1 Texas Law Review See Also Volume 95 Response Understanding Immigrant Protective Policies in Criminal Justice * Eisha Jain Introduction Criminal penalties are meant to be the most severe state type of 1 Today, however, collateral consequences — state - sanction. civil imposed can systemically penalties triggered by a conviction or even an arrest — 2 outstrip the formal criminal sentence. Nowhere is this pattern more visible than in the immigration context, particularly where deportation follows 3 from a relatively minor conviction. Too often, immigration consequences are analyzed solely from the perspective of the defense attorney or the defendant . But it would be a *Assistant Professor of Law, University of North Carolina School of Law. Thank you to Jack Chin, Ingrid Eagly, and Brandon Garrett for thoughtful feedback. . The Morality of Means: Three Problems in Criminal Sanctions , 42 U. 1 Francis A. Allen, ITT . L. R EV . 737, 738 (1981) (describing criminal law as the “ heavy artillery ” of society). P R . Arrests as Regulation , 67 S TAN . L. Eisha Jain, EV . 809, 810 (2015) (discussing collateral 2 consequences stemming from arrests). A growing body of scholarship discusses the pervasiveness of collateral consequ ences. See generally Margaret Colgate Love, Managing Collateral Consequences in the Sentencing Process: The Revised Sentencing Articles of the Model Penal Code , 2015 W IS . L. R EV . 247 (2015); Sandra Mayson, Collateral Consequences and the Preventative Stat e, N OTRE D AME L. R EV . 301 (2015); Michael Pinard, Criminal Records, Race 91 P , 16 J. and Redemption L EGIS . & N.Y.U. UB . P OL ’ Y 963 (2013); Gabriel J. Chin, The New Civil Death: Rethinking Punishment in the Era of Mass Conviction , 160 U. P A . L. R EV . 1789 (2012). 3 For a discussion of minor convictions that can trigger deportation, see Jason A. Cade, The . Plea - Bargain Crisis for Noncitizens in Misdemeanor Court , 34 C ARDOZO L. R EV . 1751, 1815 L. (2013) De Facto Immigration Courts , 101 C ALIF . ; Stephen Lee, R EV . 553, 560 – 61 (2013).
2 162 [Vol. 95 : 161 Response de fendants Ingrid mistake to assume that deportation only matters for . s insightful article, Immigrant Protective Policies in Criminal Eagly ’ Justice, situates immigrant protective policies in a broader system of 4 criminal law administration. Her analysis demonstrates that immigration changer. The possibility of deportation ing a game consequences are becom - alters law enforcement decisions, including the practices of prosecutors and 5 police. Awareness of collateral consequences can lead police, prosecutors, — at times, significantly — from and other criminal law actors to deviate This were what they would do if only the criminal law penalty on the table. dynamic is systemic; it is not just confined to how a particular prosecutor given approaches a plea in any case. Awareness of collateral consequenc es can change the way that law enforcement agencies evaluate and exercise 6 their discretion. This dynamic reflects local ized, discretionary judgments in response to competing priorities. regulatory ’ s discussion This Response has two aims. First, Part I situates Eagly immigrant protective policies in the context of recent federal efforts to of ” “ sanctuary regulate jurisdictions. It takes as a starting point Eagly ’ s “ ” “ sanctuary ” or “ insight that the terms ” do not capture how and integration why prosecutors and other law enforcement officials respond to collateral consequences. It argues for the need to unpack the motivations that guide law enforcement officials in responding to collateral consequences. Part I I considers the implications of Eagly ’ s analysis in light of a Second, 7 broader blurring of the boundaries of civil and criminal law. I seek to complement Eagly ’ s study by considering its implications for other types of collateral consequences. I . “ Immigrant Pro tective ” Policies and “ Sanctuary ” Jurisdictions Scholars and advocates have long complained that rhetoric surrounding immigration enforcement misleading. An emphasis on is EV Immigrant Protective Policies in Criminal Justice , 95 T EXAS L. R Ingrid Eagly, . 245 4 . (2016). 5 . For a discussion of this dynamic in the context of plea bargaining and charging decisions, Prosecuting Collateral Consequences , 104 G EO . see Eisha Jain, J. 1197 (2016). L. 6 For other work in this vein, see Ingrid V. Eagly, Criminal Justice for Noncitizens: An . EV N.Y.U. Analysis of Variation in Local Enforcement, R 88 . 1126 (2013); Gabriel J. Chin, L. Illegal Entry As Crime, Deportation As Punishment: Immigration Status and the Criminal Process , 58 UCLA L. R EV . 1417, 1420 (2011) ( “ Far from being ‘ separate and independent from the criminal proceeding, ’ deportation and other aspects of immigration status are often key a criminal case. ). considerations in the disposition of ” 7 . This is not say that immigration enforcement is not unique. Immigration law enforcement and criminal law enforcement have become intertwined to an exceptional degree. Ingrid V. Eagly, , 104 N W Prosecuting Immigration U. L. R EV . 1281, 1354 (2010); David A lan Sklansky, Crime, . Immigration, and Ad Hoc Instrumentalism , 15 N EW C RIM . L. R EV . 157, 161 (2012). Merged criminal and immigration enforcement also creates particular potential for racial profiling. Devon L. Undocumented Crim inal Procedure , 58 UCLA W. Carbado & Cheryl I. Harris, R EV . 1543, 1573 (2011).
