who had been sued by the widow of a patient, for the negligent failure to prevent her husbands suicide. Finding no basis for distinguishing between inpatient and outpatient cases, the panel held 2-to-1, that psychiatrists or psychologists owe a duty of care, consistent with professional community standards, to provide appropriate treatment for suicidal patients. Kockelman v. Segal, # H016390, 61 Cal.App.4th 491, 71 Cal.Rptr.2d 552, 1998 Cal. App. Lexis 104 (6th App. Dist. 1998). [PDF]
Prisoner Classification - Assessment of Suicidal Inmate
Seventh Circuit rejects claims from the family of a prisoner who killed himself. Plaintiffs produced no evidence that prison psychologists acted with indifference or negligence.
The family of an inmate who committed suicide by hanging himself in his cell sued the prisons intake psychologist, the prisons treating psychologist, the prisons treating physician and others. They alleged that the defendants violated the deceaseds constitutional rights by acting with deliberate indifference to his risk of suicide. The District Court dismissed the suit.
On appeal, a three-judge panel said that the plaintiffs failed to produce any evidence showing that the defendants had actual knowledge of [the prisoners] risk of suicide. ... They also noted:
First, [the prisoner] never told any of the defendants that he felt suicidal or depressed beyond his control during his incarceration ... despite having been asked the question numerous times during intake interviews, psychological evaluations, crisis counseling, and physical exams.
... second, not one of the defendants who interviewed or examined [the prisoner] each of whom was trained in psychology, social work, medicine, or crisis response ever determined after seeing him that he exhibited suicidal or delusional tendencies or that he needed to be placed on crisis or suicide watch.
The sole evidence in the plaintiffs favor was a medical history form indicating that, years earlier, the prisoner attempted suicide by jumping in front of a train. None of the defendants actually saw this form.
The Chief Judge wrote, As a population, prison inmates are around nine times more likely to commit suicide than free persons, and yet not every prisoner who shows signs of depression or exhibits strange behavior can or should be put on suicide watch. Matos v. OSullivan, # 02-1590, 2003 U.S. App. Lexis 13427 (7th Cir. 2003).
Click here to read the case on the Internet. [PDF]
Part Two Employment Law
Psychological Exams and Standards
Impairment or Disability Under ADA or Rehab Act
EEOC District Office finds that a police officer was disabled and that ordering him to submit to additional fitness for duty evaluations was unlawful.
Because of several encounters with coworkers, a Phoenix area police officer was ordered to participate in a psychological fitness for duty evaluation (FFDE). Under IACP guidelines, the purpose of a FFDE is to identify the presence or absence of job-related personality traits, characteristics, disorders, propensities, or conditions that would interfere with the performance of essential job functions.
At the first two meetings with the psychologist, the officer did not finish the battery of tests. The psychologist supposedly informed management that although the testing process was incomplete, the officer was not psychologically fit for duty. At a third meeting with the psychologist, his commander and three officers placed him on FMLA leave, relieved him of his ID and weapon, and escorted him home.
The officer filed a disability complaint with the local office of the EEOC, alleging the city considered him to be disabled. In response to that complaint, the citys Human Resources Administration replied that the officer had demonstrated behaviors such as nervousness, lack of appetite, staring, inability to focus, repeating himself, sudden mood swings and excessive anger ...
One sergeant reported that the officer yelled, pounded the walls ... and periodically ranted about [the] chief ... A fellow officer had said the complainant was paranoid and negatively obsessed with [the] Chief of Police and was on the verge of tears. The city denied regarding the officer as disabled or engaging in discriminatory treatment.
The EEOC has issued a determination that the city failed to provide any specificity that would justify their position or otherwise establish that he was a direct threat to anyone. Moreover, continued efforts by an employer to require an employee to provide more documentation and/or submit to additional medical examinations could be considered retaliation.
The EEOC found that the officer had a disability and was discriminated against by requiring him to submit to a psychological examination, in violation of the ADA and by denying his request to return to active duty after the officers physician declared him fit for duty.
The officer, during the pendency of the EEOC complaint made an application for a disability retirement, but withdrew the application on the advice of his attorney. EEOC ex rel. Tucker and City of Tempe Police Dept., # 350-A1-2326 (2002).
Click here to view the EEOCs Determination on AELEs website.
Click here to read or download the IACP Psychological Sections Fitness For Duty Guidelines.
Also see the Tempe Police policy on Fitness for Duty examinations.
Click here to read or download EEOCs Enforcement Guidance on the ADA and Psychiatric Disabilities.
