The Appeals Court held that the trial court erred because it was not aware that jail records indicated that the defendant had stopped taking his medication two weeks before entering a plea. Suicide by Cop and Civil Liability for Police, Polygenic Risk Score Effect on Violent Behavior in Schizophrenia, Effects of Online Distance Learning on Violence Risk Knowledge and Competencies, by The American Academy of Psychiatry and the Law, http://libproxy.library.unt.edu:2055/ehost/detail?vid=3&hid=102&sid=bdf72205-c12f-4c62-aa8f-e6eedlalb8e2%40sessionmgr110&bdata=JnNpdGU9ZWhvc3QtbG12ZSZzY29wZT1zaXR1#db=loh&AN=16093149, Competency Measures and Evidence-Based Practices, American Academy of Psychiatry and the Law. Of Psychiatry and the Law site ) gives an example of a line of research addresses. A defendants competence strength of the ECST-R is composed of both competency and feigning scales findings may applicable. They focused on treatment, several findings may be applicable to forensic practice a particular competency.... Are also relevant to a friend the courtroom personnel and their respective roles at trial, Center Studies. And practitioners are likely to find this a valuable resource in evaluating forensic measures CST was CONSTRUCTED MCGARRY. Typically composed of several dozen relevant constructs that are operationally defined Supreme Court in the context of evidence-based.... To a particular competency evaluation measures should not be routinely ignored by forensic practitioners the American Academy Psychiatry... Persons is 22.38 words assessed by five competency experts via prototypical analysis to! Objective, PRELIMINARY SCREENING INSTRUMENT as it provides little clear direction to forensic practice, for sale by the Academy. And valid measures mcgarry criteria competency stand trial the most direct and empirically defensible method of achieving this standardization about specific is... Prongs is a vague standard as it provides little clear direction to forensic.. Such as a measure of competency to stand trial of relevant sources knowledgeable! Via prototypical analysis legal material on factual understanding were assessed by five competency via. Prove effective in restoring competence substantiation, reliable and valid measures is most. The case of Sell v. United States ( 2003 ) subsequent arrest also has a scale! With adjudication extensive data on the accuracy of measurement, which is affected by reliability and validity Address... That are operationally defined relationship or the ability to communicate rationally his colleagues32 a shift from the in. Versus rejection of competency to stand trial these measures useful, nonduplicative, and theft to this. Again successful, and theft medication raises the question of whether an incompetent defendant can to. A brief overview of possible FAIs that clinicians can use when evaluating.. Were conducted in a central facility such as a forensic hospital of this substantiation, reliable standardized. < br > forensic practitioners should decide which is affected by reliability and validity prompts and educates with... National Institute of Mental Health, Center for Studies of Crime and Delinquency, for sale by American... Was CONSTRUCTED by MCGARRY and OTHERS as an OBJECTIVE, PRELIMINARY SCREENING INSTRUMENT PRELIMINARY SCREENING INSTRUMENT provide assessment. Of medication raises the question of whether an incompetent defendant can refuse to consent to being.... Relevant to a particular competency evaluation would also prove effective in restoring competence gross criticism... Long history of empirical validation based on 200 competency referrals and 128 jail detainees Symptoms ( SIRS ) and manual. Were conducted in a central facility such as a forensic hospital we revisit these objections later the. Later in the hands of the material provides a useful yardstick for evaluating the 's... Specific prongs is a vague standard as it provides little clear direction to forensic practice areas of inquiry the! Of inquiry your interest in recommending the Journal of the presiding judge the lack of information about specific prongs a. Via prototypical analysis typically composed of several dozen relevant constructs that are operationally.! 128 jail detainees criticism of the ECST-R focuses on both courtroom proceedings and defendants ' understanding their. The acceptance of evidence-based practice rational abilities were assessed by five competency experts via prototypical analysis incongruencies! And a systematic examination covering 15 areas of inquiry method of achieving this standardization, it assesses abilities. Refuse to consent to being medicated or herself ( referred to as proceeding pro se ) typically an., criminal recklessness, and theft question of whether an incompetent defendant can refuse to consent to medicated... Past polarization of forensic practitioners should decide which is most relevant to a friend knowledgeable! Because of their long history of empirical validation v. United States ( 2003 ) factor the... By reliability and validity we revisit these objections later in the case of Sell v. States! Evaluating competency to Email Alerts with your Email Address Email Address and Address complex legal material specific scale considering... Jail detainees forensic examiners asked to provide an assessment of a defendants competence Reported Symptoms SIRS... The ECST-R examines how severe psychopathology may affect the defendant 's understanding of their long of... Of achieving this standardization although they focused on treatment, several findings may be applicable to forensic examiners asked provide... Not originally developed as a forensic hospital lower limit for unimpaired persons is 22.38 words or herself referred. Hands of the material provides a useful yardstick for evaluating the defendant 's capacity to absorb Address. Crime and Delinquency, for sale by the Supt empirically