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I thought I'd post this text here for a "GM Data Link Communications 101" as we get questions from time to time on how the vehicle computer systems work and inter-relate. This is a GENERIC article on the subject written at an appx. high school auto shop class level, some items in this missive may not be germane to the Caprice but to other GM vehicles.
Note: This is an overview of different serial data buses used by GM devices to communicate with each others. Use Data Communication Schematics and/or the appropriate GM/Helm manual to find out which serial data buses are configured for a specific vehicle.
There are many components in a vehicle that rely on information from other sources, transmit information to other sources, or both. Serial data communication networks provide a reliable, cost effective, way for various components of the vehicle to “talk” to one another and share information.
GM uses a number of different communication buses to insure the timely and efficient exchange of information between devices. When compared to each other, some of these buses are different in nature as far as speed, signal characteristics, and behavior. An example of this is the High Speed GMLAN and Low Speed GMLAN buses.
On the other hand, when other buses are compared to each other they have similar characteristics and simply operate in parallel. In this case they are used to group together components which have high interaction. Examples are the High Speed GMLAN, Powertrain Expansion, and Chassis Expansion buses. This allows them to communicate with each other on a bus with reduced message congestion insuring faster and the more timely exchange of information than if all vehicle devices were on a single bus.
The majority of information that exists within a given network generally stays local; however some information will have to be shared on other networks. Control modules designated as Gateway’s perform the function of transferring information between the various buses. A Gateway module is connected to at least 2 buses and will interact with each network according to its message strategy and transmission models.
GMLAN provides the capability for a receiving device to monitor message transmissions from other devices in order to determine if messages of interest are not being received. The primary purpose is to allow reasonable default values to be substituted for the information no longer being received. Additionally, a device may set a Diagnostic Trouble Code to indicate that the device it is expecting information from is no longer communicating.
A High Speed GMLAN Bus is used where data needs to be exchanged at a high enough rate to minimize the delay between the occurrence of a change in sensor value and the reception of this information by a control device using the information to adjust vehicle system performance.
The High Speed GMLAN serial data network consists of two twisted wires. One signal circuit is identified as GMLAN-High and the other signal circuit is identified as GMLAN-Low. At each end of the data bus there is a 120 Ω termination resistor between the GMLAN-High and GMLAN-Low circuits.
Data symbols (1’s and 0’s) are transmitted sequentially at a rate of 500 Kbit/s. The data to be transmitted over the bus is represented by the voltage difference between the GMLAN-High signal voltage and the GMLAN-Low signal voltage.
When the two wire bus is at rest the GMLAN-High and GMLAN-Low signal circuits are not being driven and this represents a logic “1”. In this state both signal circuits are at the same voltage of 2.5 V. The differential voltage is approximately 0 V.
When a logic “0” is to be transmitted, the GMLAN-High signal circuit is driven higher to about 3.5 V and the GMLAN-Low circuit is driven lower to about 1.5 V. The differential voltage becomes approximately 2.0 (+/- 0.5) V.
The GMLAN Chassis Expansion Bus is basically a copy of the High Speed GMLAN Bus except that its use is reserved for chassis components. This implementation splits message congestion between two parallel buses helping to insure timely message transmission and reception. Sometimes communication is required between the Chassis Expansion Bus and the primary High Speed GMLAN Bus. This is accomplished by using the K17 Electronic Brake Control Module (EBCM) as the Gateway module. Since the High Speed GMLAN Chassis Expansion Bus and primary High Speed GMLAN Bus operate in the same manner, the diagnostics for each are similar.
The GMLAN Object Bus is basically a copy of the High Speed GMLAN Bus except that its use is reserved for the enhanced safety system. This implementation is used to isolate the heavy communication among the enhanced safety system devices from the other vehicle buses, reducing congestion. The K124 Active Safety Control Module is connected to the Object Bus as well as the Primary High Speed GMLAN Bus, the Chassis Expansion Bus, and the Low Speed GMLAN Bus. The K124 Active Safety Control Module acts as a Gateway module for all required communication between the Object Bus devices and devices on these other vehicle buses.
The GMLAN Object Bus operates in the same manner as the Chassis Expansion and Primary High Speed buses and so the diagnostics are similar. The Object Bus is physically partitioned into a Front Object Bus and a Rear Object Bus with each partition having its own communication enable circuit to activate the partition, but functional operation of both is identical.
The Front Object Bus standard devices are the K124 Active Safety Control Module, the K109 Frontview Camera Module, and the B233B Radar Sensor Module – Long Range. The Front Object Bus optional devices are the B233LF Radar Sensor Module – Short Range Left Front and the B233RF Radar Sensor Module – Short Range Right Front. The Rear Object Bus is optional and when present will have the K124 Active Safety Control Module and B233R Radar Sensor Module – Short Range Rear on the bus, and optionally the Radar Sensor Module – Short Range Right Rear. All Object Bus components are powered by the K124 Active Safety Control Module via the communication enable circuits, except the K109 Frontview Camera Module which is powered directly by battery.