Research Note: Technically, a District Office Determination is a nonprecedential and nonbinding administrative decision. Although not mentioned in the EEOCs Determination, once an employee returns from authorized FMLA with a letter, from the employees health care provider, recommending a return to work, the employer may NOT order a confirming examination, 29 U.S. Code 2614(a)(4) and 29 C.F.R. 825.310(c). There are two recognized exceptions:
1. There is a history of requiring return-to-duty such exams (and if there is a bargaining agreement, it perpetuates recognized past practices). Conroy v. Township of Lower Merion, # 00-CV-3528, 2001 U.S. Dist. Lexis 11460, 7 WH Cases2d (BNA) 365 (Unpub. E.D. Pa.).
2. The request is based on behavior that is observed subsequent to the return to duty request. Routes v. Henderson, 1999 U.S. Dist. Lexis 9835, 5 WH Cases2d (BNA) 768 (Unpub. S.D. Ind. 1999); Underhill v. Willamina, 1999 U.S. Dist. Lexis 9722 (Unpub. D.Ore. 1999); Albert v. Runyon, 6 F.Supp.2d 57, 1998 U.S. Dist. Lexis 7505 (D.Mass. 1998).
The FMLA is not enforced by the EEOC, but by the Wage and Hour Div. of the U.S. Dept. of Labors Employment Standards Administration. Under the ADA, the EEOC enforces employment-related complaints, and the Justice Depts Civil Rights Div. enforces access-related complaints.
As stated in the Postal Service case, Albert v. Runyon:
The FMLA does not authorize an employer to make its own determination of whether an employee is fit to return from FMLA leave following recovery from a serious health condition. Rather, an employer must rely on the evaluation done by the employees own clinician and return the employee to work without delay upon receipt of medical certification. This certification may be a simple statement of any employees ability to return to work, and need not contain the specific information about the employees condition ...
Moreover, requiring [the employee] to undergo a psychological examination was not the proper way for the Postal Service to resolve any legitimate concerns it might have had about her abilities and possible restrictions on her activities. An employer with questions about the scope or adequacy of a medical certification may take advantage of the FMLA provision allowing it to contact the employees clinician for clarification, but may not force an employee to submit to a further examination before allowing her to return to work. 6 F.Supp.2d 57 at 62-63, 1998 U.S. Dist. Lexis 7505 at *15-16.
Click here to read the Labor Depts regulation 29 C.F.R. 825.310, Under what circumstances may an employer require that an employee submit a medical certification that the employee is able (or unable) to return.
Psychological Exams and Standards Retaliation
EEOC appellate decision finds that a postal worker was retaliated against by management after she reported sexual harassment. Backpay awarded for a suspension for refusing to take an unnecessary fitness-for-duty examination plus $50,000 in damages for mental anguish.
A postal worker filed several equal employment opportunity complaints, alleging that various incidents constituted unlawful employment discrimination, and were in reprisal for complaining about sexual harassment.
Among other things, management transferred her to a facility where she was required to perform work inconsistent with her medical restrictions, berated her in public about her sexual harassment complaint and suspended her for 312 hours for refusing to take an unnecessary fitness-for-duty psychological exam.
The Commission noted that, irrespective of whether an employee is an individual with a disability, an agency may only make a disability-related inquiry or require a medical examination if it is job related and consistent with business necessity.
The Postal Service was required to issue backpay for the 312 hours of work the complainant missed while under suspension for failing to comply with an unnecessary fitness-for-duty examination, and pay her $50,000 for non-pecuniary harm (prolonged mental anguish, depression, humiliation, insomnia, etc.) suffered as a result of the agency's discriminatory action.
Amen v. Potter, U.S. Postal Service, Appeal #07A10069, 2003 EEOPUB Lexis 53 (EEOC 2003).
Click here to read the decision on the AELE website.
Editors Note: A federal court in New York has held that a state employee who alleged that after filing discrimination complaints with the union and with his superiors, he was forced to undergo retaliatory psychiatric evaluations as a condition of employment, has sufficiently alleged material adverse employment actions to survive a motion to dismiss. Syken v. New York, #02-Civ-4673, 2003 U.S. Dist. Lexis 5358, 91 FEP Cases (BNA) 1065 (S.D.N.Y. 2003).
Another federal court dismissed a civil rights suit filed by an ex-police officer who alleged that she was subjected to I-A investigations, criminal charges, and a psychological fitness test because of her gender. She failed to adduce any evidence of bias or bad motives. Zandhri v. Dortenzio, #3:99CV1776, 228 F.Supp.2d 167, 2002 U.S. Dist. Lexis 21048 (D.Conn. 2002).
Fitness for Continued Duty
Civil Service Commission terminates a police officer for having Disordered Personality Traits. Supreme Court denies review.
