Maternal Smoking During Pregnancy And Legal Solutions For Victims

Effects of smoking can cause in ongoing pregnancy

Discuss about the Maternal Smoking During Pregnancy And Legal Solutions For Victims?

Smoking is an activity, which harms each human organ, causes several diseases to the person engaged in smoking and results in life reduction of the smoker. On an average smoking causes over 480,000 deaths in America every year[1]. Therefore, the World Health Organisation has declared smoking to be one of the most preventable reasons for death in the United States of America. Almost 10 times more United States citizens have died due to smoking than the citizens who died during the wars fought in United States of America.   In most of the western countries, maternal smoking is a very common activity, which most women are engaged in. Maternal smoking during the early months of pregnancy is associated with abortion, major birth defects in the child and can result into sudden infant death. The problem of smoking during pregnancy is most common and highly conducted activity in the United States of America. In United States of America currently, more than 10% women smoke regularly smoke during their pregnancy[2]. Maternal smoking during pregnancy causes major side effects in fetus development which affects the infant’s physical and mental condition after birth and many adverse outcomes in pregnancy which can be as extreme as  causing infant death syndrome (SIDS)[3]. It is the duty of every woman and every mother to protect her baby right from the time it’s conceived and no governmental authority or legislation can force this duty on a mother if she herself decides to smoke during pregnancy and cause serious birth defects in her infant yet to be born. The best effort government can take in respect of this issue is to be creating awareness about the ill effects of maternal smoking during pregnancy on child birth through various media and advertisements. However, the United States government, a few years ago took an initiative to protect the fetuses from the prenatal dangers until the fetus is born alive. It is usually argued that restricting a woman from smoking during pregnancy leads to violation of her right to privacy and her right to decide what’s best for her body[4]. However, with the recent growth in number of female smokers in the United States of America, it is highly needed for government to come up with a legislation that compels woman to stop smoking during pregnancy to protect the rights of the fetus and infants. In this case, the right to protect the fetus and infants must be taken more seriously than the right of privacy of a mother who is ready to harm her child for an unhealthy habit of smoking.

Consequences of maternal smoking during pregnancy on the child after birth

This assignment will discuss ill effects of smoking done by pregnant women during her pregnancy months and the effects it has on fetus and the child after birth[5].  The assignment disuses how a woman who smokes during pregnancy can cause defects and harm in her infant, which continue to exist with the child throughout his life. These defects can be physical, mental or physiological in nature. In the next part of the assignment, legislation concerning the child’s right to be protected before birth will be examined along with suggestions to the American government to enact laws that compel a woman to quit smoking during her pregnancy months for a health child and for the best protection of the child before its birth.

It is evident that for successful development of the fetus, oxygen produced by the mother is very essential. It is this oxygen, which leads to a good developed fetus. However, women who smoke during pregnancy produce more carbon dioxide due to regular smoking habit, which reduced the amount of oxygen supply to the fetus by nearly 40%. These results in under-developed fetus, which in return gives, rise to many complications during pregnancy and create birth defects[6]. Smoking can cause significant adverse effects and create major health risks for both mother and the fetus if a pregnant woman is involved in regular smoking during her pregnant months. The women who are engaged in smoking during their pregnancy are twice likely to experience pregnancy complications than the woman who refrain from it. Some major effects of smoking in ongoing pregnancy are as follows:

Premature Birth – Smoking lead to the amniotic sac in a mother to rapture before time, which leads a woman to labour before the child, is developed fully in the womb. Although this problem can be solved with advancement in medicine and technology, it cause stress and more expense as the child who is born prematurely has to stay in the hospital for a longer period[7].

Placental Abruption – Smoking can cause the premature separation of placenta from where it is required to be attached. This can cause severe distress to the fetus resulting into its death and the mother in these cases can lose a lot of blood, which can be a severe health hazard[8].

Placenta Previa – Smoking can cause a placenta to grow in the lower part of the uterus, which leads to caesarean section delivery. This can be an expensive affair as it leads to a longer recover period, which requires prolonged hospital stay, and after care facilities.