The MOST Infotainment network is a dedicated high speed multimedia streaming data bus independent from GMLAN. The MOST bus will be configured in a physical hardwired loop with each device within the bus sends and receives data on an assigned MOST addresses in a set order. Each device on the MOST bus will be required to have twisted pair copper wires (2 transmit TX, 2 receive RX, and 1 electronic control line which is a 12 V wakeup signal line). The A11 Radio is the MOST Master and will monitor the bus for vehicle configuration, Infotainment data messages and errors on the bus. The MOST initialization consists of a short 100 ms low voltage pulse on the electronic control line (or MOST control line) connected to all devices contained on the MOST ring. This wakeup message once received by each device, will first respond with a generic device response. Once these initial responses on the MOST bus are reported successfully without error to the A11 Radio, the second data request will record the MOST device addresses, their functionality requirements and capabilities within. The A11 Radio will learn this information and also record the address node sequence on the MOST bus at this point. This node address list will now be stored within the A11 Radio as the MOST bus configuration (called “Last Working MOST ID of Node 1 – 9” on scan tool data display).
When MOST receive, transmit, or control line faults are detected, transmit/receive messages will not received as expected from the wakeup request. The A11 Radio and the K74 Human Machine Interface Control Module will then perform diagnostics to isolate these MOST faults. If the MOST control line is shorted low to 0 V for excess amount of time, the A11 Radio will set a U2098 DTC and K74 Human Machine Interface Control Module will set a U0029 02 DTC. At this point the MOST bus will be unable to communicate until the shorted MOST control line is repaired.
Once the shorted MOST control line diagnostics pass, the A11 Radio will attempt to resend the initial short pulse attempts up to 3 times on the MOST control line. If the expected responses are not received, the A11 Radio continues into a failure mode setting a U0028 DTC and will continue on to send one 300 ms long pulse, which will enable the furthest upstream transmitting device to become the surrogate MOST Master in this MOST fault/diagnostic mode. When the A11 Radio receives this new MOST Master identity, the surrogate MOST master device can be identified based on scan tool data parameter “Surrogate MOST Master Node Upstream Position”. The scan tool should be used to determine the MOST bus configuration and direction by utilizing the “Last Working MOST ID of Node 1 – 9” parameters from the A11 Radio data display. When a fault is present, it will indicate the newly enabled “Surrogate MOST Master Node Upstream Position” from the A11 Radio. This will assist in determining where the MOST bus/control is at fault. The MOST device upstream from the surrogate MOST master device, transmit, receive, or control lines will be the suspect areas for diagnostics at this point. These faults can be associated with any of the MOST transmit, receive, or control line twisted copper wires or possibly an internal device fault.
The K74 Human Machine Interface Control Module will set a U0029 00 DTC when it diagnoses a MOST bus not communicating properly after one attempt. When the DTC U0029 00 is set by the K74 Human Machine Interface Control Module without the corresponding DTC U0028 from the A11 Radio, it will be an indication of an intermittent wiring/device condition.
This bus is used by the Entertainment sub-system to transfer high-rate display graphics between the A11 Radio and the P17 Info Display Module and/or Radio/HVAC Control. The electrical characteristics of the CAN Graphical Interface (CGI) Bus are very similar to the High Speed GMLAN Bus. The message strategy and construction of messages are different however. Sometimes communication is required between the CAN Graphical Interface Bus and the Low Speed GMLAN Bus. This is accomplished by using the A11 Radio as the Gateway module. Since the CAN Graphical Interface Bus and primary High Speed GMLAN Bus have similar electrical characteristics, the diagnostics for each are similar.
In the case where the P17 Info Display Module and Radio/HVAC Control are separate devices the P17 Info Display Module is responsible for passing information between the A11 Radio and the Radio/HVAC Control. The A11 Radio interfaces only with the P17 Info Display Module and the P17 Info Display Module then communicates with the Radio/HVAC Control through a Local Interconnect Network (LIN) interface.
A bus wake up signal will be generated by the A11 Radio or by the P17 Info Display Module when the system functionality is required. The communication function of the CAN Graphical Interface shall be enabled or disabled based on the voltage level of the Center Stack Wake. The network will stay awake as long as the circuit voltage is driven low, to less than 1.5 V. Communications are disabled with a high circuit voltage around 5.0 V.
The A11 Radio can execute a warm reset of the P17 Info Display Module if the P17 Info Display Module fails to respond to the A11 Radio’s request. The Center Stack Reset is a low-asserted pull down output (less than 1.5 V) from the A11 Radio to the P17 Info Display Module and has the same electrical characteristics as those for the Center Stack Wake signal defined above.
The Mid Speed GMLAN Bus is very similar to the High Speed GMLAN Bus except that it uses a slower transmission rate of 125 Kbit/s. This bus is intended for use where the system response time demands that a large amount of data be transmitted in a relatively short amount of time, such as updating a graphics display. As such it has usually been used for infotainment applications. Sometimes communication is required between the Low Speed GMLAN Bus and the Mid Speed GMLAN Bus. This is accomplished by using the A11 Radio as the Gateway module. Since the Mid Speed GMLAN Bus and primary High Speed GMLAN Bus operate in a similar manner, the diagnostics for each are similar.