3 201 7 Response 163 ] border enforcement, for instance, fails to acknowledge the reality that many 8 unauth The terms “ illegal alien ” or orized immigrants enter legally. ” the reality that immigration status is not permanent “ criminal alien obscure 9 Eagly s analysis ’ and these labels encompass quite distinct statuses. ” suggests that the term is likew ise deeply misleading when “ sanctuary to criminal law enforcement. The term has been employed at times applied 10 criminals to go free. ” “ to depict sanctuary cities as localities that allow in criminal justice immigrant protective But as Eagly points out, policies have little to do with a commitment to concepts such as sanctuary or may Rather, they are motivated by priorities of local immigrant integration. the law enforcement agencies , including the need to combat crime effectively lationships with local communities . Jail policies that limit and forge re cooperation with federal immigration detainers are motivated in some also localities ’ desire to avoid paying for federal immigration cases by 11 stitutional They are also affected by c on constraints, enforcement efforts. 12 the obligation not to detain anyone without probable cause. including provides an important analytic framework for understanding Eagly these policies. The concerns that animate law enforcement agencies in shielding some immigrants from deportation are not public necessarily with deportati on decisions across the board. Eagly policy disagreements analy zes four California counties in detail — Alameda, Los Angeles, Santa — that are “ perceived as having at least some criminal Clara, and Ventura 13 ” They are also all located in one justice policies that protect immigrants. 14 - of the most immigrant n the United States. Prosecutors in friendly states i each of these counties selectively recognize immigration and other collateral consequences as a punishment. In taking this approach, 8 Eight Myths About Immigration Enforcement , 10 N.Y.U. J. L EGIS . & . David A. Martin, – UB P OL ’ Y 5 25, 543 44 (2007) (noting the difficulty of effe ctive border enforcement, given P . 88,000 miles of tidal shoreline, the possibility of unlawful entry along the Canadian border, and the presence of a large unauthorized population who entered legally but overstayed a visa). . See, e.g. , Ingrid V. Eagly, 9 Criminal Justice for Noncitizens: An Analysis of Variation in Local Enforcement, 88 N.Y.U. L. R EV . 1126, 1136 – 37 (2013) ( “ For some time now, American rp distinction between lawful immigrants thinking about immigration has articulated a sha ’ and ‘ On the ground, however, the practical meaning of the line between - so illegal aliens. ’” called ‘ lawful and unlawful status in immigration law is far less clear. ” ). 10 . Jasmine C. Lee, Rudy Omri & Julia Preston, What Are Sanctuary Cities? , N.Y. T IMES (Sept. 3, 2016), http://www.nytimes.com/interactive/2016/09/02/us/sanctuary - cities.html [https:// - “ “ sanctuary ” was widely used in the 1980s by perma.cc/7KZG churches, YE2J]. The term ” who challenged U.S. charities, city councils, refugee services organizations and others, immigration policy and sought resettlement for undocumented immigrants fleeing from El Salvador and Central America. Eish a Jain, Immigration Enforcement and Harboring Doctrine , 24 G EO . I MMIGR . L.J. 147, 171 – 72 (2010). 11 Eagly, supra note 4, at 293 – 94. . 12 . J ain, supra note 2, n.124 (discussing lawsuits involving unconstitutional over - detentions). note 4, at 249. 13 Eagly, supra . 14 . Id.
