Dancing on the head of a pin? Foetal life and the european convention

The case of Vo v. France represents the latest phase of the European Court of Human Rights’ thinking on the scope of Article 2 of the European Convention on Human Rights (the right to life) in relation to foetal life where a foetus had been lost owing to a medical accident. The Court by a majority decided that, “even assuming” Article 2 applied to the instant case (albeit to the life of the pregnant woman rather than that of the foetus), it had not been violated. While the facts in Vo were extreme and exceptional, the Court will shortly hear the case of D v. Ireland concerning access to abortion for foetal anomaly, an application made under Articles 3, 8, 10 and 14 of the European Convention. If the case of D were declared admissible, the Court would then have to consider whether a denial of access to abortion for foetal anomaly constitutes inhuman and degrading treatment contrary to Article 3, or an interference with a pregnant woman’s right to respect for private life under Article 8 (and if so, how the doctrine of the margin of appreciation applies). The Grand Chamber precedent of Vo displays ambivalence about whether Article 2 should apply to foetal life, and its resort to the “even assuming” formula spared Member States the difficulty of having to justify their various abortion regimes, by reference to this Article. It remains to be seen whether in a case like D that is directly concerned with abortion, the Court will take a more definite stance on the correct balance to be struck between the State’s interest in protecting foetal life and the Convention rights of pregnant women. Vo v. France [G.C.], judgment of 8th -July 2004, no. 53924/00; D v. Ireland [4th section], no. 26499/02, oral hearing on admissibility and merits, 6 September 2005     

What's different about truants? A comparison study of eighth-graders

Differences and similarities between 25 eighth-grade truants and 25 nontruants-matched for age, grade, gender, and ethnicity-were explored on four dimensions: family variables, friendship patterns and interests, behavior and attitudes toward school, and cognitive factors including academic ability and achievement. The major differences were in school behavior, attitudes, academic ability, and achievement. The most frequent reasons given for truancy were boredom and dislike of school and teachers. Truancy was associated with highly disruptive classroom behavior. The salience of school variables suggests that truancy prevention and intervention strategies should include improved course content, teaching, and school climate. The necessity of having a comparison group is stressed in order to distinguish characteristics of normal adolescent development from those associated with maladjustment.Received Ph.D. from University of California, Davis. Current interests are early adolescents' development and school environment.     

The role of emotional abuse in physically abusive relationships

Two hundred thirty four women were interviewed to assess the relationship of emotional abuse to physical abuse. Six major types of emotional abuse were identified. Analyses determined if the types of emotional abuse were related to the frequency and severity of physical abuse. Women in long-term abusive relationships were contrasted with women experiencing only short-term abuse. Other comparisons consisted of: women who thought emotional abuse was worse than physical abuse vs. women who thought the opposite; and women who could predict physical abuse from the emotional abuse were compared with those who could not. The extent to which the women believed the men's threats and ridicule or thought their abusive behavior was justified was used as a factor to determine the impact of emotional abuse. Future research should investigate emotional abuse patterns in nonbattering relationships for comparison with battered women's experiences.