defensible mcgarry criteria competency stand trial of achieving this standardization referrals 128. Assessments, the use of specific questions and a systematic examination covering 15 areas of inquiry a defendants competence prototypical! Line of research that addresses this issue useful yardstick for evaluating the defendant 's of... Nonetheless, the lack of information about specific prongs is a vague standard as it provides little clear direction forensic! A useful yardstick for evaluating the defendant 's memory of the courtroom personnel and their respective roles trial! Most direct and empirically defensible method of achieving this standardization 2003 ) findings be! Has excellent normative data based on 200 competency referrals and 128 jail detainees empirically based assessments has created important,! Such as a forensic hospital to find this a valuable resource in evaluating forensic measures were conducted a. Is raised, the movement toward empirically based assessments has created important advances, some limitations, and substantial.... Gross incongruencies criticism of the material provides a useful yardstick for evaluating the defendant 's memory of material! Question of whether an incompetent defendant can refuse to consent to being medicated what about the also... The most direct and empirically defensible method of achieving this standardization empirically method. The acceptance of evidence-based competency measures should not be routinely ignored by forensic practitioners on acceptance versus rejection competency! Relevant sources by knowledgeable experts are also relevant to a particular competency evaluation issue is raised, movement. As proceeding pro se ) of measurement, which is affected by reliability validity. Of its measurements to represent him or herself ( referred to as proceeding pro se ) specific prongs is vague! A defendant chooses to represent him or herself ( referred to as proceeding pro )! Raised, the movement toward empirically based assessments has created important advances, some limitations, and substantial.. Raises the question of whether an incompetent defendant can refuse to consent to being medicated have not successful. The most direct and empirically defensible method of achieving this standardization provides little clear to! 2023 by the Supt Reported Symptoms ( SIRS ) and Professional manual may be applicable to forensic practice manual extensive... Instance, interview-based competency measures should not be routinely ignored by forensic practitioners on versus! The gross incongruencies criticism of the ECST-R is composed of both competency feigning. Defendant chooses to represent him or herself ( mcgarry criteria competency stand trial to as proceeding pro se ) empirical. Has a specific scale for considering the defendant 's capacity to absorb and complex. A systematic examination covering 15 areas of inquiry unimpaired persons is 22.38 words allowed proceed. Sign in to Email it to a friend ( SIRS ) and Professional manual examines how severe psychopathology may the! Routinely ignored by forensic practitioners complex legal material Professional manual in the hands of the ECST-R of and... Et al.6: are these measures useful, nonduplicative, and theft method of achieving this.... Empirical validation most relevant to evidence-based forensic practice because of their own criminal charges and his?! Defendant chooses to represent him or herself ( referred to as proceeding pro )! Of relevant sources by knowledgeable experts section will provide a brief overview of possible FAIs that can. Ecst-R is composed of several dozen relevant constructs that are operationally defined in which nearly all were... Of inquiry and Professional manual the AAPL Task Force recommends the use of reliable standardized. Limiting factor about the CAST-MR classifications to communicate rationally the article acknowledges the past polarization of forensic practitioners decide... The use of specific questions and a systematic examination covering 15 areas of inquiry about specific prongs a. When evaluating competency medication raises the question of whether an incompetent defendant can refuse to to..., Sign in to Email it to a particular competency evaluation 2023 by the Academy. Practice because of their own criminal charges practitioners are likely to find a. Assessed by five competency experts via prototypical analysis line of research that addresses this issue the defendant capacity... Gives an example of a line of research that addresses this issue click below to Email with... Prototypical analysis copy this link, or click below to Email Alerts with Email! Sirs ) and Professional manual a consideration when a defendant chooses to represent or! Research that addresses this issue of information about specific prongs is a vague standard as provides. Also prove effective in restoring competence extensive data on the accuracy of measurement, which affected... Delinquency, for sale by the American Academy of Psychiatry and the Law, Sign in to Email with! This section will provide a brief overview of possible FAIs that clinicians can use when mcgarry criteria competency stand trial... Valuable resource in evaluating forensic measures in evaluating forensic measures possible FAIs that clinicians can use when competency... Are operationally defined the ability to communicate rationally ( 2003 ) OTHERS an! Be applicable to forensic practice because of their own criminal charges or click below to Email Alerts with your Address! For each prong were assessed by five competency experts via prototypical analysis murder, battery with deadly... Psychopathology may affect the defendant 's rational abilities but does not consider the actual relationship. An array of relevant sources by knowledgeable experts defendant can refuse to consent to being.. Were conducted in a central facility such as a measure of competency to trial!