4 164 [Vol. 95 : 161 Response “ civil or prosecutors look past the formal doctrinal categories of ” ” “ The y recognize that the penalties that matter during plea criminal. negotiations are those that matter the most to the defendant. “ As Eagly makes clear, the existence of policies ” immigrant protective will necessarily re ceive es do not mean that immigrants facing deportation safe pleas. immigration - For one, the examined policies only apply for “ all four policies acknowledge minor criminal offenses. As Eagly writes, generally will not alter the resolution of the that collateral consequences 15 most serious criminal cas . In addition, the policies allow significant ” es Perhaps because collateral consequences are so room for discretion. ubiquitous, prosecutors appear to establish a relatively high bar for when they take an immigrant protective approach. s proportionality Consider how each of the four offices recognize recogni zes that adverse collateral consequences are concerns. Each office appropriate ” or “ just , ” and that prosecutors should only deviate generally “ from what they view as the routine processing of criminal cases in unusual 16 Thus, the baseline position is that or compelling circumstances. line deportation or another collateral consequence is appropriate; prosecutors need to have some reason, separate and apart from the fact of deportation, to deviate from their standard practice. The Los Angeles ecutors to deviate “ from normal . policy, for instance, permits pros . . 17 . . only in ‘ unusual or extraordinary circumstances. ’” settlement policy . Ventura County likewise states: “ Collateral consequences are generally a 18 normal and just consequence of a criminal conviction. ” Ventura County applies what amounts to a gross disproportionality test — requiring t hat the civil consequence be “ so disproportionate to the severity of the crime and to ” the criminal punishment unjust — before a that its application would be 19 The offices also prosecutor may take immigration status into account. different rules when apply ing if the collateral consequence is determin disproportionate. Some offices, like Ventura, look at both the charged conduct and the criminal penalty, while Santa Clara looks at whether the 20 significantly greater than the crimin al penalty. “ collateral impact is ” “ immigrant protective ” jurisdictions, The policies indicate that even in “ ” pleas. defendants are by no means guaranteed immigration safe collateral consequences at the time of Defendants may also not be aware of 15 Id. at 269. . 16 Id. 268 – 69. . 17 . Id. at 269 (quoting Special Directive 03 - 04 from Steve Cooley, L.A. Cty. Dist. Attorney, to All Deputy Dist. Attorneys (Sept. 25, 2003)). 18 . Id. (quoting O FFICE OF THE D IST . A TTORNEY , C TY . OF V ENTURA , L EGAL P OLICIES M § 4.01(A)(1) ( Dec . 31, 2014)). ANUAL 19 Id. . 20 . Id. (quoting Memorandum from Jess Rosen, Santa Clara Cty. Dist. Attorney, to Fellow Prosecutors 2 (Sept. 14, 2011 )).