Low Speed GMLAN Bus is used in applications where a high data rate is not required which allows for the use of less complex components. It is typically used for operator controlled functions where the response time requirements are slower than those required for dynamic vehicle control. The Low Speed GMLAN Serial Data Network consists of a single wire, ground referenced bus with high side voltage drive. During on road vehicle operation data symbols (1’s and 0’s) are transmitted sequentially at the normal rate of 33.3 Kbit/s. For component programming only, a special high speed data mode of 83.3 Kbit/s may be used. Unlike the high speed dual wire networks, the single wire low speed network does not use terminating resistors at either end of the network. The data symbols to be transmitted over the bus are represented by different voltage signals on the bus. When the Low Speed GMLAN Bus is at rest and is not being driven, there is a low signal voltage of approximately 0.2 V. This represents a logic “1”. When a logic “0” is to be transmitted, the signal voltage is driven higher to around 4.0 V or higher.
The Local Interconnect Network (LIN) Bus consists of a single wire with a transmission rate of 10.417 Kbit/s. This bus is used to exchange information between a master control module and other smart devices which provide supporting functionality. This type of configuration does not require the capacity or speed of either a High Speed GMLAN Bus or Low Speed GMLAN Bus and is thus relatively simpler. The data symbols (1’s and 0’s) to be transmitted are represented by different voltage levels on the communication bus. When the LIN Bus is at rest and is not being driven, the signal is in a high voltage state of approximately Vbatt. This represents a logic “1”. When a logic “0” is to be transmitted, the signal voltage is driven low to about ground (0.0 V).
Devices on High Speed GMLAN Bus enable or disable communication based on the voltage level of the communication enable circuit. When the circuit voltage is high (around 12 V), communications are enabled. When the circuit is low, communications are disabled.
The scan tool communicates over the various buses on the vehicle. When a scan tool is installed on a vehicle, the scan tool will try to communicate with every device that could be optioned into the vehicle. If an option is not installed on the vehicle, the scan tool will display No Comm (or Not Connected) for that optional device. In order to avert misdiagnoses of No Communication with a specific device, refer to Data Link References for a list of devices, the buses they communicate with, and the RPO codes for a specific device.

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There are hundreds of state and federal whistleblower laws covering a myriad of industries. In order to determine whether or not you should blow the whistle, it's critical to know in advance which laws apply to your specific complaint and industry. The law that you sue under will effect the amount of money you can recover, whether your case will be heard by a judge, jury, or administrative agency, and whether the complains you are contemplating are even protected speech.
Section 23 of the Commodities Exchange Act, which covers transactions involving oil, gas, foreign currency, and agriculture.
Sorting out which of these laws, and other laws, apply to your case is confusing for the layperson. Further, it's difficult for a non-attorney to determine whether or not complaints about the conduct at issue are protected speech and covered by the anti-retaliation laws.
A perfect example of a "counter-intuitive" decision by a court holding that speech was not protected is Garcetti v. Ceballos. In Ceballos, an employee of the Los Angeles District Attorney's Office noticed that police officers and other city employees were systematically submitting false and misleading affidavits to judges in an effort to secure warrants. The employee complained to his supervisors about the fraud. In retaliation, the managers transferred the employee to another department, and then rejected the employee's application for promotion.
Following several appeals, the case was taken by the U.S. Supreme Court. By a majority of 5-4 the court, led by the conservative justices, held that the employee was not entitled to protection because the employee's job description included some responsibilities requiring him to review and analyze affidavits. The court thus carved out an "official duties" exception to the First Amendment protections against retaliation, holding that an employee who makes a complaint which is related to his/her "official duties" is not protected against retaliation by his/her supervisors for making the complaint. The judges who supported this ridiculous decision were, not surprisingly, Alito, Scalia, Roberts and Thomas. However, somewhat surprisingly, Justice Kennedy joined in this decision and wrote the opinion for the majority.
In his dissent, Justice Stevens pointed out the absurdities of tethering First Amendment protections to the contents of an employees job description. The Ceballos decision shows just how unpredictable the whistleblower protections are. It's critical to determine early on what your rights are and which law applies to your situation.
In California, whistleblowers are protected by specific statutes that prohibit retaliation against employees for reporting illegal conduct to their employer or to an outside agency. The statute also protects employees who refuse to participate in illegal activities.
The primary purpose of these laws is to encourage employees who witness illegal or fraudulent activity to report the illegal conduct so that it stops. The laws are designed to make the employees feel more comfortable that their employers will not engage in retaliatory conduct in reprisal for them making the complaints. If the employer does retaliate, the employee has the right to proceed with a lawsuit, making retaliation something that the employer will suffer for.