In March of 1999, a Salt Lake City police officer was involved in an incident that resulted in a determination that he had acted unprofessionally and had violated the Citys deadly force policy.
The officer was examined by Dr. David McCann, who, in March of 2000, submitted to the City the following conclusions regarding Joseph:
[He] has Disordered Personality Traits which have contributed to him placing himself in jeopardy in the shooting incident and in other incidents. Officer Josephs personality traits have caused him to be excessively self-centered and unwilling to learn from peers or superiors.
His personality traits are likely to lead him to increased isolation and alienation from appropriate professional supervision and the needs of the citizens of Salt Lake City. Personality traits similar to those of Officer Josephs are notably resistant to psychotherapeutic intervention, additional training, closer supervision or disciplinary action.
His personality traits cause an increased risk for harm to himself, to other officers and to the citizens of Salt Lake City. In [Dr. McCanns] opinion, Officer J__ is not psychologically suitable to perform the duties of a police officer.
Management terminated the officer, and he appealed to the Civil Service Commission. The appeal was dismissed due to a failure to comply with discovery demands.
Without reaching the merits of the termination, the Utah Court of Appeals affirmed. Joseph v. Salt Lake City Civil Serv. Cmsn., # 20010399, 2002 UT App. 254, 53 P.3d 11, 2002 Utah App. Lexis 72; certiorari denied, # 02-1211, 71 U.S.L.W. 3666 (U.S. Sup.Ct. 2003).
Click here to read the decision on the Internet.
Stress Related Claims and Defenses
A California appeals court affirmed an order to reinstate a deputy sheriff, who received a workers comp. stress award. County could not refuse to reinstate the deputy because she needs a stress-free work environment. Hanna v. Los Ang. Co. Sheriffs Dept., # B150425, 67 Cal. Comp. Case 1320, 2002 Cal. Wrk. Comp. Lexis 1528, 102 Cal.App.4th 887, 125 Cal.Rptr.2d 686 (2nd App. Dist. 2002). [PDF]
The Pennsylvania Supreme Court found that a death threat to a police officer and his family was unusual, even for a law enforcement officer, because it included a $50,000 bounty and death threats to the officers children at school. These were not part of a normal officers experiences and stress compensation benefits were appropriate. City of Pittsburgh v. Logan, # 95 WAP 2001, 810 A.2d 1185 (2002). [PDF]
An Arizona state trooper won disability benefits for PTSD. The state claimed that shooting suspects was not an unexpected event as required by state compensation laws. Expert testimony supported his claim, and the compensation judge ruled that shooting and killing another human being in the line of duty is an extraordinary stress related to the employment. [David] Mogel v. Dept. of Public Safety, Ariz. Indus. Cmsn. (Unrptd., 2002).
Hawaiis Supreme Court upheld a disability claim by a firefighter who suffered emotional distress because of what he perceived to be a flawed promotional process, and a threat of retaliation by the chief when he appealed the outcome. Davenport v. C&C of Honolulu, # 23141, 100 Haw. 481, 60 P.3d 882, 2002 Haw. Lexis 850 (Haw. 2002).
A Pennsylvania appeals court affirmed the right of a woman police lieutenant to recover benefits for stress resulting from male harassment because of her promotions. The city had failed to seriously investigate her claims in a timely manner. Sloan v. City of Pittsburgh Police Dept., # 1024 C.D. 2002 (Unpub., Pa. Commw. 2003).
A former employee who claimed that he suffered emotional stress because of the work environment did not place his mental condition in controversy so as to justify a court-ordered psychiatric examination. He did not claim an ongoing mental injury or a psychiatric disorder and he did not sue for the intentional or negligent infliction of emotional distress. Bowen v. Parking Auth. of Camden, # 00-5765, 214 F.R.D. 188, 2003 U.S. Dist. Lexis 6913 (D.N.J. 2003).
An arbitrator held that a grievant was eligible for assault leave, even if she did not file the proper form. She also was being treated for post-traumatic stress disorder/panic attacks with agoraphobia, and the filing of a wrong form did not prejudice the employer. Chicago Bd. of Educ. and Chicago Teachers Union, 118 LA (BNA) 349 (Goldstein, 2002).
The New Jersey Supreme Court revived the workers comp. claims filed by two police employees who suffered work-related, delayed onset, post traumatic stress disorder. PTSD can be either a disease or an accident. Brunell v. Wildwood Crest Police Dept., # A-126/127 Sept. Term 2001, 176 N.J. 225, 822 A.2d 576 (N.J. 2003).
Whistleblower Protection Laws
Federal court upholds the right of management to fire a prison psychologist who released confidential records to public advocates and the news media. Whistleblower laws protect only those who report misconduct to the appropriate public officials.