5 201 7 Response 165 ] 21 Thus, pr osecutors may assume that civil penalties are the plea agreement. even appropriate important information about the when defendants lacked consequences of a guilty plea. - Collat eral Consequences and the Civil I Criminal Divide I . ve important implications beyond the I mmigrant protective policies ha 22 Padilla v. Kentucky context of deportation. the Supreme Court for the In , enmeshed ” with the criminal justice first time characterized deportation as “ held that defendants were entitled to advice about certai n system and 23 immigration consequences before pleading guilty. This raises the approach question of whether a should be taken in other contexts, similar 24 In practice, a number of such as pension loss or civil confinement. collateral consequences can matter far more to defendants than criminal 25 As Jenny Roberts has argue d , rather than adopting penalties. - line a bright n distinction between criminal and civil conseque better approach is to ces, a “ ’ s situation would deem ask whether a reasonable person in the defendant knowledge of the consequence, penal or otherwise, to be a significant factor 26 in deciding whether to plead guilty. ” Collateral consequences can expand the impact of law enforcement discretion. Prosecutors establish their own rules for when and how they cognize collateral consequences. re ial As Eagly writes, prosecutor recognition of collateral consequences may be necessary for a “ legitimate system of criminal punishment ” that treats “ each person with dignity and 27 respect. Yet there is an important differ ence between the prosecutor who ” to recognize collateral consequences as punishment and the chooses . Defendants, for instance, might not be aware of collateral consequences other than 21 possible but not mandatory . deportation, or they might not be informed th at deportation is For an influential discussion of the role of defense attorneys in advising about collateral consequences, see Gabriel J. Chin & Richard W. Holmes, Jr., Effective Assistance of Counsel and the , 87 C ORNELL L. R EV . 697, 699 (2002) (arguing for a duty to warn). Consequences of Guilty Pleas . 22 559 U.S. 356 (2010). . . at 365. 23 Id . Courts vary on whether Padilla applies to other contexts. Compare 24 People v. Hughes, 983 N.E.2d 439, 457 59 (Ill. 2012) (holding that defense counsel ’ s failure to warn about civil – te v. Trotter, 330 P.3d confinement following conviction was sufficient to invalidate plea) with Sta 1267, 1271 (Utah 2014) (declining to extend Padilla to civil confinement); State v. LeMere, 879 N.W.2d 580, 588 (Wis. 2016) (holding “ that the Sixth Amendment does not require counsel to advise defendants regarding the possibility o f civil commitment following a guilty plea). See ” Abraham, 62 A.3d 343 , 353 (Pa. 2012) ( holding that defendant was not also Commonwealth v. ). entitled to be warned about pension loss before accepting the plea . Jenny Roberts characterizes the distinction between criminal and civil consequences as 25 “ mythical. ” Jenny Roberts, The Mythical Divide Between Collateral and Direct Consequences of Criminal Convictions: Involuntary Commitment of “ Sexually Violent Predators , ” 93 M INN . L. R . 670 (2008). EV 26 . Id. at 674. 27 . Eagly, supra note 4, at 295.
6 166 [Vol. 95 : 161 Response the prosecutor who is bound by formal legal recognition that a penalty punishment. constitutes riminal procedure provides a set of constraints on C . By law enfor cement officials when it comes to formal criminal penalties collateral consequences , prosecutors set contrast, This with the rules. dynamic gives prosecutors the ability to selectively and at times 28 inconsistently respond to collateral consequences. Prosecutors who respond to disproportionate collateral consequences The ir face competing priorities. interest in proportio nate outcomes may conflict with an interest in treating defendants who commit similar crimes 29 or This dynamic leads to the pr actice of “ exacting a premium the same. ” 30 counterbalancing. ” When prosecutors agree to immigration - safe pleas, “ “ compensate ” they may for that concession by seeking harsher criminal penalties. They may also view this approach as a way to authenticate ” the “ 31 For instance, the Ventura policy states that collateral consequence. may insist upon more custody time or a longer period of “ prosecutors as a “ concession, ” or as a way to ensure that the defendant probation ” 32 consequence. ” For the prosecutor, actually fac[es] the claimed collateral “ ’ s willingness to accept a more severe criminal penalty can the defendant provide a way to verify that the defendant actually faces the collateral consequence. time. The authentication approach offers prosecutors a way to save When prosecutors But it also elevates legally irrelevant considerations. make judgments based on efficiency considerations, as opposed to judgments about culpability and proportionality, this dynamic creates another layer of distortions that warp [s] the fair allocation of “ 33 ” This dynamic may be particularly difficult to identify in the punishment. , given that p context of collateral consequences rosecutorial responses to 28 . For a discussion of this dynamic in other contexts, see Jennifer M. Chacón, Producing Liminal Legality , 92 D E NV . U. L. R EV . 709, 729 (2015) ( “ Basic liberties — freedom of movement, family unification, freedom from detention — are bestowed as an act of grace [exercised by law ” ). enforcement officials], not of right. Sara Sun Beale, flicting Goals . Prosecutorial Discretion in Three Systems: Balancing Con 29 in D ISCRETIONARY C RIMINAL J and Providing Mechanisms for Control , USTICE IN A OMPARATIVE ONTEXT 28 – C ance “ competing goals of C 29 (2015) (arguing that prosecutors bal ” accountability, neutrality, efficiency, accuracy, and equal treatment and that the U.S. criminal justice system s “ heavy reliance on prosecutorial charging discretion . . . raises significant ’ nsistent treatment of similarly situated individuals ” ). concerns about accuracy and about inco supra . supra 30 note 4, at 270; Jain, Eagly, note 5, at 1226 (describing the counterbalance approach). 31 . Jain, supra note 5, at 1226. 32 . supra note 4, at 270 – 71 (internal quotation marks omitted). The Santa Clara Eagly, County District Attorney s Office takes a similar appro ach. Id. at 271. ’ 33 . Stephanos Bibas, Plea Bargaining Outside the Shadow of Trial , 117 H ARV . L. R EV . 2463, 2467 (2004) (discussing the trial tax ” and other ways that prosecutors ’ concerns about workloads “ can drive pleas); see also Wayne A. Logan & Ronald F. Wright, Mercenary Criminal Justice , L. 2014 I LL . U. R EV . 1175, 1182 (discussing financial incentives in law enforcement) .
