A BACKDROP FOR A SET OF TENSIONS

[Note:  This posting is a continuation of a report on the development of a civics unit of study.  This unit is directing students to formulate informed positions on a governmental topic, ground rules overseeing tort law.  It is being developed in real time.  Writer wants to identify the basic source of information, the Great Course’s course, Law School for Everyone.[1]]

This posting begins the substantive reporting on the development of a unit of study, suitable for a civics course or American government course.  That unit, at this point, features tort law.  In addition, the approach to this topic will be to address it as a national concern. 

As such, it would be situated toward the end of the course but treated as a unit that looks at one the three main branches of government, the judiciary.  Therefore, this unit can reasonably expect students to know the major goals and aims the course is trying to meet.

Among those goals and aims is to impart a mode of behavior responsible citizens can employ when considering a governmental/political issue or problem.  The elements of that mode include an appreciation of and the motivation to attain relevant historical knowledge concerning the issue/problem at hand, a disposition to engage in effective dialogue with other citizens to address the issue or problem, and a willingness to participate in citizenry action that is meant to relieve or solve the issue/problem.

Summarily, one can describe that mode as one that enhances and demonstrates the societal qualities of social capital and civic humanism – qualities that reflect federalist values.  Of specific concern regarding this unit is the federalist value of justice.  A federalist moral code identifies justice as one of that code’s key instrumental values; only superseded by the code’s trump value, societal welfare.

As the last posting stated, tort law involves court action dedicated to settle claims emanating from situations where one party causes harm to another party.  While that basic descriptor sounds simple, in real life, torts can easily become complex.  Relatively simple cases demonstrate how complex tort law can be.

Here is such a case.  A driver pulls up to a golf course’s parking lot.  The driver is driving an SUV and due to his/her heighten view, does see a beer can that was left on the parking space the driver chooses and he/she runs over the can.  Given how the tire hits the can (that is cut open with a sharp exposed edge), the can causes a slice on the bottom of the tire. 

The driver hears the contact, but does not see, upon inspection any damage.  Low and behold, a few hours later the tire is flat.  The charge to make the driver whole – acquiring a tire that is comparable to what he/she had before the contact – results in a bill of $200.  Who should pay for that bill?  The driver, the unidentified person who left the can, or the owners/managers of the golf course.  Here is a bit of more complication, the golf course is owned by the city government – in the name of the people of that municipality.

Most of the time, the simplest situations, can readily become complex.  And in that feature of tort law, most governing principles and practices are developed to handle the complexities that emerge.  While this unit cannot address all these complexities, there are a set of basic concepts that if known and appreciated, a student cannot only be introduced to those complexities, but be armed with the accompanying knowledge by which he/she can study this topic.

The more citizens know about tort law, the more they can choose life styles and acquire specific information that can, in turn, protect their legitimate interests.  But more in line with the aims advanced in this blog as to the purposes of civics courses (to encourage students to view citizenry as a partnership), the processes of the judicial system should be aimed at advancing justice.

So, some initial questions a study of tort law should address can be:  who has a duty in a given situation where harm occurs?  How does one define related legal principles in a given, harm-inducing situation?  And how do the evolving realities – such as in the economy and/or in technology – affect responsibilities parties might have in harm-inducing situations?

In the last posting, three tensions were introduced:  strict liability vs. negligence, malfeasance vs. nonfeasance, and factual causation vs. legal causation.  They are tensions that have been evolving since the mid-eighteen-hundreds.  Some argue the main force pushing this overall evolution has been caused by technological changes.  Others argue the economic/political forces have been at work.  These arguments provide the backdrop for a historical tale.

The next posting will begin describing the first of these tensions.  Whether the law should count on pure cause or count on notions of fault is a basic question.  Within the American legal tradition – that of common law – this concern has demanded a great deal of judicial attention.

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[1] Edward K. Cheng, “Torts,” Law School for Everyone – a transcript book (Chantilly, VA:  The Teaching Company/The Great Courses, 2017), 230-445.

AND NOW THERE IS TORT LAW

Now this blog proceeds to report on the development of one more unit of study.  To date this blog has reported on the development of two units, one on foreign trade and its effect on job availability (an international issue area) and the other on the opioid epidemic (treated as a local concern).  For the purposes identified in previous postings, it’s time to do – to report – a third. 

