AuthorTitleCitationSummaryYearKey Terms
Hao-Nhien Q. Vu The Law of Treaties and the Export of Hazardous Waste 12 UCLA Journal of Environmental Law & Policy 389 (1994) The public generally sees toxic waste exports as a wrong, not a legitimate activity. This perception is due, in part, to reports indicating a pattern in which a rich country dumps its hazardous wastes in a Third World country, often in an unsafe manner and without properly informing the local community. Accounts of such misdeeds abound. In one... 1994  
Jean Kephart Cipriani The Limits of the Autonomy Principle: Refusal of Life-sustaining Medical Treatment for Incompetent Persons 22 Hofstra Law Review 703 (Spring 1994) A moral position is inherent in every act of selection. This is illustrated by the patent untruth of the aphorism that morality cannot be legislated. Cannot here really means should not and should not itself is a moral construct. Legal values reflecting detachment from moral values in order to encourage tolerance of diverse moral values are... 1994  
Steve Charnovitz The Nafta Environmental Side Agreement: Implications for Environmental Cooperation, Trade Policy, and American Treatymaking 8 Temple International and Comparative Law Journal 257 (Fall, 1994) In August 1992, the Bush Administration began to prepare its formal notice to Congress on a new trade agreement with Mexico and Canada. This notification was a key procedural step in gaining fast track status for trade agreement consideration by Congress. After the broad outlines of the agreement had been announced in August, the Bush... 1994  
Bryan Beier The Perils of Analogical Reasoning: Joseph William Singer, Property and Sovereignty and Property 1 George Mason University Law Review 33 (Spring, 1994) [I]t is characteristic of reasoning by analogy, as I understand it here, that lawyers are not able to explain the basis for these beliefs in much depth or detail, or with full specification of the theory that accounts for those beliefs. Reasoning by analogy is one of the most common and most useful means of thinking about problems. Instinctively... 1994  
Francisco Orrego Vicuna The Protocol on Environmental Protection to the Antarctic Treaty: Questions of Effectiveness 7 Georgetown International Environmental Law Review Rev. 1 (Fall, 1994) Since the Protocol on Environmental Protection to the Antarctic Treaty was signed in 1991, a number of important questions have been raised in relation to its effectiveness and its ability to meet the expectations created at the time of its negotiation. The shared objective of all governments participating in these negotiations was the enhanced... 1994  
Vincent C. Milani The Right to Counsel Native American Tribal Courts: Tribal Sovereignty and Congressional Control 31 American Criminal Law Review 1279 (Summer, 1994) I. Introduction. 1279 II. Background. 1280 A. History of Tribal Courts. 1280 B. Modern Tribal Courts. 1282 1. Nature of Tribal Courts. 1282 2. Tribal Court Criminal Jurisdiction. 1283 3. The Right to Counsel in Tribal Courts. 1284 C. Role of Federal Courts in Tribal Judicial Systems. 1285 1. Federal Court Original Jurisdiction. 1285 2.... 1994 Yes
Karen E. Goldmeier The Right to Refuse Life-sustaining Medical Treatment: National Trends and Recent Changes in Maryland Law 53 Maryland Law Review 1306 (1994) Although scientific advancements in recent years have enhanced the quality of health care for hopelessly and terminally ill patients, new treatment options also have presented patients, families, and health care providers with profound legal and ethical dilemmas. The scope of a guardian's authority to refuse life-sustaining treatment on behalf of... 1994  
Paul G. Cassell The Rodney King Trials and the Double Jeopardy Clause: Some Observations on Original Meaning and the Aclu's Schizophrenic Views of the Dual Sovereign Doctrine 41 UCLA Law Review 693 (February, 1994) In August 1992, the United States Department of Justice filed federal civil rights charges against four police officers for assaulting Rodney G. King, even though they had been acquitted in an earlier state trial. The Department's decision was generally understood to follow constitutional principles of double jeopardy. While the Double Jeopardy... 1994  
