Development of Algebraic Thinking Through Justification in Elementary Education

The aim of this paper is to describe a teaching proposal that promotes algebraic thinking through the expression and justification of mathematical ideas when solving tasks related to three different approaches to algebraic thinking. We designed a classroom teaching experiment implemented during the COVID pandemic in Chile. We analyze the oral discussions and the written productions of children in fourth grade (9-10 years old). The results show that the children expressed and justified increasingly sophisticated algebraic ideas. That is, they gradually adopted a more precise and mathematical language. We conclude that this modality of work, in which the algebraic character of arithmetic is highlighted through various instances of discussion, is a contribution for teachers, by guiding them in addressing current teaching challenges. © 2023 Universitat Autonoma de Barcelona. All rights reserved.

The impact of work pressure and work completion justification on intentional nonmalicious information security policy violation intention.

As businesses have had to change how they operate due to the coronavirus pandemic, the need for remote work has risen. With the continuous advancements in technology and increases in typical job demands, employees need to increase their work productivity beyond regular work hours in the office. This type of work environment creates even more opportunities for security breaches due to employees intentionally violating information security policy violations. Although explicitly prohibited by information security policies (ISP), organizations have observed that employees bring critical data out of the office to complete their work responsibilities remotely. Consequently, developing a deeper understanding of how work pressure may influence employees to violate ISPs intentionally is crucial for organizations to protect their critical information better. Based upon the fraud triangle theory, this study proposes the opportunity to copy critical data, work pressure, and work completion justification as the primary motivational factors behind why employees copy critical company data to unsecured storage devices to work at home. A survey was conducted of 207 employees from a marketing research firm. The results suggest that opportunity, work pressure, and work completion justification are positively related to nonmalicious ISP violation intentions. Furthermore, the interaction effect between work completion justification and work pressure on the ISP violation intention is significant and positive. This study provides new insights into our understanding of the roles of work pressure and work completion justification on intentional nonmalicious ISP violation behaviors.

Stories as evidence

People often use personal stories to support and defend their views. But can a personal story be evidence? A story tells us that a certain event can happen and has already happened to someone, but it may not always help us understand what caused the event or predict how likely that event is to happen again in the future. Moreover, people confabulate. That is, when they tell stories about their past, they are likely to distort reality in some way. When people who lack access to what motivated past behaviour are asked why they made a choice, they tend to offer plausible considerations in support of that choice, even if those considerations could not have played a motivating role in bringing about their behaviour. When people experience impairments in autobiographical memory, they tend to fill the gaps in their own story by reconstructing significant events to match their interests, values, and conception of themselves. This means that people often offer a curated version of the events they describe. In this paper, we argue that the pervasiveness of confabulation does not rule out that personal stories can be used as evidence but invites us to reflect carefully about what they are evidence of. And this is especially important in the context of digital storytelling, because stories shared on online platforms can exert even greater influence on what people think and do.

Cultural values, system justification, meritocratic beliefs, and evaluations of governments' performance in handling the COVID-19 crisis

System justification and meritocratic beliefs legitimize the status quo of economic, social, and political arrangements, and may correlate with favourable evaluations of governments' performance during the COVID-19 pandemic. This study furthers research on this topic by examining (1) the cultural value antecedents of system justification and meritocratic beliefs, and (2) the differential effects of these on attitudes toward ingroups and outgroups from an intergroup perspective. The results show that collectivist values positively predict system justification and meritocratic beliefs, whereas a similar effect was not observed for individualist values. As hypothesized, system justification motivation was positively associated with favourable evaluation of the Chinese government (an ingroup). By contrast, system justification and meritocratic beliefs were negatively associated with evaluation of the American government (an outgroup). We discussed the implications for understandings of the cultural value bases of system justification and meritocratic beliefs, and the relevance of the lens of intergroup relations in studying those beliefs. © 2023 Asian Association of Social Psychology and John Wiley & Sons Australia, Ltd.