The designations assigned of the earlier units were done for the purposes of the blog, not due to their content.  That is, the two issues to date could have been treated at any of the identified levels of the polity:  local, national, or international.  The same can be said for the next unit.  Initially, the area of concern for this third unit is tort law.  It is being treated as a national topic. 

Notice, a specific issue or problem has not yet been determined and this fact highlights that the development of this next unit – as was the case with the other two – is being done in real time.  The developer has some ideas but has not committed to one of them yet.

Given a course of study outline, previously provided in this blog, the outline identifies a Unit 11, “The Courts.”[1]  Of the unit topics listed on the outline, The Courts seems like the obvious place to situate this topic.  Since what is anticipated, in terms of content, affects the courts equally throughout the nation, the national level seems most appropriate.

As with the other two units, an immediate challenge is to write a short history.  For this topic, though, this is more difficult than one would tend to think.  To start, one needs to settle on a conceptual level that is neither too broad nor too narrow.  After all, the history of American tort law can easily stretch to the middle ages in Europe.  But if one begins with a broader view – say approaching the topic through the discipline and history of jurisprudence – a responsible starting point would be the writings of Aristotle of ancient Greece. 

What is anticipated is that the history this development presents will limit its review to that of case law in the US.  This might or might not make references to the middle ages or maybe even the old Greeks.  That decision is yet to be made.  In this posting, therefore, the blog’s development of this next unit needs to conceptually start elsewhere. 

Therefore, a good place to start is to make a distinction between two approaches to tort law:  common law and civil law.  Tort has to do with damage being done on a party by another party.  A simple example is when one driver drives his/her car into another person’s car.  The damaged party, to seek relief from the harm, files suit against the alleged party that stands accused of causing the harm.[2] 

Usually, relief is in the form of a monetary award to the damaged party by the party found to be responsible.  But within the Western world, there are two approaches to this process.  The reasons for this distinction are basically historical.  England opted for a common law tradition and mostly stuck to it. 

Common law is based on case law; that is, what is considered binding depends on previous decisions – what previous courts, either justices or juries, have determined to be correct in a given area of dispute between litigants.  This brings into question the claim that judges should not make law.  In the common law tradition, judges, from time to time, do make law. 

Case law is the sum of all judicial decisions that prior cases have produced.  Case law is divided between criminal law and tort law (and tort law in the US is mostly based on common law). 

People who are charged with breaking a law – i.e., a statutory law – faces the provisions of criminal law.  Law in terms of criminality depends on enacted statutes – e.g., laws against fraud – not common law.  Within this category, when laws are dealing with private affairs (tort cases), that is known as civil law.  This is the system used in most Western nations such as France that does not have a common law tradition.  There are examples of civil law in the US regarding tort issues, but they are limited in areas of concern.

In the US, most tort law does not depend on statutes, it depends on common law.  Again, that would be depending on what prior, settled claims have established and has become part of case law.  The US has inherited this approach (except for Louisiana and its French traditions) from the British.  Most tort claims are settled using case law as opposed to statutes – that reflects this nation’s commitment to common law. 

Can legislatures and executives of the state and federal governments in the US bring areas of tort law under the provisions of statutes?  Yes, they can, but mostly have not done so.  Americans, by and large, feel comfortable with its common law tradition when it comes to tort law.

Admittedly, if one draws a Venn diagram that illustrates the boundaries among these various “laws” (case law, common, civil law, statutory law) it would be quite complex.  What is important for the purposes of this blog is that the US is a common law nation and that tradition calls on courts to settle tort cases according to prior decisions.

What is useful in this initial posting in addressing tort law, are to report some introductory observations leading to the development of a history of tort law.  For example, the first observation is that tort law, since it is based on case decisions, as opposed to statutes, is subject to slow change.  Courts, from time to time, just cannot completely abide with what has previously been decided, a precedent – it might not fit the facts of the case before it – and that court, usually an appeals court, changes the law. 

What experience shows is that while tort law does change, it does so slowly.  One of the most important functions law provides is predictability.  Change counteracts that benefit, so the reasons for change, when it happens, will be judged as necessary.

At times, new technological changes make a precedent non-applicable to a tort claim or the precedent would obviously lead to an unjust finding.  While judges are bound by common law, one does observe changes taking place.  But this process of change hints at a way to put together a history. 