Stephen M. Feldman The Supreme Court's New Sovereign Immunity Doctrine and the Mccarran Amendment: Toward Ending State Adjudication of Indian Water Rights 18 Harvard Environmental Law Review 433 (1994) Mark Twain once said that water, taken in moderation, cannot hurt anybody. Taking water from the land, however, even in moderation, may prove terribly damaging to the land itself and those who subsist on it. Water is the lifeblood of the land and consequently the lifeblood of civilization. This truth is nowhere more self-evident than in the arid... 1994 Yes
Amir Pasic Theme Panel I: Theoretical Perspectives on the Transformation of Sovereignty 88 American Society of International Law Proceedings Proc. 1 (April 6-9, 1994) The panel was convened at 4:00 p.m., Wednesday, April 6, 1994, by its Chair, James R. Crawford, who introduced the panelists: Benedict Kingsbury, Duke University School of Law; Karen Knop, University of Toronto; Martti Koskenniemi, Ministry of Foreign Affairs, Finland; and Fernando Tesón, Arizona State University College of Law. This is the first... 1994  
Susan T. Gibbs Theme Panel Iii: Multiple Tiers of Sovereignty: the Future of International Governance 88 American Society of International Law Proceedings 51 (April 6-9, 1994) The panel was convened at 10:15 a.m., Friday, April 8, 1994, by its Chair, Thomas M. Franck, who introduced the panelists in the order of their speaking: Roy S. Lee, United Nations, Office of the Legal Counsel; Paul W. Kahn, Yale Law School; Ruth Wedgwood, Yale Law School; Francis Deng, Senior Fellow at The Brookings Institution and former... 1994  
Richard Ponzio Theme Panel Iv: the End of Sovereignty? Roundtable 88 American Society of International Law Proceedings 71 (April 6-9, 1994) The roundtable to discuss the three earlier theme panels was convened at 10:15 a.m., Saturday, April 19, by its moderator, Professor James R. Crawford, who introduced the panelists and rapporteur. Panelists were Anne-Marie Slaughter Burley, University of Chicago; Thomas M. Franck, New York University School of Law; Rosalyn Higgins, London School of... 1994  
Michael M. Pacheco Toward a Truer Sense of Sovereignty: Fiduciary Duty in Indian Corporations 39 South Dakota Law Review 49 (1994) Federal Indian law ought to be praised for inspiring the Indians' faith in the law but cursed for betraying the believer. The number of Indian corporations is on the rise, and more and more American Indians are becoming part of the corporate world. Today's Indians fight their battles in corporate boardrooms and law offices as tribes endeavor to... 1994 Yes
Timothy P. Terrell , Bernard L. McNamee Transovereignty: Separating Human Rights from Traditional Sovereignty and the Implications for the Ethics of International Law Practice 17 Fordham International Law Journal 459 (1994) C1-2CONTENTS L1-2Introduction 459 I. Sovereignty, Rights, and Political Theory. 462 A. Austin. 463 B. Hart. 464 C. Dworkin. 466 II. Transovereignty. 468 III. The Catholic Church as Transovereign in Poland. 472 IV. Transovereignty and Legal Ethics. 479 A. Transovereigns and Lawyer Independence. 480 B. Transovereigns as Clients: Conflicts and... 1994  
Joseph W. Dellapenna Treaties as Instruments for Managing Internationally-shared Water Resources: Restricted Sovereignty Vs. Community of Property 26 Case Western Reserve Journal of International Law 27 (Winter, 1994) During Operation Desert Storm, the coalition air forces targeted electric power stations, impairing water supplies for civilian and military needs. The impairment of water supplies resulted both from the incidental destruction of water storage facilities and, more importantly, from the deprivation of power from the pumping stations as a result of... 1994  
Joseph W. Dellapenna Treaties as Instruments for Managing Internationally-shared Water Resources: Restricted Sovereignty Vs. Community of Property 26 Case Western Reserve Journal of International Law 27 (Winter, 1994) During Operation Desert Storm, the coalition air forces targeted electric power stations, impairing water supplies for civilian and military needs. The impairment of water supplies resulted both from the incidental destruction of water storage facilities and, more importantly, from the deprivation of power from the pumping stations as a result of... 1994  
Ellen P. Aprill Tribal Bonds: Indian Sovereignty and the Tax Legislative Process 46 Administrative Law Review 333 (Summer, 1994) I. Background: IRS Rulings II. Congressional Action 1975 to 1982 A. Legislative Proposals B. Bonding Authority Under the Tribal Tax Act C. Statutory Ambiguity and Its Uses III. IRS Response to the Tribal Tax Act A. Development of the Regulations B. Administrative Discretion, Legislative History, and Regulatory Bias IV. Consequences of the... 1994 Yes
