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Ideally, justice for mass atrocities would be meted out by national courts in the jurisdiction in which the crimes were committed. Due to political and practical constraints, however, this task is sometimes delegated to international tribunals and foreign courts that are able and willing to prosecute such cases. In the United States, human rights litigators have recourse to many federal statutes establishing civil and criminal penalties for war crimes, crimes against humanity, and genocide. Academics and practitioners have argued in favor o f three main avenues o f international justice in U.S. courts: (1)federal tort claims, (2)federal criminal prosecution, and (3) state tort claims. This article argues that a fourth must be opened: (4) state criminal prosecutions. Whereas Congress is a body o f enumerated powers, state legislatures may prescribe criminal law subject only to the limitations set forth by the Constitution. States are empowered to prescribe criminal sanctions where Congress has not or cannot. Where the scope o f existing statutes is too limited to fidly capture the unconscionable injustices faced by survivors, state criminal law could fill the void. This Article discusses the viability o f state criminal prosecutions as a domestic model o f international justice by analyzing the only statute that currently permits such proceedings: Articles 299 and 300 o f the Puerto Rico Penal Code, which respectively codijy genocide and crimes against humanity. Part I defines four typologies o f justice fo r atrocities available within the U.S legal system and makes the case for pursuing criminal justice in state courts. Part II builds on these typologies to survey the current state o f U.S. atrocity law, and then introduces Puerto Rico's own atrocity crimes legislation. Part III analyzes the Puerto Rico statute, with an emphasis on its crimes against humanity provision. Part IV addresses several challenges that state atrocity crimes statutes might face. [ABSTRACT FROM AUTHOR]

The article focuses on the Saint Charles Circuit Court Case Samuel S. Watson v. Robert P. Farris which was filed regarding the political, cultural, and religious conditions of Missouri after the Civil War. It illustrates conflict over the Linden Wood Female College between the Northern and Southern branches of the Presbyterian Church in the U.S. It adds that Missouri-based Presbyterian Church could not make decision on slavery and political loyalties.

Exocrine pancreatic insufficiency (EPI) is frequently seen in patients with pancreatic cancer (PDAC) and is thought to contribute to nutritional complications. While EPI can be pharmacologically temporized with pancreatic enzyme replacement therapy (PERT), there is lack of clear evidence informing its use in PDAC. Here we aim to survey pancreatic surgeons regarding their utilization of PERT in the management of EPI for PDAC. An online survey was distributed to the members of The Americas Hepato-Pancreato-Biliary Association (AHPBA) and The Pancreas Club. 86.5% (180/208) of surgeons prescribe PERT for at least some resectable/borderline resectable PDAC cases. Only a minority of surgeons order investigations to confirm EPI before starting PERT (28.1%) or test for adequacy of therapy (28.3%). Few surgeons believe that PERT has an effect on overall survival (19.7%) or disease-free survival (6.25%) in PDAC. PERT is widely prescribed in patients with resectable/borderline resectable PDAC, but investigations establishing EPI and assessing PERT adequacy are underutilized. A substantial proportion of surgeons are unclear as to the effect of PERT on survival outcomes in PDAC. These data call for prospective studies to establish guidelines for optimal use of PERT and its effects on survival outcomes in PDAC. [ABSTRACT FROM AUTHOR]