That history can trace the development of three conceptual areas – strict liability vs. negligence, malfeasance vs. nonfeasance, and factual causation vs. legal causation – and how their development are points of historical focus.  And that history will rely on precedent or challenging precedent and the cases that illustrate these tensions. 

They also add to the story-telling quality in that that history tells the stories of affected parties.  One difference, though, case history is not time determined.  A resulting history will jump around in terms of time, at least as the information of those cases are found and shared or how the courts have dealt with these various countervailing conceptions.

One last point to be made in this initial posting.  The aim is not to train young lawyers or even to encourage secondary students to consider a legal profession.  Tort law is chosen for this blog because it points to an area of social interaction where federalist values are tested.  In a court of law, one is concerned primarily with one’s interests – not the general welfare – and one is wise to assume all the parties involved are looking at the experience the same way. 

What can one say?  Are federalist concerns simply not applicable?  That is what this treatment expects students to ask and, by so asking, the student can make another distinction.  When reviewing cases, one is tempted to get caught up in the fate of the actors involved.  The federalist quality is not in how the individuals behave or are treated in such adversarial circumstances, but on how the system seeks and secures justice, an important federalist value.

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[1] The course of study identifies the following units:  Unit 1:  The individual, Unit 2:  The family, Unit 3:  The neighborhood, Unit 4:  A small business, Unit 5:  A labor association (such as a union), Unit 6:  A large corporation, Unit 7:  A local government, Unit 8:  A law enforcement agency, Unit 9:  Congress, Unit 10:  The White House, Unit 11:  The courts, Unit 12:  Society, and Unit 13:  International associations.

[2] Tort law can also include the issuaence of injunctions that are issued to order a party to do or refrain from doing some action.

FROM LOCAL TO NATIONAL

[Note:  This posting completes this blog’s report on the development of a civics unit of study.  The unit is meant to direct students in their understanding of a local political/governmental issue.  The issue is the opioid epidemic.  Writer wants to express gratitude to Wikipedia for identifying the bulk of the research this blog has used in the development of this unit.[1]]

This posting will serve as a transition from reporting, in real time, the development of one unit of study to another.  As indicated above – and in a long string of previous postings – the unit being completed targeted the opioid epidemic.  That development took various steps in its progression.

The plan consisted of first choosing an issue area that affects a local area within the polity – the neighborhood.  Then the development determined where in the course it should be situated.  In terms of a local issue, progressing from the immediate and local toward the outer reaches of students’ civic interests, this unit is situated early in the course.

          For example, the assumed course places the “opioid” unit as probably the third unit.  To remind a recurring reader – one who follows this blog – it has been suggested that a civics course, one guided by federation theory, should have students study issues that help advance social capital and civic humanism.

          This is what this blog reported in a previous posting:

To implement this course, one needs to forget the prevailing textbooks[2] and the structure that these textbooks outline and [instead] develop a course entirely on social capital [and civic humanism] priorities.  To begin with, each element of a society, from the most basic to the most complicated, becomes a potential source of content.  From the individual – the most basic, but still complicated – to international arrangements such as the UN can be included.

A list of these elements and an accompanying “social capital” [and “civic humanist”] issues is included in the following:

•         The individual – short term interests vs. long term interests

•         The family – the effects of divorce

•         The neighborhood – responsibilities toward problem children

•         A small business – treatment of employees

•         A labor association (such as a union) – efficiency and quality issues vs. worker interests

•         A large corporation – product safety

•         A local government (either city or county) – zoning or racial/ethnic divisions

•         Law enforcement agency – judicial rights applicable to an accused

•         White House – leadership that advances social capital

•         Congress – the extent that money (donations) is influential

•         The courts – the role of interpreting constitutional principles as expressions of social capital

•         Society during wartime – special demands on citizenship

•         International associations – levels of interdependence between nations

Such a course of study would be comprised of thirteen units to be covered in an eighteen-week semester at the high school level.  Middle school civics courses last the entire academic year, so the list can be longer, or each item can demand more time (or a combination of the two).[3]

A third unit would correspond to the “neighborhood” unit in the above listing.  Of course, an “opioid” concern replaces the above identified issue, “responsibilities toward problem children.”

          On another matter, in a previous posting, this blog promised that the listing of all factoids and insights, previously identified in prior postings, would be collected in one extra, posting site.  The resulting list takes up eighteen pages, so the posting option on this blog seems undoable.  So instead, the listing appears in a PDF type posting. 