A prison psychologist sued, claiming that management violated his First Amendment rights by firing him in retaliation for objecting to racial discrimination in parole determinations and employment practices
Management said the psychologist was fired for violating the Dept. of Corrections Code of Ethics. The plaintiff admitted that he released confidential inmate psychological reports to a prison reform advocate, a local NAACP official, and to Fox-TV News in an effort to reveal racial discrimination in parole determinations.
The court said that the dissemination of confidential prison records, involved a matter of public concern. However, this did not outweigh the prisons interest in keeping such records confidential.
Although the plaintiff had a right to speak out, and the public should hear about charges of discriminatory treatment, the institution had an overriding interest in keeping inmate psychological reports confidential. The judge wrote:
... common sense dictates that such records contain highly personal and sensitive information that is designated confidential for a number of valid reasons. Not the least of these reasons, we presume, is that such reports are generated as a result of psychological care that is designed to both treat inmates and evaluate their potential for rehabilitation and possible parole.
If psychological evaluations are not kept confidential, inmates may be less likely to frankly discuss their problems, hampering any possibility they may have for rehabilitation. Similarly, prison psychologists may be less likely to record their conclusions with necessary candor out of fear that they could become public.
Consequently, the release of confidential, psychological records of inmates has a detrimental and possibly profoundly negative effect on important aspects of [the institutions] public responsibilities.
The court noted that under the states Whistleblower Law, the plaintiff had an approved avenue for disclosing racial discrimination in parole determinations. However, the Whistleblower Law does not protect the release of inmate psychological records to the news media and public advocates.
The judge concluded that the DoCs interest in the efficient operation of its organization outweighs the free speech rights of the plaintiff to distribute confidential psychological records to non-authorized persons. Dennison v. Penna. Dept. of Corrections, #3:01cv56, 2003 U.S. Dist. Lexis 9579 (M.D. Penna. 2003).
Click here to view the opinion on the AELE website. [PDF]
Click here to view the American Psychological Associations ethical standards relating to privacy and confidentiality of personal information.
Part Three Selected Articles
(In chronological order)
Article, No Recall of Weapon Discharge, by Alexis Artwohl, Ph.D., 3(2) Law Enf. Executive Forum 41 (2003).
Article, Perceptual and Memory Distortion During Officer-Involved Shootings, by Alexis Artwohl, Ph.D., 2002 (10) FBI Law Enf. Bulletin 18 - online in PDF format at www.fbi.gov/publications/leb/2002/oct02leb.pdf
Law Outline: Equal Employment Opportunity Commission: Selected case law developments under the Americans with Disabilities Act. Download an 82 page summary in Ms-Word and then search the text for psych and mental.
Law Annotation: Liability of doctor, psychiatrist, or psychologist for failure to take steps to prevent patients suicide, 81 A.L.R.5th 167, sec. 3 (1999).
Law Review: Unconscious bias and self-critical analysis: The case for a qualified evidentiary equal employment opportunity privilege, 74 Wash. L. Rev. 913 (1999).
Law Note: Is a personality test a pre-job-offer medical examination under the ADA?, 93 Nw. U.L. Rev. 597 (1999).
Law Note: Beyond Jaffee v. Redmond: Should the federal courts recognize a right to physician-patient confidentiality?, 58 Ohio St. L.J. 1809 (1998).
Law Review: Is employee privacy an oxymoron?, 15 Delaware Lawyer 20 (1997).
Law Note: The quest for the honest worker: a proposal for regulation of integrity testing, 49 SMU L. Rev. 329 (1996).
Law Note: Integrity tests: Do they have any integrity?, 6 Cornell J. L. & Pub. Poly 211 (1996).
Law Review: Employees with mental and emotional problems workplace security and implications of state discrimination laws, the ADA (etc.), 24 Stetson L. Rev. 201 (1994).
Law Review: Preplacement examinations and job-relatedness: how to enhance privacy and diminish discrimination in the workplace, 49 U. Kan. L. Rev. 517 (1994).
Law Note: To catch a thief: The private employers guide to getting and keeping an honest employee, 63 UMKC L. Rev. 251 (1994).
Law Review: Privacy regulation of computer-assisted testing and instruction, 63 Wash. L. Rev. 841 (1988).
Law Review: Medical and psychotherapy privileges and confidentiality: On giving with one hand and removing with the other, 75 Ky. L.J. 473 (1986).
Law review articles and notes are accessible with Lexsee , a service of Lexis-Nexis. A.L.R. annotations are accessible on Westlaw . The EEOC outline is on the American Bar Assn. website.
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