A woman who smokes during her pregnancy is more likely to give birth to an infant with series of defects, which can vary in nature. The consequences of maternal smoking during pregnancy can be extreme for both mother and the child. A cigarette contains nearly 2000 harmful substances present in it, which includes the presence of nicotine in large quantities. Nicotine is a stimulant drug, which is quick in entering the blood in the human body disturbing the entire human organ system. Irrespective of its additive nature, consumption of nicotine can lead to many biological and health defects like cancer and heart attacks. It is to be considered that if the drug can harm a full-grown human body to this extent, its effects on a fetus or an infant can be extreme and threatening[9]. The consequences of maternal smoking by the mother during pregnancy create serious birth defects in her child when born and the defect can be mental, physical or physiological in nature. Most common and serious effects suffered by children who are born to mothers who smoke dueing their pregnancy moths are as follows:-

Low birth weight – Smoking mothers give birth to babies who are under weight. The risk for a baby to born underweight increased to two times when the mother is engaged in regular smoking during pregnancy. In a survey conducted in the United States of America, 11. 9% babies were born underweight to smoking mothers compared to only 7.2% babies who were underweight to non-smoking mothers[10]. The survey had results, which suggested that the difference of around 200 grams exist between babies born to smokers than to non-smokers, which mean the babies born to smoking mothers were on an average 200 grams underweight compared to babies born to non-smoking mothers[11]. A baby who is under weight or premature has a higher risk to health hazards which he will probably face throughout his life. These health hazards can be as simple as learning disability in the child during his growing years or can be as extreme as mental retardation due to underdeveloped brain activities. Thus, a baby born to smoking mothers are more likely to face health issue, which in return decreases their life expectancy. Smoking during pregnancy is considered a potential risk to the infant who can be born with major abnormalities.

Sudden Infant Death Syndrome (SIDC) – Sudden Infant Death Syndrome (SIDC) means a sudden death of a new born child whose death cannot be explained by the reviewing the child’s medical history. Infants who are born to mothers who smoke during their pregnancy months are more likely to die due to Sudden Infant Death Syndrome (SIDC)[12]. Infants exposed to smoke before and after birth are 3 times likely to be affected with Sudden Infant Death Syndrome (SIDC). Medically it is still not clear as to what are the primary causes of Sudden Infant Death Syndrome (SIDC), however the doctors in the United States of America have clearly suggested that infants who are exposed to smoke before and after their birth are more likely to suffer from the same[13].

Birth Defect – Infants who are born to smoking mothers are more likely to be born with serious birth defects. One of the most common birth defect is congenital heart defects, which creates problem due to the structure of the infant’s heart being abnormal or the chances that the infants will be having a hole in his heart. Some other birth defects, which are seen with infants who are born to smoking mothers, are cleft lips, cleft palate, etc. One major birth defect of smoking during pregnancy is increased risk of respiratory problems in infants, which is often noticed with increased heart rate of the infants. Infants who are born to smoking mothers usually suffer from asthma and other allergies in later stages of life.

Future obesity – One of the critical reasons for health hazards in the United States of America is the problem of obesity. Obesity is a common health issue, which Americans have suffered since a long period[14]. A study has suggested that maternal smoking during pregnancy can cause a high chance of teenager obesity in the infant born. A survey was conducted where teenagers of older age were compared based on their obesity level trying to check who is born to smoking and non-smoking mothers, it was reviewed that nearly 22% teenagers born to smoking mothers suffered from obesity compared to the other counterpart. Teenager obesity is a major health issue, which can attract serious health hazards like diabetes and cardiac attacks in the later stages of the teenagers who suffer from obesity[15].

Behaviour Defects – Many studies show that children who are born premature or with low birth weight have lower level of IQ levels. Smoking thus can indirectly affect the intellect level and behaviour of an infant as premature birth and infants with low birth weight are usually born to mothers who smoke during pregnancy. A study conducted on around 200 children concluded that children born to smoking mothers have smaller brains and are more likely to suffer from depression and mood swings compare to children born to non-smoking mothers[16]. The reason for the same is that smoking causes destruction of neurons and reduced level of oxygen supply to the foetus due to narrowing blood vessels[17]. Therefore, children born to smoking mothers have a high risk of developing mental diseases, as their brain development was disturbed during birth. Moreover, mothers who smoke during pregnancy months are more likely to give birth to children who are hyperactive in nature. This hyperactive disorder is referred as attention deficit hyperactivity disorder (ADHD) which can be complex and create a lot of stress in the life of the parents as such children require excessive care[18].