Edward V. Byrne What Ever Happened to the Peremptory Challenge? 63-SEP Journal of the Kansas Bar Association 18 (September, 1994) The right of [peremptory] challenge...has always been held essential to the fairness of trial by jury. [I]t must be exercised with full freedom, or it fails of its full purpose. Lewis v. United States, 146 U.S. 370, 376, 378 (1892). Our constitution is color-blind, and neither knows nor tolerates classes among citizens. Plessy v. Ferguson,... 1994  
Richard Monette When Tribes Sue States: How "Federal Indian Law" Offers an Opportunity to Clarify Sovereign Immunity Jurisprudence 14 QLR 401 (Fall, 1994) Sovereign immunity goes to the very heart of [the] federal system and affect [[[s] the allocation of power between the United States and the several States. From the early days of this Nation, when Chisholm v. Georgia was decided against the State by the Federalist-minded Supreme Court and was then summarily reversed by the Anti-Federalist-minded... 1994 Yes
John R. Wunder William G. Mcloughlin, after the Trail of Tears: the Cherokees' Struggle for Sovereignty, 1839-1880. Chapel Hill: University of North Carolina Press, 1993. Pp. Xv + 439. 44 Journal of Legal Education 308 (June, 1994) The Cherokees have not been blessed with many positive happenings in their legal relationships with the United States, but they do have something no other Indian nation of North America has: they have received significant historical attention from legal and political historians, and their story has benefitted from it. The first modern legal scholar... 1994  
Steve T. Madsen A Certain False Security: the Madrid Protocol to the Antarctic Treaty 4 Colorado Journal of International Environmental Law and Policy 458 (Summer, 1993) Antarctica has in the past two decades come to the fore of mainstream international law. Increasing awareness of its mineral potential, coupled with an appreciation for the finiteness of global resources in general and hydrocarbon resources in particular, has resulted in increased attention being paid to this unique land. Diplomatic activity may... 1993  
David Everett Marko A Kinder, Gentler Moon Treaty: a Critical Review of the Current Moon Treaty and a Proposed Alternative 8 Journal of Natural Resources & Environmental Law 293 (1992-1993) A few thousand miles beyond our little planet, there are enough natural resources to support a civilization many thousand times larger than the Earth's population. Who owns those resources? Who has the right to use and appropriate them? Who should? Today there is no widely accepted international law governing the moon and other celestial bodies.... 1993  
Bruce A. Wagman Advancing Tribal Sovereign Immunity as a Pathway to Power 27 University of San Francisco Law Review 419 (Winter, 1993) AMERICAN INDIAN tribes existed as individual, self-contained nations before the first Europeans set foot on the American continent. Initial treaty making by British and Spanish colonizers officially recognized the undisputed sovereignty of Indian nations. At the same time, the Europeans set a precedent of domination through cession of Indian lands... 1993 Yes
Kristin M. Lomond An Adult Patient's Right to Refuse Medical Treatment for Religious Reasons: the Limitations Imposed by Parenthood 31 University of Louisville Journal of Family Law 665 (1992/1993) In 1985 Stacey Paddock, a pregnant woman required to undergo a caesarian section because of pregnancy complications, consented to all treatment necessary to perform the operation except for blood transfusions. Paddock refused the blood transfusions because of her religious convictions. The hospital and her attending physicians then petitioned the... 1993  
Ron S. Chun Avoiding a Jurassic Dinosaur Run Amok: Circumventing Eleventh Amendment Sovereign Immunity to Remedy Violations of the Automatic Stay 98 Commercial Law Journal 179 (Summer, 1993) Any step through the looking glass of the Eleventh Amendment leads to a wonderland of judicially created and perpetuated fiction and paradox. Section 362 of the Bankruptcy Code invokes an automatic stay upon actions against the debtor, property of the debtor, and property of the estate. The automatic stay is fundamental to bankruptcy because it... 1993  