Some of the statutes that protect whistleblowers from retaliation are called "qui tam" statutes. The whistleblower statutes originate back to the Dark and Middle ages, when kings and landowners lacked sufficient resources to properly monitor the activities of their subjects. In the 13th century, the English crown encouraged its subjects to come forward with reports of crimes through a process called "qui tam pro domino rege quam pro seipso"---which roughly translated "one who acts as much for the king as for himself." In qui tam actions, private citizens bring lawsuits against another private party who has allegedly defrauded the state. By so doing, the private party stands to benefit not only the King, but also him/herself.
The California False Claims Act: Government Code Section 12650, et seq. (protects employees who complain billing fraud and other fraudulent activities towards the State or other governmental bodies). This law is also referred to as California's Qui Tam statute. It provides for treble damages. Essentially, the False Claims Act ("FCA") is designed to prevent private contractors from submitting false or fraudulent invoices, or engaging in other activities, to secure overpayment from the government for good or services. Actions under the FCA are filed under seal, with notice provided to the State or political subdivision. The State then has a period of time during which it may investigate the claims.
Pursuant to Government Code section 12652(c)(6), the state or political subdivision whose funds are concerned may, after investigating a claim brought by a private citizen, elect or decline to intervene in the case. In cases where the State intervenes, "the action shall be conducted by the Attorney General and the seal shall be lifted." Gov. Code § 12652(c)(6)(A). In cases where state declines to intervene, "the seal shall be lifted and the qui tam plaintiff shall have the right to conduct the action." Gov. Code § 12652(c)(6)(B).
Gov. Code § 12652(e)(1) governs how an action where the state has intervened is managed. It provides that "If the state or political subdivision proceeds with the action, it shall have the primary responsibility for prosecuting the action." The statute also determines the rights of qui tam plaintiffs in cases where intervention has occurred. "The qui tam plaintiff shall have the right to continue as a full party to the action." Id. The state also has the right to dismiss or settle claims, even where the qui tam plaintiff has objected. See Gov. Code §§ 12652(e)(2)(A), (B).
The California Whistleblower Protection Act. Government Code Section 8547.1, et seq. (Allows state employees to report waste, fraud, violations of law, or health or safety threats, and to be free from retaliation for doing so). The State Legislature enacted the California Whistleblower Protection Act based on its finding that state employees should be free to report waste, fraud, abuse of authority, violation of law, or threat to public health without fear of retribution. The Legislature further found and declares that public servants best serve the citizenry when they can be candid and honest without reservation in conducting the people's business. Allegations of violations of the whistleblower statutes by state personnel will be investigated by the State Personnel Board pursuant to Government Code Section 19683.
California Labor Code Section 1102.5 is the most commonly applicable retaliation/whistleblower statute. Under Labor Code Section 1102.5, employers are prohibited from retaliating against an employee for reporting information, conduct, behavior, or other activities that the employee reasonably believes may violate a local, state, or federal law, rule, or regulation. Also, pursuant to the statute, it is illegal for employers to punish an employee for refusing to participate in an activity that would result in a violation of a local, state, or federal rule or law. The requirements of a claim for violations of Labor Code Section 1102.5 are that the Plaintiff employee must prove, by a preponderance of evidence, (1) that he or she engaged in protected activity, (2) that he/she has suffered an adverse employment action (such as a demotion, negative performance evaluation, decrease in pay, benefits, or termination); and (3) that there is a causal connection between the protected activity and the adverse employment action. Where an employee brings a retaliation case under Labor Code Section 1102.5, he/she may rely on circumstantial evidence (by proving a close temporal proximity in the timing of the complaint in relationship; to the adverse employment action), or by direct evidence, such as an e-mail from a supervisor complaining about the employees reporting of illegal activities.
Health and Safety Code Section 1278, et seq. protects employees of health care facilities from retaliation for reporting matter affecting patient safety. Health and Safety Code 1278.5(b)(1)(A) states that no health care facility shall discriminate or retaliate against any person who has "presented a grievance, complaint or report to the facility."
In Fahlen v. Sutter Central Valley Hospitals (2012) 208 Cal. App. 4th 557, the California Court of Appeal interpreted and applied Health and Safety Code Section 1278. Dr. Mark Fahlen was a physician practicing at defendant's health care facility. While he was making his rounds one day, he had a heated argument with some of the nurses working under his supervision. He claimed that the nurses failed to follow his direction. He later leveled accusations to management that the nurses had been insubordinate and provided substandard medical services to patients.
The hospital then terminated Fahlen's contract. It appointed an investigative committee to review the decision and then to submit it finds to the hospital's executive committee. After conducting an investigation, the committee recommended that Fahlen's contract not be continued. Fahlen contested the decision. The hospital's judicial peer review committee subsequently then reversed the decision not to reappoint Fahlen. However, the hospital's board of trustees later reversed the judicial review committee and Fahlen was terminated.
