Dillon's Rule Under the Burger Court: The Municipal Liability Cases

Under the Burger Court, the constitutional relationship betweenstates and their municipalities has been examined primarilyin cases involving private suits initiated against municipalitiesunder federal antitrust and civil rights statutes. Since theCourt's 1943 Parker v. Brown decision, it had been presumedthat municipalities as political subdivisions of states wereas immune as their states from tort liability under the ShermanAntitrust Act. The Burger Court, however, ruled that municipalitiesare not automatically immunized from tort liability simply becauseof their status as political subdivisions unless they can demonstratethat their actions were undertaken pursuant to an expressedstate policy. After 1980, the Court continued to uphold thevulnerability of municipalities to private suits authorizedby federal statutes, but moved to narrow the types of remedyappropriate under common law. The Burger Court did not, therefore,address the more fundamental question of whether municipalitiesas public actors should be liable to private damages in thecourse of their public functions.     

Death resulting from ruptured cerebral artery aneurysm: 219 cases

To characterize the demographics of ruptured cerebral artery aneurysm as a cause of death and to examine the effect of improved diagnostic and therapeutic techniques on the incidence of sudden death associated with the condition, the authors reviewed 219 autopsies performed at the Dallas County Medical Examiner's Office between 1977 and 1997 in which the cause of death was ruptured cerebral artery aneurysm. Ruptured cerebral artery aneurysms accounted for 1.5% of 15,033 natural deaths and 0.4% of all deaths (45,492) followed by autopsy during this period. The majority (56%) of cases occurred in females, with Caucasian females composing the largest group (38%). Seventy-seven percent of cases occurred in individuals between the ages of 31 and 70 years, with the highest concentration in the 41- to 50-year decade (29%). The most common location for ruptured aneurysms was the middle cerebral artery distribution (39%). Multiple aneurysms occurred in 22 (9.1%) cases. Other factors, such as medical history, coexisting disease, symptoms, activity at onset of symptoms, survival time, and toxicology results are also presented. Compared with literature reports before 1980, when ruptured cerebral artery aneurysms were reported as the cause of death in approximately 4% to 5% of sudden natural deaths, the results of this study suggest that despite improved diagnostic and therapeutic techniques during the past two decades, morbidity and mortality from ruptured aneurysms remain a significant health problem.     

Systems Ideologies and Street-Level Bureaucrats: Policy Change and Perceptions of Quality in a Behavioral Health Care System

This article examines the stability of street-level bureaucrats' negative perceptions regarding a newly implemented managed care system on quality of care and service delivery in a publicly funded behavioral health care system. Overall findings indicate that the generally negative perception of managed care did not differ between staff in the two programs, indicating a weak effect on attitudes of frontline workers. More proximal variables to the caregiver, such as service type and job title, show more influence on attitudes. The conclusion discusses the implications of these findings for practicing administrators and academic researchers.