Steven Paul McSloy Bac Native American Sovereignty in the 21st Century 20 New York University Review of Law and Social Change 217 (1993) Introduction I. From Then to Here A. International Law B. Land C. Federalism D. The Frontier E. Plenary Power F. The Road II. The Empire Has No Clothes A. The Commerce Clause B. The Treaty Power C. The Trust Relationship D. Implicit Divestiture E. There Is No There There F. What Is to Be Done? III. International Law and Indigenous Peoples A.... 1993 Yes
Keith Highet, George Kahale III, William A. Schabas, University of Quebec at Montreal Canada-extradition-death Penalty-international Human Rights Treaties 87 American Journal of International Law 128 (January, 1993) Recent issues of this Journal have focused attention on the conflict between extradition treaties and international human rights obligations, where capital punishment may be imposed. The Canadian Government has indicated that it will not follow the emerging trend in Europe to refuse extradition to the United States and other countries in death... 1993  
James J. Belliveau Casino Gambling under the Indian Gaming Regulatory Act: Narragansett Tribal Sovereignty Versus Rhode Island Gambling Laws 27 Suffolk University Law Review 389 (1993) The question of how best to regulate gaming on Indian lands raises important issues regarding State law enforcement authority, the need for proper regulation of gaming activities and the strong interests of Indian tribes in self-government and economic development. As with most matters affecting the legal relations between the States and Indian... 1993 Yes
John King Gamble , Charlotte Ku Choice of Language in Bilateral Treaties: Fifty Years of Changing State Practice 3 Indiana International & Comparative Law Review 233 (Spring, 1993) Treaties and treaty-making deservedly occupy a central place in the international legal scholarly literature. As the major source of international obligation, examining the form and content of treaties can provide tangible and quantifiable information about the behavior of states and the international environment in which they operate. On a more... 1993  
Robert Berry Civil Liberties Constraints on Tribal Sovereignty after the Indian Civil Rights Act of 1968 1 Journal of Law & Policy Pol'y 1 (1993) The Indian Civil Rights Act of 1968 provided a legislative answer to the question of whether, and to what extent, fundamental civil liberties recognized in constitutional law should constrain federally recognized Indian Tribes in the exercise of their sovereign powers. In enacting this law, Congress weighed its desire to protect individuals from... 1993 Yes
Michelle L. Farmer Constitutional Law-bills of Attainder-supplemental Extradition Treaty Struck down as Bill of Attainder, Mcmullen v. United States, 953 F.2d 761 (2d Cir.1992). 16 Suffolk Transnational Law Review 668 (Spring, 1993) Extradition treaties have played an integral part in United States foreign policy. These treaties consistently provided a political offense exception clause which forbade extradition if the nature of the petitioner's crime was political. In McMullen v. United States, the United States Court of Appeals for the Second Circuit considered the... 1993  
Peter McKenna Constitutional Law-sovereign Immunity-states May Not Impose Civil Penalties on the United States Government for Violations of State Statutes Promulgated under the Authority of the Clean Water Act and the Resource Conservation and Recovery Act-united State 23 Seton Hall Law Review 762 (1993) During the last several decades, Congress has responded to concerns about the deteriorating conditions of the environment by passing major legislation aimed at preventing further harm. Chief among these legislative enactments are: the Clean Air Act (CAA); the Federal Water Pollution Control Act (the Clean Water Act or CWA); the Resource... 1993  
Scott Gardner Constitutional Law-tenth Amendment-state Sovereignty as a Limit of Congressional Power-the United States Supreme Court Held That a Federal Statute Offering the States an Option Between Two Unconstitutionally Coercive Regulatory Techniques-either Accepting 31 Duquesne Law Review 877 (Summer, 1993) Congress enacted the Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA) in response to an anticipated shortage of low-level radioactive waste sites among the states. The LLRWPAA declared a federal policy of holding each state responsible for providing for the disposal of all low-level radioactive waste generated within its... 1993  