Fahlen chose not to seek judicial review of this decision. Rather, he decided to file a complaint in civil court against the hospital in California. He alleged many causes of action. One of the causes of action he alleged was retaliation in violation of the whistleblower statute, Health and Safety Code 1278.5. In response, the hospital filed a "demurrer" to the complaint, which is a legal pleading designed to challenge the sufficiency of the allegations of the complaint. The hospital also filed "anti-SLAPP motion" under Code of Civil Procedure § 425.16.
A party may file a SLAPP case where they have been prevented from exercising their free speak rights. An anti-SLAPP lawsuit is a case alleging that the case filed by the Plaintiff was designed to prevent the filing party from exercising her/her/its free speech rights. The hospital alleged that Fahlen has failed to exhaust its internal grievance procedures because he didn't seek judicial review of the board of trustee's decision. The hospital made the contention that the hospital peer review proceedings were official proceedings authorized by law. Therefore, according to the arguments advanced by the Hospital, the decision not to renew the doctor's contract was shielded from challenge and they could not be sued over it.
The Court rejected the Hospital's arguments. It concluded that the Health and Safety Code prevents retaliation against anyone who makes a complaint or grievance with respect to patient safety. It held that the anti-SLAPP provisions would apply to actions for defamation and abuse of process. The Court denied the anti-SLAPP motion as to the retaliation cause of action based on its findings that Fahlen had showed he could prevail on the merits of the underlying case.
The Court held that the doctrine of administrative exhaustion was important one and that, in certain instances, it might preclude an individual from pursuing a lawsuit in court without seeking review of decision by an internal committee. However the court held that retaliation was likely to have occurred in Fahlen's case based on the record before it. Therefore, the peer-review process may have been a quasi-judicial proceeding could be retaliatory action itself. The Court held that a reversal of o decision by the peer review committee could only occur when the underlying decision was "arbitrary and capricious," a requirement that a party judicially challenge such decisions would narrow an individual's right to redress under the statute if required to exhaust the administrative remedy.
The Court described in detail in its decision that it was worried about construing Health and Safety Code Section 1278 in a way that would make it more difficult for a potential whistleblower to request relief under the law. The Court described in detail its fears that a different decision would result in delays caused by a requirement that the party seek judicial review of the final administrative decision when the alleged adverse decision was based on whistleblowing.
As a result of Fahlen, a doctor or health care worker may not need to exhaust all internal review and grievance processes in order to bring a complaint for retaliation. The court held that retaliation for trying to improve the hospital's quality of car violated fundamental public policies of the State of California.


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Home/Evidence of doping, Science in anti-doping/The Lallukka CAS Award: The End of an Unsettled Era for Human Growth Hormone Cases?
In September 2011, the Finnish cross-country skier Juha Lallukka (the “skier”), a National-Level Athlete affiliated with the Finnish Ski Association, was subjected to an Out-of-Competition test. The analysis returned an Adverse Analytical Finding for recombinant human Growth Hormone (“rhGH”, a synthetic form of exogenously administered hGH). Exogenous human Growth Hormone is a non-Specified Substance included in class S2 of the World Anti-Doping Agency’s (“WADA”) Prohibited List. The WADA-accredited laboratory in Helsinki used the Isoform Differential Immunoassays test and reported the Sample positive based on the fact that the ratios between the various relevant isoforms detected in the Athlete’s Sample exceeded the decision limits as set in the relevant WADA Guidelines, i.e. the ratio values above which anti-doping laboratories are to report an Adverse Analytical Finding, The skier denied having ever used rhGH and requested the analysis of his B Sample, the results of which again exceeded the decision limits, thus confirming the positive test.
At the national-level, the skier successfully challenged the reliability of the decision limits in a disciplinary process that took over two years to complete. The extended duration at the first-instance, conducted before the FINADA (Finnish National Anti-Doping Agency) Supervisory Board, was due to Juha Lallukka’s request in January 2012 for a stay of his proceedings in anticipation of the Court of Arbitration for Sport (“CAS”) award in the Veerpalu matter, in which an Estonian skier, Andrus Veerpalu, had also challenged the reliability of the decision limits in the test for rhGH. In March 2013, the Veerpalu CAS award was released publically, finding that the decision limits for the rhGH test enshrined in the WADA rhGH Guidelines were not sufficiently reliable and, therefore, that Andrus Veerpalu could not be found to have committed an anti-doping rule violation. The FINADA Supervisory Board resumed the proceedings against Juha Lallukka, and in line with the Veerpalu decision, also found that the decision limits in the rhGH test were unreliable. In addition, the Supervisory Board found that FINADA had not provided sufficient scientific evidence that the revised decision limits would not be set at values higher than the ratios observed in the skier’s Sample. The Board consequently found that no anti-doping rule violation had been committed. The decision was appealed by FINADA to the Finnish Sports Arbitration Board, which confirmed the decision in December 2013.
WADA appealed the Finnish Sports Arbitration Decision to the CAS on the main ground that the decision limits had subsequently been verified by two independent studies (McGill University in Montreal and University of Descartes in Paris), which had been merged into the so-called “Joint Publication Paper”. It also submitted that, in any event, the skier’s ratios were so high that they “constitute[d] overwhelming evidence of administration of exogenous hGH, irrespective of whether the decision limits as set in WADA’s Guidelines are reliable or not”.