Interested readers can click to the online site identified in the footnote below.[4]  That collection of factoids and insights were made up of researched information and the sources of that information is identified by accompanying footnotes.  Interested parties that wish to access those sources can merely click on those sites.

Those bits of information are arranged according to an aspect of the opioid crisis.  Those aspects are:  updating information of the epidemic history, effects on the individual, counter measures, production and distribution, demographics, and governmental reactions.  So, for example, factoids regarding heroin appear as follows:

Factoids relating to current updating of historical account:

Concerning heroin –

* Of those who misuse prescribed opioids, 4 to 6 percent “graduate” to heroin and 80 percent of those, who use heroin, previously misused prescription opioids.

* Men are significantly more likely to use heroin;

* Between 2012 and 2015, deaths due to heroin-use were more numerous than deaths due to other opioids even though among women, deaths were higher due to opioid medications;

* The last decade or so has seen significant increases in heroin use. Those numbers include an increase from an estimated 374,000 Americans using heroin in the years 2002-2005 to 607,000 in the years 2009-2011.4 By 2014, as a reflection of a leveling-off progression, the number was estimated to still be over half a million.

In turn, each of these entries are properly footnoted and their sources identified.

With that effort completed, it is time to move on.  This blog will develop another unit of study.  This will be a third unit so developed.  The first one covered the issue of foreign trade and how that trade has affected the availability of jobs here in the US.  This blog developed that unit as one that would appear at the end of a course of study.  The “trade” issue would replace (or develop further) the “levels of interdependence between nations” in the identified course of study above.

What is visualized here is that a unit on jurisprudence can be a third developed unit and can be situated with a “national” context – “the courts.”  More specifically, the federalist target will be three sets of jurisprudential concepts:  strict liability vs. negligence, malfeasance vs. non feasance, reasonable standard vs. causation.  All three are central concepts in the practice of tort law.  Again, this will be the organizing aim for a long string of postings to come.

As with the other two units, this newer plan will be to identify a history (aligning this effort with the “historical dialogue-to-action” strategy), to cull out those aspects that define the current social/political condition that affect citizens in this area of interest, and develop lesson-scenarios that address, individually, each identified aspect.  And it will be done, as with the other two, in real time. 

That means, the reader should not be surprised if its development backtracks at times.  It also points out that this development should not be equated to what a typical teacher can do.  He/she does not have the luxury of spending weeks to develop the units that comprise his/her courses.  That is especially true if the textbook takes a backseat – as suggested here – in defining what is to be taught.

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[1] The writer also wants to state that where possible, he has checked the sources and has at times added to the listed research.

[2] The prevailing textbooks can be maintained, but as reference books that contain much, if not all, of the structural information a student would use in carrying out inquiries this course of study would have students perform.

[3] The previous posting is entitled “Social Capital as a Fundamental Commitment,” February 10, 2017.

[4] The site for the PDF type document is https://onedrive.live.com/view.aspx?resid=CED163627385DD3C!11635&ithint=file%2cdocx&app=Word&authkey=!AFhwqIF3ZhONVK8 .

THREE REMAINING ASPECTS

[Note:  This posting is a continuation of a report on the development of a civics unit of study.  This unit is directing students to formulate informed positions on the opioid epidemic.  It is being developed in real time.  Writer wants to express gratitude to Wikipedia for identifying the bulk of the research this blog has used in the development of this unit.[1]]

The development of this unit of study has already determined that it should last five periods (assuming each period consists of fifty to sixty minutes).  To this point, the development has accounted for three periods, leaving two.  One of those remaining periods is already dedicated to administering the unit’s overall evaluation.  The challenge is to provide instruction for three more aspects of the problem area:  production and distribution, demographics, and governmental reactions.

          This posting, in the main, provides a lesson plan to meet that challenge.  But first, it shares an insight of which the writer has become aware.  On TV, MSNBC reports the following relationship:  the opioid crisis, where it has been experienced to heightened levels, has correlated with children’s lower probability of attaining higher education opportunities.[2] 

Whether consumption of opioids is by young people or by young people’s parents or care givers is not made clear.  The TV feature highlights a case where a low-income mother is the consumer while her son is attempting to start a program to meet the needs of young people who find themselves in this type of family situation and are trying to advance their education.