Patrick Macklem DisTributing Sovereignty: Indian Nations and Equality of Peoples 45 Stanford Law Review 1311 (May, 1993) I. Introduction. 1312 II. Indian Government in North America. 1316 A. United States. 1317 B. Canada. 1320 C. Similarities. 1323 D. Racial or Political?. 1324 III. Indian Government and Prior Occupancy. 1327 A. The Relevance of Prior Occupancy. 1327 B. Prior Occupancy as Proxy. 1329 1. Immigration and consent. 1330 2. The role of treaties. 1331 3.... 1993 Yes
Talbot J. Nicholas II Eec Measures on the Treatment of National Treasures 16 Loyola of Los Angeles International and Comparative Law Journal 127 (November, 1993) The European Economic Community (EEC) has adopted a regulation on the export of cultural goods and a directive on the return of cultural objects unlawfully removed from the territory of a Member State. The EEC adopted these measures to coordinate EEC law with the national laws of EEC Member States governing the protection of national treasures... 1993  
Vicki J. Limas Employment Suits Against Indian Tribes: Balancing Sovereign Rights and Civil Rights 70 Denver University Law Review 359 (1993) The proliferation of employment suits in state and federal court is mirrored in the courts of Indian tribes that employ people in tribal government and commercial enterprises. The employment relationship provides a fertile source of litigation in federal and state courts; not only is it heavily regulated by statute, but numerous common law theories... 1993 Yes
Timothy W. Joranko Exhaustion of Tribal Remedies in the Lower Courts after National Farmers Union and Iowa Mutual: Toward a Consistent Treatment of Tribal Courts by the Federal Judicial System 78 Minnesota Law Review 259 (December, 1993) In National Farmers Union Insurance Cos. v. Crow Tribe and Iowa Mutual Insurance Co. v. LaPlante, the Supreme Court ruled that defendants in tribal court actions must exhaust available tribal court remedies before proceeding with a parallel action in federal court. At the same time, the Court held that defendants could challenge the tribal court's... 1993 Yes
Michael R. Wing Extradition Treaties-international Law-the United States Supreme Court Approves Extraterritorial Abduction of Foreign Criminals-united States v. Alvarez-machain, 112 S.ct. 2188 (1992) 23 Georgia Journal of International and Comparative Law 435 (Summer, 1993) On April 2, 1990, bounty hunters posing as Mexican police authorities forcibly kidnapped Dr. Humberto Alvarez-Machain, a physician of Mexican citizenship, from his medical office in Guadalajara. The bounty hunters took Dr. Machain by force to a private plane and flew him to an El Paso, Texas airfield. Upon arrival in the United States, his... 1993  
Antony B. Klapper Finding a Right in State Constitutions for Community Treatment of the Mentally Ill 142 University of Pennsylvania Law Review 739 (Fall, 1993) Experience should teach us to be most on our guard to protect liberty when the Government's purposes are beneficent. Introduction I. Institutionalization and Deinstitutionalization: History and Policy A. Civil Commitment Procedures B. Pre-1980s C. 1980s and 1990s II. Community-Based Treatment and the Policy Arguments Favoring It A. The Concept of... 1993  
Melvin D. Chan Fortino v. Quasar Co.: Invocation of Parents' U.s.-japan Fcn Treaty Rights Gives Japanese-owned U.s. Subsidiaries a Defense Against Title Vii 6 Transnational Lawyer 653 (Fall, 1993) C1-3TABLE OF CONTENTS I. INTRODUCTION. 654 II. LEGAL BACKGROUND. 655 A. The U.S.-Japan Treaty of Friendship, Commerce and Navigation. 656 B. Title VII of the Civil Rights Act of 1964. 658 1. Distinction Between National Origin and Citizenship. 659 2. Bona Fide Occupational Qualification Exception. 660 C. Judicial Attempts to Reconcile the of Their... 1993  
John Webb Genocide Treaty-ethnic Cleansing-substantive and Procedural Hurdles in the Application of the Genocide Convention to Alleged Crimes in the Former Yugoslavia 23 Georgia Journal of International and Comparative Law 377 (Summer, 1993) On Tuesday, October 15, 1991, in a controversial vote, the parliament of the Yugoslav republic of Bosnia-Herzegovina proclaimed their republic a sovereign state and adopted documents to secede from Yugoslavia. In so doing, Bosnia-Herzegovina joined Croatia and Slovenia who declared independence in June of 1991. Fearing political and economic... 1993  
Allison M. Dussias Geographically-based and Membership-based Views of Indian Tribal Sovereignty: the Supreme Court's Changing Vision 55 University of Pittsburgh Law Review Rev. 1 (Fall, 1993) C1-2Table of Contents I. The Cherokee Cases. 6 A. Cherokee Nation v. Georgia. 6 B. Worcester v. Georgia. 12 II. Geographically-based and Membership-based Sovereignty in Recent Supreme Court Cases. 17 A. Tribal Court Criminal Jurisdiction. 18 1. Tribal Court Criminal Jurisdiction Over Tribal Members. 21 2. Tribal Court Criminal Jurisdiction Over... 1993 Yes