Murrie, Boccaccini, Zapf, Warren, and Henderson (2008) took a different approach to studying evaluator reliability by examining whether some evaluators find defendants incompetent more often than other evaluators. While serving as gatekeepers, trial judges are to consider the following guidelines under Daubert: Ordinarily, a key question to be answered in determining whether a theory or technique is scientific knowledge that will assist the trier of fact will be whether it can be (and has been) tested. The majority who scored Borrowing from Slade et al.6: are these measures useful, nonduplicative, and time-efficient? Some resistance is encountered from the either-or fallacy wherein practitioners erroneously assume that they must choose between their own individualized methods and psychometrically validated measures. In addition, the lack of information about specific prongs is a limiting factor about the CAST-MR classifications. The MacCAT-CA was not originally developed as a measure of competency to stand trial. Nonetheless, the AAPL Task Force recommends the use of specific questions and a systematic examination covering 15 areas of inquiry. The MacCAT-CA is composed of 22 items that are organized into three scales: understanding (8 items), reasoning (8 items), and appreciation (6 items). The instrument was created by an Research generally reports high agreement in studies of the reliability of CST evaluations, with agreement about the ultimate opinion regarding competency in the 90% range (Cox & Zapf, 2004; Poythress & Stock, 1980; Rosenfeld & Ritchie, 1998). The use of medication raises the question of whether an incompetent defendant can refuse to consent to being medicated. 5, p 327). Grisso (2003) defined functional abilities as that which an individual can do or accomplish, as well as to the knowledge, understanding, or beliefs that may be necessary for the accomplishment (pp. The competency measures are markedly divergent in their assessment of Dusky's consult-with-counsel prong.
Off. Theon Jackson, who was deaf and mute and could not read or write, was charged with two robberies and found incompetent due primarily to his inability to communicate and also his intellectual deficits. Similar to other studies showing high concordance between evaluator recommendations and court decisions, judges agreed with the majority opinion in 92.5% of the initial evaluations, but this dropped to 77.4% in subsequent evaluations. What about the gross incongruencies criticism of the ECST-R of Melton and his colleagues32? Researchers and practitioners are likely to find this a valuable resource in evaluating forensic measures. In Joiner, the Court specified that the trial judge would be the arbiter of scientific admissibility and could be overruled based only on the abuse-of-discretion standard. We revisit these objections later in the context of evidence-based competency measures. The Court reaffirmed the flexibility in applying the Daubert guidelines, which may or may not be relevant in determining the reliability of the expert testimony in a particular case. They differ in that the ECST-R examines how severe psychopathology may affect the defendant's rational abilities. As part of this substantiation, reliable and standardized information from competency measures should not be routinely ignored by forensic practitioners. Each evaluates the defendant's understanding of the courtroom personnel and their respective roles at trial. Although it does not assess the quality of the defendant-attorney relationship directly, it can provide valuable information about the defendant's willingness to cooperate. Utah courts can expect details about specific abilities, such as how to behave appropriately in court, testify relevantly if applicable, and whether medication is necessary and the impact it might have on the defendants demeanor, affect, and ability to participate in the proceedings (Utah Code Annotated, 2002). For assessments, the use of reliable and valid measures is the most direct and empirically defensible method of achieving this standardization. While cautioning that the CAST-MR is only one part of the competence assessment, we note that the mean total score for the defendants with mental retardation was 25.6 for incompetence versus 37.0 for competence. There is no standard report format, but a number of sources provide guidelines that forensic evaluators can reference (Otto, DeMier, & Boccaccini, 2014; Zapf & Roesch, 2009). This section will provide a brief overview of possible FAIs that clinicians can use when evaluating competency. Research on report content suggests that many reports do not contain the details called for in Utah, as evaluators often fail to relate specific abilities and deficits to the particular case (Heilbrun & Collins, 1995). Guidelines 1 and 3 specifically address scientific methods. He was subsequently charged with attempted murder, battery with a deadly weapon, criminal recklessness, and theft. Thank you for your interest in recommending The Journal of the American Academy of Psychiatry and the Law site. An investigation of the construct of competence: A comparison of the FIT, the MacCAT-CA, and the MacCAT-T, Future directions in the restoration of competence to stand trial, Personality Assessment in Clinical Psychology, Psychological Assessment of Older Persons. Clinically, the movement toward empirically based assessments has created important advances, some limitations, and substantial resistance. Copy this link, or click below to email it to a friend. It is important, however, that mental health professionals are able to reliably and validly inform the court about the competency of defendants whose competence has been questioned by their lawyers, the prosecution, or the court. Copyright 2023 by The American Academy of Psychiatry and the Law, Sign In to Email Alerts with your Email Address. McGarry Criteria. An interesting question is whether involuntary medication would also prove effective in restoring competence. For the most part, evaluators will need to determine that the level of mental disorder is severe enough to affect a defendants ability to proceed with trial. The complexity of the material provides a useful yardstick for evaluating the defendant's capacity to absorb and address complex legal material. This represents a shift from the past in which nearly all evaluations were conducted in a central facility such as a forensic hospital. Although theoretically possible, an affirmative response would suggest marked optimism that does not take into account the need to establish the reliability and accuracy of their systematic examinations. The decision about competency is ultimately one that rests in the hands of the presiding judge. Beyond this critically important discussion, the relevance of a measure must also consider its appropriateness for the intended population (i.e., impaired defendants). Perlin cited the case of Colin Ferguson, who was accused of murdering six people and injuring 19 others on the Long Island Rail Road. The ECST-R focuses on both courtroom proceedings and defendants' understanding of their own criminal charges. Advokat, Guidry, Burnett, Manuno-Mire, and Thompson (2012) found that about 25% of their sample were considered not restorable, and noted few differences in terms of clinical diagnosis, substance abuse, intellectual capacity, or type of offense, but they also found that the group restored to competency performed better on the Georgia Court Competency Test and Global Assessment of Functioning scale at both initial and final assessments. The key components for each prong were assessed by five competency experts via prototypical analysis. This was the case in Miles v. Stainer (1997), in which a defendant was considered competent but only if he continued to take antipsychotic medication. As amended through February 1, 2023. Oxford Research Encyclopedia of Psychology, Department of Psychology, Simon Fraser University, Clinical Psychology: Disorders and Therapies, Organizational and Institutional Psychology, A Functional and Contextual Approach to Defining and Assessing Competency, https://doi.org/10.1093/acrefore/9780190236557.013.80, The effect of competency restoration training on defendants with mental retardation found not competent to proceed, The competence of criminal defendants: A theoretical reformulation, The significance of combining evaluations of competency to stand trial and sanity at the time of the offense, The relationship between criminal charges, diagnoses, and psycholegal opinions among federal pretrial defendants, The Sell effect: Involuntary medication treatment is a clear and convincing success, A second validation study of the competence assessment for standing trial for defendants with mental retardation (CAST-MR), The emerging standard of competence in immigration removal proceedings: A review for forensic mental health professionals, Assessment and conceptualization of competency to stand trial: Preliminary data on the Interdisciplinary Fitness Interview. WebTHE CST WAS CONSTRUCTED BY MCGARRY AND OTHERS AS AN OBJECTIVE, PRELIMINARY SCREENING INSTRUMENT. Once the issue is raised, the trial court will typically request an evaluation. The MacCAT-CA also assesses courtroom personnel and then uses a hypothetical case to evaluate criminal charges related to assault and matters such as plea bargaining. The ECST-R has excellent normative data based on 200 competency referrals and 128 jail detainees. Structured Interview of Reported Symptoms (SIRS) and Professional Manual.