Thus, the effects of maternal smoking by a pregnant woman can be grave on the child who is born. Therefore, it is the need of an hour that the United States of America introduces significant reforms and laws that advertise the ill effects of smoking during pregnancy and compels women to quit smoking during pregnancy months to protect their child from serious dangers associated with smoking during pregnancy. The rights of children in the United States of America should include the protection of foetus irrespective of how it affect the other rights a women has to live her life in a manner she desires. This right is referred as fetal rights and is recognised in the United States of America under Civil Rights and Human Rights[19]. The rights suggests it to be a punishable offense if the foetus is illegally killed or harmed in any way by the women who is carrying it or the mother of an potential human life.

The Unites States of America has in the recent years enacted several legislation, which make provisions to protect the unborn child while it’s in its mother’s womb from the several dangers that can cause abnormalities in its birth. However, while calculating the dangers of smoking by a pregnant woman, it can have on the infant that is born to her eventually; the legislation in the United States feared the lack of laws that can provide remedy to the child who is the victim and suffers many disabilities as a result of mother ‘s smoking habits.

The United States of America enacted the Unborn Victims of Violence Act of 2004, which recognized an unborn child in the utero as a legal victim.  The Act made provisions, which suggested that if any individual including the mother of the unborn child committed any activity to adversely harm or kill the said child in the utero or the womb would be punishable criminally for homicide and murder under the Criminal laws in the United States of America.

In addition, there are many child abuse and child neglect legislations currently active in the United States of America. Child abuse or neglect is termed as any activity or omission of any act by a parent or a caretaker, which results in death, injury, serious physical or emotional damage, sexual abuse or exploitation of a child.  Thus, the Courts in the United States of America have defined the consumption of alcohol, smoking and drugs by the mother during her pregnancy is considered as a child abuse and neglect on her part. In Whitner v. South Carolina, 492 S.E.2d 777 (1997) a pregnant woman was consuming drugs and was held criminally for the offence as the Court considered the fetus as a child under the criminal laws in the United States of America[20]. Thus, in the said case the Court went ahead to conclude that any behaviour on part of a pregnant woman whether legal or illegal which is harmful to the fetus can attract criminal laws and punishment against the pregnant woman in the United States of America[21].

This case law makes it clear that the Courts in United States of America give more importance to protection of fetus and fetal rights of an unborn child over the rights of privacy that a pregnant woman have to live her life as desired[22]. Thus, the privacy rights of an expecting mother’s is considered secondary by the Courts while deciding case laws that relate to protection of fetus and potential life. As there is no definite law, which related to protection of the fetus from the harms of a smoking pregnant mother, the legislation presumes that child abuse and neglect laws in the United States of America extend to childcare before birth also. In a case, decide by the Florida Court, Johnson v. State, 578 So. 2d419 (Fla. 1991), the pregnant woman named Jennifer Johnson was arrested twice for two instances where a child born to her was tested positive for cocaine immediately after birth. When the woman appealed, the appeal court upheld the decision of conviction of the woman, which was passed by the lower court[23].

Most of the child abuse and neglect legislations in the United States of America refer to drugs when they talk about harm to the child, infant or fetus. There is no direct mention of the term smoking in any child abuse and neglect laws, which harms the unborn child in the womb of the mother who is constantly smoking during pregnancy. However, it is to be noted here that nicotine, which is a drug and it, forms a major composition of a cigarette, which leads to smoking and harming the unborn life inside a mother when she smokes. Therefore, smoking is a form of drug, which makes the individual smoking get addicted to the activity, and eventually harms the individual and in case of an expecting mother smoking, it harms the mother along with the child[24]. Therefore, child abuse and neglect laws that related to drugs can be extended to cover smoking which harms the unborn child. Thus, a pregnant woman who smokes causing harm to her unborn child can be criminally liable for the offence of causing injury to the foetus.

However, the laws in United States of America have failed to enact any laws, which make provisions for a child who has suffered birth defects due to the smoking or drinking habits of his pregnant mother, to collect damages for the harm that he has suffered after birth. The State of California however, has enacted a provision in its criminal law amendments, which allows a child who has suffered birth defects to collect compensation from his mother in case the birth defect is a result of her ill actions during pregnancy[25]. This revolutionary law was introduced in California in the year 2004, it allowed a child to recover compensation after birth for the injuries, and damages it suffered while it the utero. The California Civil Code included a provision, which stated that a child conceived but yet to be born is considered as a existence person in the eyes of law as is required for the interest of the child in the event of child’s future birth.