Sustaining Livelihoods or Saving Lives? Economic System Justification in the Time of COVID-19.

An ongoing debate in the United States relating to COVID-19 features the purported tension between containing the coronavirus to save lives or opening the economy to sustain livelihoods, with ethical overtones on both sides. Proponents of opening the economy argue that sustaining livelihoods should be prioritized over virus containment, with ethicists asking, "What about the risk to human life?" Defendants of restricting the spread of the virus endorse saving lives through virus containment but contend with the ethical concern "What about people's livelihoods and individual freedoms?" A commonly held belief is that political ideology drives these differential preferences: liberals are more focused on saving lives, whereas conservatives favor sustaining livelihoods with no additional government intervention in the free-market economy. We examine these lay beliefs among US residents in four studies and find that economic system justification (ESJ), an ideology that defends the prevailing economic system when under threat, is a reliable psychological predictor beyond political ideology. Specifically, compared to those who scored low on ESJ, people who scored high on ESJ judged China as more justified in downplaying the spread of virus to protect its interest in the global free-market economy, supported in-person over online learning, viewed shelter in place as less desirable, and perceived the opening of the Texas economy as more legitimate. We also find that multiple psychological mechanisms might be at work-resistance to market interventions, perceived legitimacy of opening the economy, perceived seriousness of the health crisis, and violation of human rights. Supplementary Information: The online version contains supplementary material available at 10.1007/s10551-022-05091-4.

A creeping crisis when an urgent crisis arises: The reprioritization of plastic pollution issues during COVID‐19

Single‐use plastics (SUPs) are increasingly polluting terrestrial, coastal, and marine habits, contributing to the creeping “plastic crisis.” The COVID‐19 pandemic provided a window of opportunity for decision makers to change the degree of urgency and responsiveness to this crisis and for policy entrepreneurs and industry who are against reducing plastic consumption to influence decision makers to change their position on various plastic‐related issues. Hygiene/health concerns have been used as a justification by governments and industry to increase the use of SUPs resulting in a reversal in, or a reprioritization of, policy decisions. Through the Multiple Streams Framework (MSF), I examine how creeping crises become secondary to urgent crises through agenda setting that is influenced and leveraged by policy entrepreneurs. I explore examples of such plastic policy decisions finding that they have been politically driven and influenced by entrepreneurs and industry rather than being primarily based on health concerns.Related ArticlesDiaz‐Kope, Luisa, and John C. Morris. 2022. “Why Collaborate? Exploring the Role of Organizational Motivations in Cross‐sector Watershed Collaboration.” Politics & Policy 50(3): 516â€"39. https://doi.org/10.1111/polp.12470.Gerlach, John David, Laron K. Williams, and Colleen E. Forcina. 2013. “The Science‐Natural Resource Policy Relationship: How Aspects of Diffusion Theory Explain Data Selection for Making Biodiversity Management Decisions.” Politics & Policy 41(3): 326â€"54. https://doi.org/10.1111/polp.12017.Neill, Katharine A., and John C. Morris. 2012. “A Tangled Web of Principals and Agents: Examining the Deepwater Horizon Oil Spill through a Principalâ€"Agent Lens.” Politics & Policy 40(4): 629â€"56. https://doi.org/10.1111/j.1747‐1346.2012.00371.x.Alternate :Una crisis progresiva cuando surge una crisis urgente: La repriorización de los problemas de contaminación plástica durante el COVID‐19Los plásticos de un solo uso (SUP) están contaminando cada vez más los hábitos terrestres, costeros y marinos, lo que contribuye a la progresiva "crisis del plástico". La pandemia de COVID‐19 brindó una ventana de oportunidad para que los tomadores de decisiones cambien el grado de urgencia y capacidad de respuesta a esta crisis y para los empresarios de políticas y la industria que están en contra de reducir el consumo de plástico para influir en los tomadores de decisiones para cambiar su posición sobre varios temas relacionados con el plástico. Los gobiernos y la industria han utilizado las preocupaciones de higiene/salud como justificación para aumentar el uso de SUP, lo que ha dado lugar a una reversión o una nueva priorización de las decisiones políticas. A través del Marco de Corrientes Múltiples (MSF, por sus siglas en inglés), examinamos cómo las crisis progresivas se vuelven secundarias frente a las crisis urgentes a través del establecimiento de una agenda que es influenciada y aprovechada por los empresarios de políticas. Exploramos ejemplos de tales decisiones sobre políticas de plástico y descubrimos que han sido impulsadas políticamente e influenciadas por empresarios y la industria en lugar de basarse principalmente en preocupaciones de salud.Alternate :紧急危机发生时的慢性危机:2019å† çŠ¶ç—…æ¯'病期间塑料污æŸ"问题的优先次序调整一次性塑料(SUP)越来越多地污æŸ"陆地、沿海å'Œæµ·æ´‹çŽ¯å¢ƒï¼Œä¸ºæ…¢æ€§â€œå¡‘料危机”作贡献。2019å† çŠ¶ç—…æ¯'ç—…(COVID‐19)大流行为决策者提供了一个机会之窗，以改变对这场危机的紧迫程度å'Œå"åº”程度，并为反对减少塑料消费的政策企业家å'Œè¡Œä¸šæä¾›æœºä¼šï¼Œä»¥å½±å"å†³ç­–者改变其在不同塑料相关问题上的立场。卫生/健康问题已被政府å'Œè¡Œä¸šç”¨ä½œå¢žåŠ SUP使用的理由，从而导致政策决策发生逆转或优先次序调整。通过使用多源流框架(MSF)，我们分析了慢性危机如何在一个受政策企业家影å"å'Œåˆ©ç”¨çš„议程设置下次于 ´§æ€¥å±æœºã€‚我们探究了这类塑料政策决策的例子，发现决策的制定并非主要基于健康问题，而是受到企业家å'Œè¡Œä¸šçš„政治驱动å'Œå½±å"ã€‚