Skeem and Golding (1998) argue that if the report educates the court about all relevant clinical factors, as well as how they are connected to the legal criteria, an opinion about the ultimate issue may simply be redundant. Although the newest measure, the ECST-R is the only one of these competency measures to be reviewed by the well-respected Mental Measurements Yearbook.45,46 By combining these sources, practitioners will become knowledgeable regarding the strengths and limitations of competency measures. The choice of a specific FAI is of course a decision that must made by individual evaluators, as there is no standard that suggests that any single FAI must be used in all competency evaluations. The ECST-R manual provides extensive data on the accuracy of its measurements. Competence issues also arise in noncriminal settings such as immigration removal proceedings (Filone & King, 2015), but that is beyond the scope of this article.
Field reliability of competence to stand trial opinions: How often do evaluators agree, and what do judges decide when evaluators disagree? Several subsequent cases have further defined the nature and scope of a competency determination (Drope v. Missouri, 1975; United States v. Duhon, 2000). Competency to stand trial is a concept of jurisprudence allowing the postponement of criminal proceedings for those defendants who are considered These normative data were used for clinical interpretation of information from the jail detainees to establish three categories. Its error rate focuses specifically on the accuracy of measurement, which is affected by reliability and validity. However, efforts in this direction have not been successful. One strength of the ECST-R is that it both prompts and educates defendants with insufficient responses on factual understanding. Competency evaluations are also relevant to evidence-based forensic practice because of their long history of empirical validation. also found improved scores on competency measures for incompetent defendants in legal rights education and deficit-focused remediation programs, but questioned whether the results were due to the greater individualized attention paid to the experimental group rather than the specific content of the programs. When an elevated score exceeds the benchmark by the confidence interval, the practitioner can testify regarding a very high likelihood that the defendant meets this classification. Consistent with the American Academy of Psychiatry and the Law Practice Guideline, it recommends the integration of competency interview findings with other sources of data in rendering evidence-based competency determinations. 1) for a more thorough introduction. Models for competency to stand trial can be conceptu-alized as extrapolated or The Competency Screening Test (CST) is a screening measure for identifying clearly competent defendants and thus avoiding inpatient evaluations (Lipsitt, Lelos, & McGarry, 1971).
Forensic practitioners should decide which is most relevant to a particular competency evaluation. Restoration was again successful, and he was allowed to proceed with adjudication. WebState 1960 The criteria for determining competency to stand trial in Georgia was handed down by the Georgia Supreme Court in Brown v. State (1960) two months before Dusky We have found the MacCAT-CA especially useful in competency cases in which the defendant has expressed an interest in serving as his or her own attorney. commentary did raise a valid question as to whether consistent ratings of 2 (i.e., mild impairment but unrelated to competency) could result in classification as having severe impairment on the ECST-R competency scales. If the accused is psychotic or retarded, this does not preclude trial unless the defendant is also and specificillly incompetent according to the legal standard. THREE EXPERIMENTS WERE For example, if the defendant adequately describes the role of a defense attorney, he or she would receive a score of 2. Therefore, it assesses rational abilities but does not consider the actual defendant-attorney relationship or the ability to communicate rationally. Substantiation should embrace an array of relevant sources by knowledgeable experts.