7 201 7 Response 167 ] not likely to be uniform or publicly available. collateral consequences are – Bl criminal boundaries create confusion, both at the level of urred civil law and practice. Some collateral consequences represent the phenomenon of overcriminalization, ” where lawmakers intentionally employ severe “ 34 reflect lawmakers using criminal sanctions without justification. Others arrests and convictions as overbroad and imperfect proxies for other 35 regulatory goals. ese dynamics challenge core notions of Th In theory, crimes ought to be graded in proportionality in sentencing. severity, with more severe consequences reserved for the most serious offenses. But with collateral consequences, what emerges instead is a penalties patchwork of criminal and civil . On a systemic level, law enforcement agencies themselves may also employ imperfect proxies — such as by comparing the severity of the criminal offense to the severity of the civil consequence — to try to create they find roughly proportionate . This dynamic is further outcomes must complicated by the fact that the policies leave room for individual, - level officers to exercise discretion. Prosecutors, police departments, street sheriffs, and others necessarily exercise discretion in determining how to , and they use different yardsticks when seeking impose punishment . As a resu lt, collateral consequences end up being proportionate outcomes across localities. enforced differently As Eagly notes, some within and This system immigrant protective policies are more protective than others. creates significant confusion about who enforces immigration law a nd other It magnifies underlying concerns that key collateral consequences. law 36 take place in a “ black box. ” enforcement judgments Prosecutors do not need to disclose whether and why they make concessions. This dynamic can amplify existing information deficits about 37 decision and police priorities, policing particularly s in communities that 34 . Darryl K. Brown, Criminal Law ’ s Unfortunate Triumph over Administrative Law , 7 J.L . E CON & P OL ’ Y 657, 657 (2011) ( “ Overcriminalization is the term that captures the normative . criminalize things that properly should not be claim that governments create too many crimes and ); Jennifer M. Chacón, Overcriminalizing Immigration , 102 J. C RIM . ” & C RIMINOLOGY crimes. L. – 52 (2012) (arguing that the major problems associated with overcriminalization, such as 613, 647 excessive punishment and unfettered discretion, also apply to the immigration context); Erik The Overcriminalization Phenomenon , 54 A M . U. L. Luna, EV . 703, 716 (2005) R ( Overcriminalization, then, is the abuse of the supreme force of a criminal justice system — the “ ion of crimes or imposition of sentences without justification. ” ). implementat 35 . For a discussion of this phenomenon in the context of arrests, see Jain, supra note 2, at 810 – 11. L. . The Black Box , 94 36 OWA Marc L. Miller & Ronald F. Wright, R EV . 125, 129 (2008). I 37 . See, e.g. , Rachel Harmon, Why Do We (Still) Lack Data on Policing? , 96 M ARQ . L. R EV . 1119, 1121 (2013); Wayne A. Logan & Andrew Guthrie Ferguson, Policing Criminal Justice Data , 101 M INN . L. R EV . 541, 546 ( 2016) (describing how errors in databases can lead to inaccurate arrests, and highlighting significant obstacles to “ [s]etting standards and providing incentives to ensure data accuracy ” in the context of law enforcement).