Connectedness of green investments and uncertainties: new evidence from emerging markets

Purpose>This study aims to investigate the response of green investments of emerging countries to own-market uncertainty, oil-market uncertainty and COVID-19 effect/geo-political risks (GPRs), using the tail risks of corresponding markets as measures of uncertainty.Design/methodology/approach>This study employs Westerlund and Narayan (2015) (WN)-type distributed lag model that simultaneously accounts for persistence, endogeneity and conditional heteroscedasticity, within a single model framework. The tail risks are obtained using conditional standard deviation of the residuals from an asymmetric autoregressive moving average – ARMA(1,1) – generalized autoregressive conditional heteroscedasticity – GARCH(1,1) model framework with Gaussian innovation. For out-of-sample forecast evaluation, the study employs root mean square error (RMSE), and Clark and West (2007) (CW) test for pairwise comparison of nested models, under three forecast horizons;providing statistical justification for incorporating oil tail risks and COVID-19 effects or GPRs in the predictive model.Findings>Green returns responds significantly to own-market uncertainty (mostly positively), oil-market uncertainty (mostly positively) as well as the COVID-19 effect (mostly negatively), with some evidence of hedging potential against uncertainties that are external to the green investments market. Also, incorporating external uncertainties improves the in-sample predictability and out-of-sample forecasts, and yields some economic gains.Originality/value>This study contributes originally to the green market-uncertainty literature in four ways. First, it generates daily tail risks (a more realistic measure of uncertainty) for emerging countries' green returns and global oil prices. Second, it employs WN-type distributed lag model that is well suited to account for conditional heteroscedasticity, endogeneity and persistence effects;which characterizes financial series. Third, it presents both in-sample predictability and out-of-sample forecast performances. Fourth, it provides the economic gains of incorporating own-market, oil-market and COVID-19 uncertainty.