For purposes here, an association can be made:  children, who come from households where opioid use is a problem, experience significantly lesser levels of success in attaining higher educations.  Cause and effect?  Hard to say, but intuitively, one can imagine, an addiction problem deters one from attaining a good education and that goes for the effect other household members might have on the young person in question.

But now back to the main purpose here.  To cover the last three aspects, it is suggested that the class be divided into three equally (or as close to equally) populated groups.  Each group is assigned one of the remaining aspects.  The teacher can distribute a reading in which an entire listing of all factoids and insights is included.[3]  The teacher requests that each student look at that portion of the handout that refers to the aspect he/she has been assigned.

This fourth-class period of the unit can be dedicated to having students work on their assigned aspect by researching the literature.  They are to go online, assuming they have access, and look at the sites their listing identifies – in the form of footnotes – and see what information those sources supply in relation to informing their unit assignment regarding local counter measure facilities – the assignment given to them earlier in the unit.

The teacher instructs the students to look at the information available and see how it affects their research over local opioid fighting resources.  They are also going to be given, in the next class period, an opportunity to express any opinions they wish to express in a limited opportunity.  Each group is going to have, in total, ten minutes to express those opinions.  They should also be able to support their opinions with evidence they glean from the information sources they have.

Teacher allows students to conduct their initial research with the information given them.[4]  They should be encouraged to access, through the identified footnotes, the sources from which the factoids and insights have been derived.  As students conduct their research, the teacher can roam the classroom and assist students – he/she can answer any questions students might have as to the meaning or significance the information reveals.

Students continue their research at home with knowing that the next day, beyond their “opinion session,” they will begin writing their reports on local, counter measure resources.  They also know that they will be allowed to use any notes or computer assistance they can bring to bear.  They will have roughly twenty minutes to write their one sheet report – no more, no less than the one sheet.

Teachers, for this last class period, might work out an extra credit arrangement for the “opinion session” and consider giving students extra time to finish their report.  The teacher can collect students’ products at the beginning of the next class period.  However, the teacher handles this assignment, the suggestion here is for the reports to be considered comparable to a unit test.

What remains for this posting to report is the sampling of examples of factoids and insights for the remaining aspects.  Below is that sampling divided according to each aspect.  Since there are three remaining aspects, each aspect will be described here by sharing one factoid and one insight each.

·        Related production and distribution factoid – the Drug Enforcement Administration reports that an interested party can purchase one kilogram of fentanyl for $3,000 to $5,000 in China and smuggling it into the US can be accomplished by merely mailing it there.  That smuggled kilogram can mean a million and half dollars in sales.[5] 

·        Related production and distribution insights – Florida has made a concerted effort at distribution systems.  In the year 2015, the authorities there closed 250 pill mills.[6] The state has altered its regulations to prohibit clinics from issuing opioid prescriptions and this, in turn, has notably lowered the dispensing of prescription opiates.[7] Florida’s efforts have garnered it some attention.

·        Related demographic factoid – American incidence of overdosing mostly affects whites, Native Americans, and working-class residents.[8]  For example, Native Americans have witnessed a 500% upsurge in opioid induced overdose fatalities between the years 1999 and 2015 – this reflects the highest increase of any identifiable demographic group.[9]

·        Related demographic insight – researchers hypothesize that the reason doctors from various states prescribe opioids at different rates of frequency is due to a lack of agreement among medical professionals as to the appropriate amounts of medication patients need.[10]  This writer would add that there does not seem to be evidence that this variance is contingent on geographic location.

·        Related governmental reactions factoid – governors of 45 states and 3 territorial governors organized themselves, in July 2016, to draw up an agreement, “Compact to Fight Opioid Addiction.”  The compact calls on the governors to coordinate their actions to help end the crisis.  This includes policies to address both governmental and private activities and protocols.  Special attention should be given to how the compact focuses on opioid producers and doctors.[11]

·        Related state government reaction insight – state governments have been moved to act, including the legislating of laws, by the numbers of overdoses, deaths, and costs their citizens have suffered because of the increased prescribing and consuming of opioid drugs.  Illustrative example is that of Arizona that suffered in the Phoenix area 3,114 overdoses from mid-June 2017 to the end of January 2018.  That situation led to the enactment of the Arizona Opioid Epidemic Act.[12]

·        As for national policy the following factoid is offered – the journalist, George Lopez, summarizes the Trump’s Administration’s policy to meet the opioid crisis with the following:

In 2017, the President said:  “I made a promise to the American people to take action to keep drugs from pouring into our country and to help those who have been so badly affected by them.”  The Administration has taken a number of significant actions to address the crisis.  The President created the Commission on Combating Drug Addiction and the Opioid Crisis and the Administration declared the opioid epidemic a nationwide public health emergency.  The Administration provided nearly $500 million in new resources to States to prevent and treat opioid abuse and addiction in 2017, in addition to last year’s Budget that requested another $500 million.