Thus, the courts in different states of United States of America have recognized the concept of recovery for injuries caused to a foetus by the mother. In a case Smith v Borello, the father of an infant boy sued his mother stating that the child has suffered from birth defects like leg and hand deformation due to the negligence on part of the mother. The mother in the said case was driving negligently when she was pregnant and the accident resulted in birth defects from which the infant suffered. While deciding the said case, the court considered the basic principle, which gave the child the right to start his life with a healthy body and a strong mind. This principle gives a child after his birth the right to recover damages for the injures he has suffered in the utero by the negligence of his mother. Therefore, this case law is a strong precedent followed in the United States of America when makes clear grounds for a child to recover damages after his birth if the actions of his mother during pregnancy has harmed his health physically, mentally or physiologically[26].

Many courts in the United States of America have made provisions to provide remedy to the infant for recovery for injuries caused to him before his birth due to the habits of his mother by taking the regular course and applying tort law and negligence in the said case. Thus, the standard principles of negligence and tot law can help the infants who have suffered birth defects due to smoking mother to recover damages for their loss. In this case, it is the Courts that need to recognize the concept of tort law and negligence and how it can be applied to remedy the infant who has suffered birth defects. In fact, the courts recognizing the same principles relating to the said matter can make recommendations to the legislation to introduce the same in the form of a proper enacted Act. This proposed Act can allows the infant to resort to tort laws to claim recovery from the mothers due to whose action they suffer birth defects which they have to carry with them all their lives. The formation of the said Act can lie on the basic principle that a child cannot be denied a right to claim damages for the injuries he has suffered on no fault in his part and he legally should not be allowed to bear the burden of his mother’s fault all his life without any legal relief for the same[27].

Children who have suffered birth defects can claim damages from their mother for prenatal injuries while they were in the womb by resorting to tort laws. This can be a proposed legal amendment that can be enacted which creates a spate and a definite law concerning the said matter[28]. As there is no separate Act to protect a foetus from the harms, it suffers due to ill behaviour of his mother; the issue can be solved by allowing a tort remedy for the same. Under the tort law, two remedies are available in the said case which are negligence and battery.

Negligence – Negligence of a mother can be proved by a child after its birth to claim that he has suffered birth defects due to the negligent behaviour or habits of his mother during pregnancy months. To prove the same, the child will have to establish the following events:-

The mother owed the child duty of care

The mother breached the said duty

The child suffered harm and injuries due to the breach of the duty of care by the mother

The mother’s breach of duty of care was the direct reason of child’s injury or harm[29].

Following the tort law of negligence claiming compensation will be easier and create larger recognition for the rights of the foetus. When a woman is pregnant, she owes a duty of care towards her child and breaching this duty and harming the child before or after birth is a valid and a good ground of negligence on her part, which can be legally, rectified using tort of negligence.

Battery – Battery is an offense under tort law, which includes an intentional and voluntary contact with an individual, which is harmful, violent or offensive. Therefore, a child can claim that his mother when under physical contact with the baby who was in her womb has engaged in activities which has physically harmed the foetus and the infant after birth, the child born who suffers injuries can file an action for battery against his mother. As smoking is an intentional harm, which a mother causes to her child when she smokes during pregnancy, the child has a good case of battery against her[30].

Thus, it is very important for United States of America to come up with definite and separate laws to protect the rights of the unborn child who suffers birth defect, which is associated to maternal smoking during pregnancy. Laws need to be created which will restrict a woman from smoking during pregnancy without thinking that such restrictions affect the human rights and right to privacy of a woman. The foremost important safeguard in these cases need to be the protection of the foetus which will eventually when come to the world needs to be healthy and sound[31]. In fact, not just during pregnancy, it is the duty of every mother, parent and the society to protect children from the ill effects of passive smoking, which can harm their growth and development.

American Diabetes Association. “Standards of medical care in diabetes—2010.” Diabetes care 33.Supplement 1 (2010): S11-S61.

Behm, Ilan, et al. “Increasing prevalence of smoke-free homes and decreasing rates of sudden infant death syndrome in the United States: an ecological association study.” Tobacco Control 21.1 (2012): 6-11.

Briggs, Gerald G., Roger K. Freeman, and Sumner J. Yaffe. Drugs in pregnancy and lactation: a reference guide to fetal and neonatal risk. Lippincott Williams & Wilkins, 2012.

Bronitt, Simon, and Bernadette McSherry. Principles of criminal law. Thomson Reuters, 2010.

Bruin, Jennifer E., Hertzel C. Gerstein, and Alison C. Holloway. “Long-term consequences of fetal and neonatal nicotine exposure: a critical review.”Toxicological sciences 116.2 (2010): 364-374.