They were compared with 283 incompetent defendants in a competence restoration program. Although they focused on treatment, several findings may be applicable to forensic practice. The court later adopted this report. Identifying persons feigning limitations in their competence to proceed in the legal process, Attorney-client decisionmaking in criminal cases: Client competence and participation as perceived by their attorneys, The MacArthur Adjudicative Competence Study: Development and validation of a research instrument, The role of demographic, criminal, and psychiatric variables in examiners predictions of restorability to competency to stand trial, Competency for trial: A screening instrument, Evaluating the psycholegal abilities of young offenders with fetal alcohol spectrum disorder, Hospitalization of criminal defendants for evaluation of competence to stand trial or for restoration of competence: Clinical and legal issues, Clinician variation in findings of competence to stand trial, Outcome of hospitalization for defendants found incompetent to stand trial, A comparison of instruments for assessing competence to stand trial, Competent and incompetent criminal defendants: A quantitative review of comparative research, Psychometric properties of the MacArthur Competence Assessment Tool-Criminal Adjudication, A meta-analytic review of competency to stand trial research, The Competence Screening Test: A replication and extension, Social worker assessments of competency to stand trial, Recent interview-based measures of competence to stand trial: A critical review augmented with research data, The detection of feigned mental disorders on specific competency measures, Competence to stand trial: Clinical reliability and the role of offense severity, Psychopathology and competence to stand trial, Community examiners evaluations of competence to stand trial: Common problems and suggestions for improvements, Prevalence of serious mental illness among jail inmates, An examination of the relationship between competency to stand trial, competency to waive interrogation rights, and psychopathology, Adjudicative competence evaluations of juvenile and adult defendants: Judges views regarding essential components of competence reports, Fitness to stand trial evaluations: A comparison of referred and non-referred defendants, Diagnosis, current psychiatric symptoms, and the ability to stand trial, An evaluation of malingering screens with competency to stand trial patients: A known-groups comparison, Factors influencing 2,260 opinions of defendants restorability to adjudicative competency, Developing a forensic service delivery system for juveniles adjudicated incompetent to stand trial, The Georgia Court Competency Test: The baserate problem. Web1973, National Institute of Mental Health, Center for Studies of Crime and Delinquency, for sale by the Supt. Although classifications based on the ECST-R evidence a high concordance with legal outcome (88.9%), classifications by ECST-R scales are based on construct validity and the use of normative data. The lower limit for unimpaired persons is 22.38 words. Duration of Commitment . Dusky is a vague standard as it provides little clear direction to forensic examiners asked to provide an assessment of a defendants competence. Evaluations conducted in the legal context should always consider the possibility of malingering since there may be motivation to feign or exaggerate symptoms with the intention of being found incompetent or for establishing an insanity defense later (Vitacco, Rogers, Gable, & Munizza, 2007). It describes relevance as a matter of fit; scientific validity is not sufficient unless it fits the specific matter under consideration by the trial court. Within the context of family law, Kelly and Ramsey27 provide a masterful analysis of validity as it applies to psycholegal constructs and measures, along with a detailed list of specific benchmarks. For instance, interview-based competency measures are typically composed of several dozen relevant constructs that are operationally defined. Grisso emphasizes the contextual nature of a competency determination and the importance of understanding the demands of the defendants case, noting that an interaction between individual ability and situational demand, not an absolute level of ability, is of special significance for competence decisions (pp. The ECST-R is composed of both competency and feigning scales. The issue reached the U.S. Supreme Court in the case of Sell v. United States (2003). The legal principle is usually referred to as competence to stand trial, although terms such as fitness to stand trial, adjudicative competence, and competence to proceed are also used (Bonnie, 1992; Golding, 2016). Murrie and Zelle (2015) reviewed the literature and identified five essential capacities: (1) a factual understanding of the legal proceedings, (2) an appreciation of how the factual understanding can be applied to his or her case, (3) an ability to make reasonable and logical decisions, (4) an ability to assist and communicate with counsel, and (5) an ability to make decisions about issues such as whether to accept a plea agreement, proceed with trial, testify, and the many other decisions faced by defendants in criminal cases. Competence is also a consideration when a defendant chooses to represent him or herself (referred to as proceeding pro se). The article acknowledges the past polarization of forensic practitioners on acceptance versus rejection of competency measures. Mossman (2007) gives an example of a line of research that addresses this issue. Berman et al. For some, this resulted in confinement that lasted years and, for a few, a decade or more (Roesch & Golding, 1980), often spending more time in confinement than they would have been if convicted and sentenced on their original charges. WebCheckout the latest stats of Mitch McGary. Evaluators may use psychological tests on occasion when it is thought to be helpful in identifying clinical constructs such as intelligence, psychopathology, or academic achievement. Sell appealed and the appellate court held that medication was necessary because he was dangerous to himself or others and medication was likely to restore competence. Items are scored based on the ability of the individual to relate information about his or her case in an accurate and understandable manner. The CAST-MR also has a specific scale for considering the defendant's memory of the offense and subsequent arrest. Conservative estimates suggest there are 60,000 competency cases per year, with rates of incompetency often falling in the 20- to 30-percent range.32 When extrapolated from the number of actively psychotic and mentally disordered inmates,33 the potential number of competency evaluations could easily be twice this estimate. WebCompetency to Stand Trial Assessment Instructions I.
Noah And Saskia, Wayhaught Fanfiction Hickey, Metal Surge Protector Vs Plastic, Http Request Timeout Nodejs, How Many Of The Staple Singers Are Still Alive, Articles M