At first read, this might sound impressive.  Trump not only created a commission to address the crisis head-on, but reportedly added $1 billion in funding to combat the epidemic.

But this paragraph is extremely misleading.  Trump’s commission?  The administration has only implemented less than a handful of its dozens of proposals.  The extra $1 billion?  That money actually comes from the 21^st Century Cures Act – signed into law not by Trump but by President Barack Obama in 2016.[13]

Hopefully, from this sample, the reader can get a sense of the type of information the entire list of factoids and insights provides. 

That completes this posting’s suggestions on how to conduct a unit of study dedicated to having students form informed positions on the opioid crisis.  If successful, the student will be well-positioned to take an active role in his/her community to address its battle with this epidemic.

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[1] The writer also wants to state that where possible, he has checked the sources and has at times added to the listed research.

[2] Kate Snow, “One Nation Overdosed,” MSNBC Live – TV broadcast, 10:45 EDT, September 3, 2018.

[3] As has been pointed out previous postings, soon, this blog will post a special posting with a listing of all the factoids and insights this blog has identified as relating to the opioid crisis.

[4] The information can be distributed in the form of a handout or the students, if they have access to computers or smart phones, go online to access the site containing the lists of factoids and insights.

[5] “Addressing America’s Fentanyl Crisis,” National Institute on Drug Abuse/Advancing Addiction Science, April 6, 2017, accessed on July 4, 2018, https://www.drugabuse.gov/about-nida/noras-blog/2017/04/addressing-americas-fentanyl-crisis .

[6] “America’s Pill Mills:  A Look into the Prescription Opioid Problem,” DrugAbuse.Com, n.d., accessed July 8, 2018, https://drugabuse.com/featured/americas-pill-mills/ .

[7] “More ‘Pill Mill’ Doctors Prosecuted Amid Opioid Epidemic,” Healthline, May 19, 2016, accessed July 8, 2018, https://www.healthline.com/health-news/pill-mill-doctors-prosecuted-amid-opioid-epidemic#1 .

[8] Dan Nolan and Chris Amico, “How Bad Is the Opioid Epidemic?” Frontline, February  23, 2016, accessed July 12, 2018, https://www.pbs.org/wgbh/frontline/article/how-bad-is-the-opioid-epidemic/ .

[9] “Native American Overdose Deaths Surge Since Opioid Epidemic,” R and D, March 15, 2018, accessed August 2, 2018, https://www.rdmag.com/news/2018/03/native-american-overdose-deaths-surge-opioid-epidemic .

[10] Dan Nolan and Chris Amico, Frontline, February 23, 2016, accessed June 15, 2018, https://www.pbs.org/wgbh/frontline/article/how-bad-is-the-opioid-epidemic/ .

[11] “A Compact to Fight Opioid Addiction,” National Governors Association, July 13, 2016, cite no longer on-line AND Gale Pryor, “6 Ways States Are Fighting the Opioid Epidemic,” Athenainsight, May 19, 2017, accessed August 6, 2018, https://www.athenahealth.com/insight/6-ways-states-are-fighting-opioid-epidemic .

[12] Joan Magtibay, “Ducey Signs Sweeping Law to Confront Arizona Opioid Crisis,” Cronkite News, January 26,2018, accessed August 7, 2018, https://cronkitenews.azpbs.org/2018/01/26/ducey-signs-sweeping-plan-confront-arizona-opioid-crisis-law/ .

[13] George Lopez, “Trump’s Budget Could Help Fight the Opioid Crisis – If It Didn’t Try to Repeal Obamacare:  One Big Step Forward, One Bigger Step Back,” Vox, February 13, 2018, accessed August 25, 2018, https://www.vox.com/policy-and-politics/2018/2/13/17004656/trump-budget-opioid-epidemic .