Analysing the interplay between the right to health and pharmaceutical patent rights in the introduction of a COVID-19 vaccine into the Philippines

Purpose>The COVID-19 pandemic has devastated economies and public health systems across the globe, increasing the anticipation for the creation of an effective vaccine. With this comes the reinforcement of debates between the right to health and pharmaceutical patent rights. The purpose of this study is to illustrate how the Philippines could attempt to balance the right to health with pharmaceutical patent rights in the introduction of a potential COVID-19 vaccine into the country.Design/methodology/approach>This will be accomplished through an examination of the flexibilities allowed by international agreements and domestic patent laws.Findings>With the economic and health challenges brought about by the COVID-19 pandemic, the Philippine Government will have a strong justification to pursue parallel importation and compulsory licencing under the Agreement on Trade-Related Aspects of Intellectual Property Rights. This is exacerbated by the bold leadership of President Duterte, whose administration has so far shown a propensity to decide in favor of the right to health at the expense of other rights in dealing with the pandemic.Originality/value>While this paper focuses on the Philippines, it has a potential application in the least developed and developing countries which aim to gain access to a prospective COVID-19 vaccine. Moreover, while this study discusses the harmonization of laws on the right to health and patent laws as a solution to the COVID-19 pandemic and the lack of access to vaccines, it also calls for solutions that go beyond the application of the law.

Normative foundations of society in the time of COVID-19: On alienation, repetition and social recognition

(Slovene) V prispevku bom pokazal, zakaj poudarjanje potrebe po normativnem upravicenju predstavlja pomembno referencno tocko za moznost konkretnejsega razumevanja druzbenih patologij in konfliktov, ki nastajajo v sodobni druzbi, ki jo zaznamuje dolgotrajna kriza zaradi COVID-19, in ki ga je po avtorjevem prepricanju mogoce ustrezno razloziti le s pomocjo cvrstega normativnega programa;le-ta pa je pogojen z moznostjo lastnega upravicenja. Zdi se, da v spremenjeni politicni klimi in ob novih druzbenih vprasanjih, ki nam jih predstavlja sodobna druzba, tako relativizacija razuma v druzbi kot strog kantovski kognitivizem delujeta kot vedno bolj neustrezni skrajnosti. Pri tem pa ostaja odprto vprasanje, ce je moc razviti sprejemljiv in prakticno uporaben koncept komunikativne racionalnosti in razmeroma trdnih normativnih struktur druzbe, brez da bi se zatekli k prevec abstraktnim, funkcionalno omejenim in pogosto nehistoricnim pristopom k moralni filozofiji. Sprico tega avtor predlaga razvoj programa kriticne hermenevtike, ki ob podajanju formalnih pogojev eticnega zivljenja v druzbi poudarja tudi pomen hermenevticnega samorazumevanja. (PsycInfo Database Record (c) 2022 APA, all rights reserved)

Determining Vaccine Justice in the Time of COVID-19: A Democratic Perspective

What does vaccine justice require at the domestic and global levels? In this essay, using the COVID-19 pandemic as a backdrop, we argue that deliberative-democratic participation is needed to answer this question. To be effective on the ground, principles of vaccine justice need to be further specified through policy. Any vaccination strategy needs to find ways to prioritize conflicting moral claims to vaccine allocation, clarify the grounds on which low-risk people are being asked to vaccinate, and reach a balance between special duties toward countrymen and universal duties toward foreigners. Reasonable moral disagreement on these questions is bound to exist in any community. But such disagreement threatens to undermine vaccine justice insofar as the chosen vaccination strategy (and its proposed specification of vaccine justice) lacks public justification. Inclusive democratic deliberation about vaccine justice is a good mechanism for tackling such moral disagreement. By allowing residents and citizens to participate in the specification of principles of vaccine justice, and their translation into policy, democratic deliberation can enhance the legitimacy of any vaccination strategy and boost compliance with it.