Carpenter, Robert, et al. “Bed sharing when parents do not smoke: is there a risk of SIDS? An individual level analysis of five major case–control studies.” BMJ open 3.5 (2013): e002299.

Centers for Disease Control and Prevention (CDC). Unintentional drug poisoning in the United States. CDC Data Brief, July, 2010.

Cobb, Caroline, et al. “Waterpipe tobacco smoking: an emerging health crisis in the United States.” American journal of health behavior 34.3 (2010): 275.

Davies, Michael J., et al. “Reproductive technologies and the risk of birth defects.” New England Journal of Medicine 366.19 (2012): 1803-1813.

De Cruz, Peter. Comparative healthcare law. Routledge, 2013.

del Carmen, Rolando. Criminal procedure: Law and practice. Cengage Learning, 2013.

Dietz, Patricia M., et al. “Infant morbidity and mortality attributable to prenatal smoking in the US.” American journal of preventive medicine 39.1 (2010): 45-52.

Finer, Lawrence B., and Mia R. Zolna. “Unintended pregnancy in the United States: incidence and disparities, 2006.” Contraception 84.5 (2011): 478-485.

Fuller, David W. “Intentional torts and other exceptions to the federal tort claims act.” U. St. Thomas LJ 8 (2010): 375.

Ino, Toshihiro. “Maternal smoking during pregnancy and offspring obesity: Metaâ€Âanalysis.” Pediatrics International 52.1 (2010): 94-99.

James, David K., et al. High risk pregnancy: management options-expert consult. Elsevier Health Sciences, 2010.

Johnson, Kenneth C., et al. “Active smoking and secondhand smoke increase breast cancer risk: the report of the Canadian Expert Panel on Tobacco Smoke and Breast Cancer Risk (2009).” Tobacco control (2010): tc-2010.

Joubert, Bonnie R., et al. “450K epigenome-wide scan identifies differential DNA methylation in newborns related to maternal smoking during pregnancy.” Environmental health perspectives 120.10 (2012): 1425.

Langley, Kate, et al. “Maternal and paternal smoking during pregnancy and risk of ADHD symptoms in offspring: testing for intrauterine effects.”American journal of epidemiology 176.3 (2012): 261-268.

Levi, Edward H. An introduction to legal reasoning. University of Chicago Press, 2013.

Mochow, Suzanne Painter. “Whitner v. South Carolina.” J. Juv. L. 18 (1997): 238.

Moon, Rachel Y. “SIDS and other sleep-related infant deaths: expansion of recommendations for a safe infant sleeping environment.” Pediatrics 128.5 (2011): e1341-e1367.

National Center for Health Statistics (US). Healthy people 2010: Final review. Government Printing Office, 2011.

Neuman, Åsa, et al. “Maternal smoking in pregnancy and asthma in preschool children: a pooled analysis of eight birth cohorts.” American journal of respiratory and critical care medicine 186.10 (2012): 1037-1043.

Reiss, Dorit Rubinstein. “Compensating the victims of failure to vaccinate: what are the options.” Cornell JL & Pub. Pol’y 23 (2013): 595.

Schetter, Christine Dunkel, and Lynlee Tanner. “Anxiety, depression and stress in pregnancy: implications for mothers, children, research, and practice.” Current opinion in psychiatry 25.2 (2012): 141.

Steele, Jenny. Tort Law: Text, cases, and materials. Oxford University Press, 2010.

Tapon, Dagmar. “Prenatal testing for Down syndrome: Comparison of screening practices in the UK and USA.” Journal of genetic counseling 19.2 (2010): 112-130.

Thun, Michael J., et al. “The global burden of cancer: priorities for prevention.” Carcinogenesis 31.1 (2010): 100-110.

Weininger, Alexandria. “Fetal Rights and Prenatal Substance Abuse: A Comparative Law Perspective.” (2013).

World Health Organization. World health statistics 2010. World Health Organization, 2010.

[1] Centers for Disease Control and Prevention (CDC). Unintentional drug poisoning in the United States. CDC Data Brief, July, 2010.

[2] World Health Organization. World health statistics 2010. World Health Organization, 2010.

 [3] Carpenter, Robert, et al. “Bed sharing when parents do not smoke: is there a risk of SIDS? An individual level analysis of five major case–control studies.” BMJ open 3.5 (2013): e002299.

[4] Finer, Lawrence B., and Mia R. Zolna. “Unintended pregnancy in the United States: incidence and disparities, 2006.” Contraception 84.5 (2011): 478-485.