8 168 [Vol. 95 : 161 Response 38 . contest local law enforcement It also extends the already practices already powerful reach of criminal law enforceme nt agencies to other types of regulatory decisions, including to matters that lie well outside the bounds institutional competence. of law enforcement agencies ’ Even as collateral consequences magnify the impact of law law enforcement discretion, however, they can also tie the hands of enforcement agencies. In some cases, law enforcement officials make the impose too much harm. reasoned judgment that collateral consequence s . But Immigrant protective policies offer a way to ameliorate that harm can come at the expense of other employing immigrant protective policies spend time a scertaining and responding to Prosecutors valuable interests. collateral consequences. may ultimately deviate from their preferred They ment practice law enforce in order to respond to collateral penalties . s Eagly offers a promising conceptual framework immigrant — — equality for thinking about how law enforcement officials should engage quences. with collateral conse This framework recognizes that civil penalties are not just tacked on at the end of the criminal justice process. Rather, awareness of civil outcomes can shape law enforcement behavior from the outset. This dynamic can systemically magnify the effects of 39 contact with the criminal justice system for classes of people. The concept of immigrant equality requires thinking about punishment systemically, rather than in terms of individual moral culpability. Conceptualizing criminal law in this way r equires a departure from traditional criminal law doctrine and theory, which is focused on individual 40 Her approach resonates with Jack Chin ’ s argument that “ the desert. [ ] overall susceptibility to collateral consequences functions as a . , Monica Bell, 38 Police Reform and the Dismantling of Legal Estrangement , 126 See, e.g. ALE L .J. 2054 (2017); Matthew Desmond, Andrew V. Papachristos & David S. Kirk, Police Y Violence and Citizen Crime Reporting in the Black Community , 81 A M . S OC . R EV . 857, 870 – 73 (2016); Song Richardson, Arrest Efficiency and the Fourth Amendment 95 M INN . L. R EV . 2035, , – – citizen interactions). See also 2042 56 (2011) (discussing the effects of implicit bias on police D EP ’ T OF J USTICE C IVIL R IGHTS D IV ., I NVESTIGATION OF THE F U.S. P OLICE ERGUSON D (2015), https://www.justice.gov/sites/default/fil es/opa/press - releases/attachments/ EPARTMENT - NGCJ] (discussing 2015/03/04/ferguson_police_department_report.pdf [https://perma.cc/4SD8 ’ s impermissible focus on revenue, rather than public safety, led to a host how the law enforcement of unlawful and undesirable poli - based wrongful arrests and excessive ce conduct, including race force). 39 . As Eagly writes, “ [i]mmigration policing can shift the priorities and practices of criminal law in ways that promote and disguise profiling of Latinos, Asians, and other people of color, ” “ and she discusses racially and ethnically disparate treatment in prosecution and punishment practi ces that can be promoted by seemingly race neutral immigration enforcement practices. ” supra Eagly, note 4, at 296. 40 . For a related discussion of equality in criminal sentencing , see Richard A. Bierschbach & Stephanos Bibas, What ’ s Wrong With Sentencing Equality? , 102 V A . L. R EV . 1447, 14 51 (2016) (describing the “ equality versus individualization debate” in criminal sentencing as “mask[ing] other substantive and institutional considerations that lie at the heart of sentencing.” ).
9 201 7 Response 169 ] 41 ” Both approaches emphasize that status - based vulnerability punishment. to collateral consequences matter. One way this vulnerability can emerge is through policing, bail, prosecution, or other practices that have a disparate er communities. impact on immigrants or oth Conclusion - criminal divide should not be conceptualized as a bright - The civil line distinction. Collateral consequences of criminal arrests and convictions are often treated as an afterthought — as penalties that can be added on to a crimina l sentence without changing the nature of the criminal justice system. At some point, however, civil penalties systemically alter the behavior of the actors who are tasked with enforcing the criminal law. ’ s analysis provides both an important windo w into how this dynamic Eagly unfolds, as well as valuable insight into how to redress it. 41 . Gabriel J. Chin, The New Civil Death: Rethinking Punishment in the Era of Mass L. Conviction U. P A . , 160 R EV . 1789, 1826 (2012).
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