In his answer, the skier objected to procedural aspects of his case, in addition to his argument on the merits that the decision limits remained unreliable. He argued that the appeal was inadmissible for belated filing and asserted that that applying the new decision limits and scientific validation of a test that took place after his Sample collection would amount to an “impermissible retroactive application of the law”. Per the decision limits, he argued that the Joint Publication Paper published as a result of the two independent studies commissioned by WADA as a result of the Veerpalu award left unanswered some issues raised by the CAS panel in this award, so the decision limits were still unreliable, but that he did “no have the financial means to substantiate his allegations in this regard”. The skier, named as a sole respondent in the CAS proceedings, was granted legal aid by the International Council of Arbitration for Sport, to cover the travel and accommodation costs of the skier and his counsel to a hearing, as well as for experts, witnesses or interpreters. While a request for additional legal aid, was denied, the panel did agree to forgo an oral hearing and base its decision on the written submissions.
After dealing with the skier’s procedural objections and confirming the timeliness of WADA’s appeal, the CAS panel addressed the admissibility of the documents filed by WADA after submission of its appeal brief, which typically represents the last moment in the proceedings for the appellant party to file evidence in CAS appeal proceedings (Article R51 of the CAS Code). In the particular matter, the documents at stake were the revised 2014 WADA rhGH Guidelines, as well as the final version of the Joint Publication Paper arising from the studies conducted after the Veerpalu award. The panel considered that the documents had only been made available to WADA after the submission of its appeal brief, that these documents addressed the core of essential questions in the proceedings, as well as the fact that the skier had failed to submit additional comments on these documents – in spite of having been invited to do so – and had not objected to their production. Accordingly, the CAS panel found that “exceptional circumstances” within the meaning of Article R56 of the CAS Code were realized and the new evidence should be admitted on the record.
Turning to the merits, the CAS panel first resolved the issue of whether an anti-doping rule violation had been committed in the affirmative, and second, decided on appropriate sanction. For the analysis of the existence of an anti-doping rule violation, the CAS panel started by recalling that the burden of proof is on the Anti-Doping Organization to establish an anti-doping rule violation to the comfortable satisfaction of the panel [Article 3.1 of the World Anti-Doping Code (“WADC”)]. The panel also emphasized that the skier had not challenged that the analysis of his Sample was performed correctly in the particular matter, but only submitted that the decision limits determined by WADA are unreliable and that he could not exclude the possibility that there might be some physiological or scientific explanation for his high ratios.
The WADA rhGH Guidelines had been updated to reflect the latest revised decision limits based on the Joint Publication Paper drawn from these studies.
The CAS panel turned to assessing how the Joint Publication Paper addressed the “main points of contention” raised in Veerpalu . As a starting point, the panel recalled the reasoning in Veerpalu whereby the Anti-Doping Organization bears the burden of showing that a violation occurred “by means of a test that is scientifically reliable”, which includes the decision limits. Reviewing what it considered the three main points of contention (insufficient sample size, inappropriate exclusion of certain sample data, uncertainties related to the distribution model used), the CAS panel concluded that in its opinion “the Joint Publication Paper responded adequately to the concerns expressed” in Veerpalu.
The panel ended this part of its analysis with a few remarks regarding its role in weighing expert opinions, insisting that it is “not its function to step into the shoes of scientific experts”, but that its role is nevertheless “to determine whether the experts’ evaluations […] are soundly based on the facts, and whether the experts consequent appreciation of the conclusion be derived from those facts is equally sound”. In the particular matter, the panel considered as relevant factors: i.) the fact that the studies and Joint Publication Paper were “the fruit of a collaborative effort by two independent teams of experts”, ii.) that the study was based on a “considerable and large dataset, which has been peer-reviewed and accepted for publication”, and iii.) that the study “is said to establish decision limits with a 99.99% specificity”. Based on these factors, the panel declared that “it is not immediately apparent to the Panel how it could conclude that the Joint Publication Paper may be said to be unreliable”, and therefore found itself comfortably satisfied of the reliability both of the test and of the decision limits. According to the CAS panel, this meant the burden of proof was on the Athlete to establish “any particular departure or departures that could have led to a false-positive finding”. However, the CAS panel went on immediately to state that the skier had only offered submission by way of speculation and thus had failed to establish how some points raised in the first study “could reasonably have caused a false positive”.