Business diplomacy and justification: new postpandemic 'Rules of the Game'

The pandemic disrupted normal life worldwide in 2020-21 and created room for the recreation of society as a 'moral community'. History shows that moral norms and power structures that are developed during social crises impact the future 'rules of the game' for transnational businesses. During the pandemic, many governments made health their top priority and imposed restrictions that harmed some business interests. By doing so, they demonstrated both a willingness and an ability to prioritise other goals than economic growth, and post-pandemic this may lead to prioritising other of the UN SDGs. This study contributes to the existing literature with the suggestion that firms will be motivated to engage in diplomacy when economy is not the sole priority for governments and governments have demonstrated the strength and willingness to impose restrictions on business. In short, the incentives come from the acknowledgment of societies' need to balance and mediate between different priorities and actors from different spheres with different interests. Benevolence seems to be increasingly important for trust in businesses and for justification. © 2022 Inderscience Enterprises Ltd.

Vitamin D deficiency in British South Asians, a persistent but avoidable problem associated with many health risks (including rickets, T2DM, CVD, COVID-19 and pregnancy complications): the case for correcting this deficiency.

High vitamin D deficiency rates, with rickets and osteomalacia, have been common in South Asians (SAs) arriving in Britain since the 1950s with preventable infant deaths from hypocalcaemic status-epilepticus and cardiomyopathy. Vitamin D deficiency increases common SA disorders (type 2 diabetes and cardiovascular disease), recent trials and non-linear Mendelian randomisation studies having shown deficiency to be causal for both disorders. Ethnic minority, obesity, diabetes and social deprivation are recognised COVID-19 risk factors, but vitamin D deficiency is not, despite convincing mechanistic evidence of it. Adjusting analyses for obesity/ethnicity abolishes vitamin D deficiency in COVID-19 risk prediction, but both factors lower serum 25(OH)D specifically. Social deprivation inadequately explains increased ethnic minority COVID-19 risks. SA vitamin D deficiency remains uncorrected after 70 years, official bodies using 'education', 'assimilation' and 'diet' as 'proxies' for ethnic differences and increasing pressures to assimilate. Meanwhile, English rickets was abolished from ~1940 by free 'welfare foods' (meat, milk, eggs, cod liver oil), for all pregnant/nursing mothers and young children (<5 years old). Cod liver oil was withdrawn from antenatal clinics in 1994 (for excessive vitamin A teratogenicity), without alternative provision. The take-up of the 2006 'Healthy-Start' scheme of food-vouchers for low-income families with young children (<3 years old) has been poor, being inaccessible and poorly publicised. COVID-19 pandemic advice for UK adults in 'lockdown' was '400 IU vitamin D/day', inadequate for correcting the deficiency seen winter/summer at 17.5%/5.9% in White, 38.5%/30% in Black and 57.2%/50.8% in SA people in representative UK Biobank subjects when recruited ~14 years ago and remaining similar in 2018. Vitamin D inadequacy worsens many non-skeletal health risks. Not providing vitamin D for preventing SA rickets and osteomalacia continues to be unacceptable, as deficiency-related health risks increase ethnic health disparities, while abolishing vitamin D deficiency would be easier and more cost-effective than correcting any other factor worsening ethnic minority health in Britain.

RESEARCH DURING THE TIME OF THE PANDEMIC

Funding agencies are providing financial resources for projects. [...]although people are going through a harrowing period, creative possibilities have opened up for research on new forms of management. Questioning the justification of entrepreneurship in Chilean public policies," by Oriana Bernasconi and Juan Felipe Espinosa-Cristia;"Tupi, or not Tupi that is the question": Amerindian perspectivism and Organizational Studies," by Sergio Eduardo de Pinho Velho Wanderley and Ana Paula Medeiros Bauer;and "Organizing the Organizational Studies in Chile: History of the creation of the Minga Group," by Gregorio Perez-Arrau, Alvaro Espejo, Marcela Mandiola, Nicolás Ríos González, and Juan Pablo Toro. Happy reading and take care! (*) Professor Carlos Henrique de Brito Cruz, President of Fapesp, leaves office in April 2020.