[5] National Center for Health Statistics (US). Healthy people 2010: Final review. Government Printing Office, 2011.

[6] James, David K., et al. High risk pregnancy: management options-expert consult. Elsevier Health Sciences, 2010.

[7][7] Dietz, Patricia M., et al. “Infant morbidity and mortality attributable to prenatal smoking in the US.” American journal of preventive medicine 39.1 (2010): 45-52.

[8] Bruin, Jennifer E., Hertzel C. Gerstein, and Alison C. Holloway. “Long-term consequences of fetal and neonatal nicotine exposure: a critical review.”Toxicological sciences 116.2 (2010): 364-374.

[9] Johnson, Kenneth C., et al. “Active smoking and secondhand smoke increase breast cancer risk: the report of the Canadian Expert Panel on Tobacco Smoke and Breast Cancer Risk (2009).” Tobacco control (2010): tc-2010.

[10] Cobb, Caroline, et al. “Waterpipe tobacco smoking: an emerging health crisis in the United States.” American journal of health behavior 34.3 (2010): 275.

[11] Thun, Michael J., et al. “The global burden of cancer: priorities for prevention.” Carcinogenesis 31.1 (2010): 100-110.

[12] Behm, Ilan, et al. “Increasing prevalence of smoke-free homes and decreasing rates of sudden infant death syndrome in the United States: an ecological association study.” Tobacco Control 21.1 (2012): 6-11.

[13] Moon, Rachel Y. “SIDS and other sleep-related infant deaths: expansion of recommendations for a safe infant sleeping environment.” Pediatrics 128.5 (2011): e1341-e1367.

[14] Ino, Toshihiro. “Maternal smoking during pregnancy and offspring obesity: Metaâ€Âanalysis.” Pediatrics International 52.1 (2010): 94-99.

[15] American Diabetes Association. “Standards of medical care in diabetes—2010.” Diabetes care 33.Supplement 1 (2010): S11-S61.

[16] Joubert, Bonnie R., et al. “450K epigenome-wide scan identifies differential DNA methylation in newborns related to maternal smoking during pregnancy.” Environmental health perspectives 120.10 (2012): 1425.

[17] Neuman, Åsa, et al. “Maternal smoking in pregnancy and asthma in preschool children: a pooled analysis of eight birth cohorts.” American journal of respiratory and critical care medicine 186.10 (2012): 1037-1043.

[18] Langley, Kate, et al. “Maternal and paternal smoking during pregnancy and risk of ADHD symptoms in offspring: testing for intrauterine effects.”American journal of epidemiology 176.3 (2012): 261-268.

[19] Schetter, Christine Dunkel, and Lynlee Tanner. “Anxiety, depression and stress in pregnancy: implications for mothers, children, research, and practice.” Current opinion in psychiatry 25.2 (2012): 141.

[20] Mochow, Suzanne Painter. “Whitner v. South Carolina.” J. Juv. L. 18 (1997): 238.

[21] Briggs, Gerald G., Roger K. Freeman, and Sumner J. Yaffe. Drugs in pregnancy and lactation: a reference guide to fetal and neonatal risk. Lippincott Williams & Wilkins, 2012.

[22] Tapon, Dagmar. “Prenatal testing for Down syndrome: Comparison of screening practices in the UK and USA.” Journal of genetic counseling 19.2 (2010): 112-130.

[23] Davies, Michael J., et al. “Reproductive technologies and the risk of birth defects.” New England Journal of Medicine 366.19 (2012): 1803-1813.

[24] Bronitt, Simon, and Bernadette McSherry. Principles of criminal law. Thomson Reuters, 2010.

[25] Levi, Edward H. An introduction to legal reasoning. University of Chicago Press, 2013.

[26] del Carmen, Rolando. Criminal procedure: Law and practice. Cengage Learning, 2013.

[27] Reiss, Dorit Rubinstein. “Compensating the victims of failure to vaccinate: what are the options.” Cornell JL & Pub. Pol’y 23 (2013): 595.

[28] Weininger, Alexandria. “Fetal Rights and Prenatal Substance Abuse: A Comparative Law Perspective.” (2013).

[29] De Cruz, Peter. Comparative healthcare law. Routledge, 2013.

[30] Steele, Jenny. Tort Law: Text, cases, and materials. Oxford University Press, 2010.

[31] Fuller, David W. “Intentional torts and other exceptions to the federal tort claims act.” U. St. Thomas LJ 8 (2010): 375.