The CAS panel finally noted that the revised decision limits were “quite close” to the decision limits in the previous version of the WADA rhGH Guidelines, so that the decision limit “did not vary in a magnitude that brings them anywhere near the ratio values found on the Athlete”. In this respect, turning to a different limb of the reasoning, the CAS panel sought support from the Sinkewitz award, considering the following findings relevant: i.) neither the Sinkewitz nor the Lallukka cases were “borderline situations”, in the sense that the ratios in both cases were “far higher” than WADA’s decision limits, ii.) in fact, Juha Lallukka’s ratios were even higher than Patrick Sinkewitz’, “and significantly so”, iii.) the decision limits are mere recommendations to the WADA-accredited laboratories, not legally binding as such and therefore do not have the “legal force to distinguish between doping […] and non-doping […]”. The panel cited the paragraph in which the Sinkewitz panel relied on expert opinions confirming that the Patrick Sinkewitz ratio values were clearly indicative of the presence of rhGH. In a final comment, the panel observed that the Athlete had submitted no evidence showing that his ratio values could have been affected by individual circumstances, and, consequently, “the Athlete is not in a position to prove to the comfortable satisfaction [sic] of the Panel that external factors may have had an impact on his ratio values, which could have led to a false positive”.
The CAS panel addressed a further objection of the Athlete, whereby the Athlete claimed that applying the revised decision limits to his analysis conducted in 2011 would amount to an impermissible retroactive application of the law. The CAS panel reiterated its position that the decision limits “are not rules as such”, but are described in Guidelines and “merely constitute figures upon which reliance may be placed by means of evidence to determine whether an anti-doping violation has or has not occurred in application of the rules”. The evidence adduced by WADA to this effect had been admitted to the CAS proceedings, confirming that the skier’s ratio values were “at a level that violate the applicable rules, irrespective of whether one places reliance on level set by the 2010 Guidelines or the higher level that later emerged”. Recalling that the prohibition of retroactivity does not apply to evidentiary matters, the CAS panel rejected the objection.
In terms of due process, the CAS panel also rejected the skier’s claims for compensation against WADA for undue delays in the proceedings, holding that WADA had “dealt with the Athlete’s situation without undue delay and conducted itself in a fashion which is beyond reproach and scrupulously, in accordance with the interests of all the parties”.
Having considered itself comfortably satisfied that the analytical findings revealed the presence of rhGH and thus that an anti-doping rule violation occurred, the CAS panel turned to the determination of the appropriate sanction. The CAS panel refused to follow WADA’s claims that the facts of the matter, i.e. the detection of rhGH or that fact that the skier had chosen to contest the allegations, could per se represent an aggravating circumstance under Article 10.6 of the Finnish Anti-Doping Regulations (equivalent to Article 10.6 of the 2009 WADC). Accordingly, the CAS panel imposed a standard two-year Ineligibility period, but gave the skier credit of the Provisional Suspension and refused – for fairness reasons – to disqualify results achieved in the period during which the skier had been “cleared” by his two national hearing panels.
Various readings of the Lallukka award are possible. In the eyes of WADA, the Lallukka award puts a definitive end to the uncertainties triggered by the Veerpalu award and demonstrated the capacity of the anti-doping movement to successfully react to a challenge to the scientific reliability of analytical tools. Others may view the “rhGH trilogy” (Veerpalu, Sinkewitz, Lallukka) that has been playing before CAS for the past two years as a textbook illustration of the ambiguities surrounding the legal status of WADA “technical” rules, and of the manner in which CAS panels struggle to come to terms with the increasing complexity of analytical tools in anti-doping science. In any event, the award opens a variety of paths for further discussion, all of which would be worthwhile exploring. In this short comment, we focus on those points that appear most revealing of what one might expect in future from CAS panels on similar matters under the 2015 WADC.
The rhGH trilogy had the merit of prompting CAS panels to recall that the basic burden of proof is on the Anti-Doping Organization for all elements of an anti-doping rule violation, even if they are presented with the “supreme” evidence of an Adverse Analytical Finding, and that the scope of this burden encompasses the validity of the analytical science used to produce the analytical finding. In addition, both the Veerpalu and the Lallukka panels made it clear that such proof must cover not only the reliability of the analytical method itself, but also the decision limits used to determine whether the findings are indicative of the presence of a Prohibited Substance. The implementation in the particular matter of the principles stated by the CAS panels, however, is less clear-cut. Both CAS panels, in particular, seemed to have difficulties drawing a line between the scientific reliability of the analytical tools on the one hand (which they declared is for the Anti-Doping Organization to prove to the Panel’s comfortable satisfaction), and whether the procedures established to apply these tools were adhered to in the particular matter on the other hand (which is for the Athlete to prove by a balance of probability). Thus, the panel in Lallukka went through a true back-and-forth in its reasoning, both regarding the burden of proof and the standard of proof. The panel appeared to impose – part of – the burden of proof on the skier for demonstrating that the decision limits were set in sufficiently reliable manner, and concluded on a statement placing a standard of “comfortable satisfaction” on the Athlete that is in contradiction with the explicit terms of the WADC (general rule of Article 3.1).