Learning from COVID-19: Public Justification and the Ontology of Everyday Life

Liberal democracies across the world have responded to the COVID-19 pandemic by implementing measures that significantly curtail the rights and liberties of individual citizens. These measures must receive public justification in order to be politically legitimate. By combining analytical political philosophy with ontology in an original way, in this article we argue that liberal democratic governments have so far failed to adequately justify these measures, since they have not systematically targeted the scholarly study of COVID-19 in everyday environments, consequently implementing rules that are epistemically unsound and not publicly justified, at least not fully. [ FROM AUTHOR] Copyright of Social Theory & Practice is the property of Florida State University, Dept. of Philosophy and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full . (Copyright applies to all s.)

Intelligent Decision Support System for Modeling Transport and Passenger Flows in Human-Centric Urban Transport Systems

Engineering human-centric urban transport systems should be carried out using information technology in forecasting traffic and passenger flows. One of the most important objects of urban transport systems’ progress is modeling patterns of transport flows and their distribution on the road network. These patterns are determined by the subjective choice of city residents of traffic routes using public and private transport. This study aimed to form a sequence of stages of modeling transport and passenger flows in human-centric urban transport systems and passenger flows in the human-centric urban intelligent transport systems and to determine the patterns of change to the gravity function of employees of municipal services. It was revealed that the trip distribution function of workers of urban service enterprises can be described by the attributes of the structure of the city, socio-economic data, and attributes characterizing the zones and its residents.

"The greedy I that gives"-The paradox of egocentrism and altruism: Terror management and system justification perspectives on the interrelationship between mortality salience and charitable donations amid the COVID-19 pandemic.

Why do people give and help others in face of their own mortality salience? The existential struggle with the awareness of death impacts the gamut of human cognition, emotion, and behavior. This multi-method research (∑N = 1,219) explains the psychosocial impact of COVID-19-related mortality salience on altruism. Drawing from terror management theory, two studies tested death-thought accessibility, mortality salience, and anxiety buffer hypotheses. Study 1 (cross-sectional survey), using structural equation modeling, confirms death anxiety and fear are predictors of powerlessness and materialism which, in turn, predict charitable donations. Study 2 (between-subjects experiment) confirms the causal effects of COVID-19-induced mortality salience on altruism. Controlling income and socioeconomic status, people in the mortality salience treatment condition indicate greater monetary donations ($), ratio of prosocial (altruistic) to proself (egocentric) spending (%), donation of time (hour), monetary valuation of time (hourly rate = $/hour), and economic value of donated time (hourly rate*hour) than the controls. These effects are mediated by powerlessness. Moderating effects of relevant individual difference factors are significant: the greedier, more selfish, narcissistic, materialistic, and system-justifying the donor is, the higher monetary donations, volunteer time, and perceived value of donated time are, only when the COVID-19-induced mortality is made salient but not in the controls. Environmental and dispositional factors jointly influence vulnerability to mortality salience. The paradox of egocentrism and altruism, as an evolutionarily adaptive protective buffer against existential insecurity for social and cultural animals, can help revitalize resilience, thus shedding some lights on the sociopsychological mechanism of consumers' subjective well-being. Implications for consumer affairs, social marketers, and policymakers are discussed.