Samuel K. Murumba Grappling with a Grotian Moment: Sovereignty and the Quest for a Normative World Order 19 Brooklyn Journal of International Law 829 (1993) I. Introduction On the first day of the same French Revolution that Wordsworth captured in his exuberant lines, Bliss was it in that dawn to be alive But to be young was very heaven! legend has it that one Frenchman's diary entry read: Nothing happened here today. The same mixture of enthusiasm and skepticism greeted President Bush's 1991... 1993  
Ronald G. Morgan Identifying Protected Government Acts under the Sovereign Acts Doctrine: a Question of Acts and Actors 22 Public Contract Law Journal 223 (Winter, 1993) I. Introduction II. Nature of the Doctrine A. Theory of Dual Capacity B. Scenarios under Which the Doctrine Arises C. Purposes of the Doctrine D. Effects of the Doctrine III. Elements of the Doctrine A. Development and Coverage of Elements 1. Articulation of the Elements 2. Centrality of Public and General Application 3. Elements Accorded Varying... 1993  
Laura M. Plastine In God We Trust: When Parents Refuse Medical Treatment for Their Children Based upon Their Sincere Religious Beliefs 3 Seton Hall Constitutional Law Journal 123 (Spring, 1993) I. INTRODUCTION. 123 II. THE SCOPE OF THE FREE EXERCISE CLAUSE. 125 III. IS SPIRITUAL HEALING A PROTECTED RELIGIOUS ACTIVITY UNDER THE FREE EXERCISE CLAUSE?. 138 A. Court-Ordered Medical Treatment. 141 1. Life-Threatening Afflictions. 141 2. Non Life-Threatening Afflictions. 145 3. Incurable Afflictions. 147 B. Criminal Prosecution of the Parents... 1993  
John H. Mcclanahan Indian Law-Tribal Sovereignty-congress, Please Help Again-the Cheyenne River Sioux Tribe Cannot Regulate Hunting and Fishing Because the Non-Indian Interest Controls. South Dakota v. Bourland, 113 S.ct. 2309 (1993). 29 Land and Water Law Review 505 (1993) Before 1988, both the Cheyenne River Sioux Tribe and the State of South Dakota had successfully negotiated the issue of regulatory authority over hunting and fishing activities on Cheyenne River Reservation lands, and had each enforced their respective game and fish regulations. However, a dispute arose between the State of South Dakota and the... 1993 Yes
Lance Compa International Labor Rights and the Sovereignty Question: Nafta and Guatemala, Two Case Studies 9 American University Journal of International Law and Policy 117 (Fall, 1993) Worker rights advocates in trade unions, human rights groups, and other non-governmental organizations (NGOs) have played an increasingly important role in promoting internationally established fair labor standards as a factor in international trade. Particularly in the United States, recent developments have widened the scope for action on labor... 1993  
Christina D. Ferguson Martinez v. Santa Clara Pueblo: a Modern Day Lesson on Tribal Sovereignty 46 Arkansas Law Review 275 (1993) How has our own country treated its oldest and most persisting minority, the Indians; how has it treated them, and how is it treating them now? President Franklin D. Roosevelt Like the miner's canary, the Indian marks the shift from fresh air to poison air in our political atmosphere . our treatment of Indians, even more than our treatment of other... 1993 Yes
Carol Weisbrod Minorities and Diversities: the "Remarkable Experiment" of the League of Nations 8 Connecticut Journal of International Law 359 (Spring, 1993) The State exists for the sake of Society, not Society for the sake of the State. Woodrow Wilson This paper considers some issues relating to state frameworks intended to permit and encourage large diversities in societal group life. It focuses illustratively on material relating to the period after the First World War, when the League of Nations... 1993  
June Starr , Kenneth C. Hardy Not by Seeds Alone: the Biodiversity Treaty Native Agriculture 12 Stanford Environmental Law Journal 85 (1993) We have to ask what kind of relationship can our advanced culture have with primitive nature and how can we nurture and be nurtured by nature? Maintaining and preserving the delicate balance of each ecosystem is central to any attempt to halt the ecological damage to our planet. As scientific studies reveal, balanced ecosystems do not develop... 1993 Yes
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