Rhetoric and Argumentation in the Pandemic Legislation: The Italian Case

This chapter examines the argumentative and rhetorical structure of the regulatory techniques used to deal with the SARS-CoV-2 pandemic in Italy. The first part of the chapter aims to clarify the connection between law and rhetoric, in order to provide a framework in which the legislative activity has operated. After analyzing critical aspects of the chosen regulatory tools, we will focus on the three most innovative elements of the pandemic legislation: the frequent use of images, the sporadic presence of sanctions, and the relevant role of experts. In the second part, an analysis of the fundamental traits of visual argumentation will be presented to highlight the fact that the use of images, during the pandemic period, has become a political-normative technique, which is never a neutral tool, but is always subject to interpretation and endowed with a notable rhetorical value. Given the sporadic presence of sanctions, the second section will analyze the argumentative strengthening applied by the legislator in order to promote the obedience of the recipients of the measures. Finally, we will examine the involvement of experts in the justificatory activity of the legislator, and the need for them to acquire legislative legitimacy through a rhetorical-argumentative relationship with citizens. © 2022, The Author(s).

Letting go of strict deadlines: Increasing flexibility to level the playing field

Some faculty feel that due dates teach professionalism and self-regulation. In line with that intent, professors administer penalties to enforce the value of completing work in a timely manner. However, the shared cultural experience of the COVID-19 pandemic found faculty and students facing a common concern, which demanded greater flexibility. Faculty were readily able to empathize with challenges students were facing at that moment. Thus, the pandemic became a time to reconsider such strict enforcement of various policies, including those surrounding due dates and late work. Certainly, prior to the pandemic, professors may have offered extensions or waived penalties on a case-by-case basis when students provided justification. This approach, while well intentioned, may disproportionately hinder students who have been historically marginalized, as these students may not think to make such requests or may worry about a professor's reaction to such requests. Rather ironically then, students with the most privilege may be more likely to request assistance but are less likely to struggle with an overload of work, family, and school obligations. Women, in particular, are more likely to receive such requests and therefore be disproportionately burdened. (PsycInfo Database Record (c) 2022 APA, all rights reserved)

The General Court's Decisions on State Aid Law in Times of COVID-19 Pandemic

The unprecedented crisis caused by the pandemic of Coronavirus disease 2019 (COVID-19) not only shattered the economics of the aviation industry, it also put to test long established legal rules, while Governments were desperately adopting emergency measures. Facing a very severe situation, caused by airspace closures and restrictions imposed to travellers, several European airlines received governmental support, while others did not. This led to criticisms from airlines, most notably from the low-cost carrier Ryanair, which transposed into legal actions undertaken in front of the General Court of the European Union. At the heart of this legal battle lay the rules governing State Aid, as the European Commission was criticized for not assessing thoroughly enough the measures that were notified by the Member States. The judgments of the General Court revealed that, irrespective of the exceptional situation faced in Europe, the correct application. of EU Law must prevail, which includes the judicial review of acts adopted by the European institutions. As two decisions of the Commission authorizing measures of governmental support were annulled, some lessons can be learnt for the future.

ICE RUSES: FROM DECEPTION TO DEPORTATION

In 2005, the Immigration and Customs Enforcement (ICE) agency enacted a policy sanctioning its civil ICE agents to use strategic deception, known as "ruses," to facilitate community immigration enforcement operations. This policy provided agents a means to overcome the limitation that civil immigration arrest warrants are administrative as opposed to judicial in nature, which effectively precluded agents from entering a target's home without first obtaining consent. Since, civil ICE agents have deployed various ruses to lure targets outside of their homes or, more controversially, elicit consent to gain entry into their homes. Once inside, agents often conduct sweeping searches and execute "collateral arrests" of nontarget bystanders who are also suspected to be undocumented. The Fourth Amendment has always tolerated some degree of law enforcement deception. But the existing body of law that delineates the constitutional limits of government deceit contemplates the use of ruses in only the criminal context, which assumes that criminal law enforcement officers are employing subterfuge only against purported criminals. Legal analysis of the use of deception in the civil immigration context is almost entirely lacking, largely because ICE ruse practices have escaped judicial scrutiny. This Note seeks to close this gap by examining both the legal and policy questions raised when a civil government agency uses deception against those who have committed a civil immigration infraction. It then proposes two limitations on the current policy that would address the constitutional concerns and better align it with the policy justification underlying the use of government deception.