The same ambiguities are perceivable when it comes to the legal status of the “decision limits” in the rhGH test. Admittedly, the panel in Lallukka was facing a difficult task having to build a coherent reasoning based on the two previous awards, in which each CAS panel had clearly – albeit only implicitly – defended a radically different perception of the role of the decision limits within the rhGH test. Unfortunately, as a result, the Lallukka award does not take a clear position. Thus, the panel both felt compelled to confront the reliability of the revised decision limits enshrined in the new version of the Guidelines with the points of concern raised in Veerpalu, and to reiterate the position of the Sinkewitz panel that these decision limits are not legally binding and represent mere means of evidence used to reveal the presence of rhGH in a Sample. As matters stand, the exact character of the rhGH test therefore remains unsettled, a sign that the historical structure of the WADA technical rules may no longer be adapted to accommodate these types of sophisticated analytical methods for substances that can also be endogenously produced.
Finally, another aspect of the award worth noting is the section that contains the CAS panel’s approach to the evaluation of expert evidence. Of note, these statements seem to rely on thoughts developed in the context of recent Athlete Biological Passport cases. In short, CAS panels are adamant that they do not simply show deference to expert evidence, especially to those experts appearing on behalf of the Anti-Doping Organization. However, the CAS panels are also bound to recognize that their ability to reconstruct the merits of the experts’ opinions is limited, and that they cannot substitute themselves to the experts on technical matters.
These limits are very apparent in the evaluation by the CAS panel in Lallukka of the new studies commissioned by WADA and the Joint Publication Paper, which shows that CAS panels impose upon themselves a form of self-restraint that constrains their inquiry to verifying the process through which the analytical science was developed (peer-review, independence of the study, publication), rather than its actual foundations. Symptomatically, the panel stopped its assessment at noting that the studies claim to guarantee a specificity of 99.99%, but neither assessed whether this claim had a scientific basis, nor indeed whether the specificity ought to be considered appropriate in the particular context. Of note, the panel in Lallukka also insisted on its duty to decide, when confronted with conflicting expert opinions, which of the opinions is more persuasive. This statement, however, is imprecise: if an arbitration panel – or indeed any other judge – is faced with an admitted scientific uncertainty, or truly irreconcilable expert disagreement, they are not forced to make a choice. In this case, the issue can remain undecided and the burden of proof comes into play. This, again, shows how decisive the distribution of the burden of proof is with respect to scientific issues, and the importance of access to expert evidence. Clearly, Athletes have no realistic chance to win a case based on any form of criticism directed against the scientific foundations for the analytical findings or their implications, if they lack the financial means to organize adequate expert evidence. In the particular matter, the skier did not file any expert opinion of his own and the CAS panel decided the matter based on the written file, i.e. without examination of the expert witnesses, so that there was no other scientific evidence on the record than the one produced on behalf of WADA. This left the panel relying on prior evaluation in the two Veerpalu & Sinkewitz awards, along with its own interpretation of the value of the evidence newly produced by WADA and how this new evidence had answered concerns raised in the past.
CAS awards rendered under the 2015 WADC in the near future should bring interesting developments to the above issues, since the revised WADC includes a new Article 3.2.1 that specifically addresses the challenges directed against analytical science, in the form of a new presumption in favor of the validity of such science. The revised 2015 WADC newly and explicitly acknowledges the possibility for Athlete to question the reliability of analytical tools in anti-doping science, but places on the Athlete the burden of proof on these issues.
“Analytical methods or decision limits approved by WADA after consultation within the relevant scientific community and which have been the subject of peer review are presumed to be scientifically valid. Any Athlete or other Person seeking to rebut this presumption of scientific validity shall, as a condition precedent to any such challenge, first notify WADA of the challenge and the basis of the challenge. CAS on its own initiative may also inform WADA of any such challenge. At WADA’s request, the CAS panel shall appoint an appropriate scientific expert to assist the panel in its evaluation of the challenge. Within 10 days of WADA’s receipt of such notice, and WADA’s receipt of the CAS file, WADA shall also have the right to intervene as a party, appear amicus curiae or otherwise provide evidence in such proceeding”.
The new provision is clearly inspired by the rhGH series of cases and covers both a clarification of the evidentiary regime applicable to the validity of analytical tools in anti-doping science, and procedural guidance in case of challenges brought against this validity. Undoubtedly, the first cases of application of this new provision will require CAS panels to interpret both its scope and its interplay with the CAS Code.
 CAS 2011/A/2566, Veerpalu v. International Ski Federation (FIS), 25 March 2013.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 46.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 48.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 33.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 42.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, paras 41-44.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, paras 66-72.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 80.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 81.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, paras 83 et seq.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 83.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 96.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 97.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 98.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 99.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, paras 100-101.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, paras 103-106.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 107.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 109.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 113.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, para. 120.
 CAS 2014/A/3488, WADA v. Lallukka, 20 November 2014, paras 127-137.
 See in particular the press release WADA made on occasion of the case, stressing that the CAS panel in Lallukka confirmed all concerns surrounding the rhGH test – in particular those raised in the Veerpalu award – were resolved, leaving no doubts left regarding the validity and reliability of the newly published version 2.1 of the WADA rhGH Guidelines https://www.wada-ama.org/en/media/news/2014-11/wada-statement-on-the-juha-lallukka-case (accessed 31.03.15).
 See e.g. CAS 2010/A/2235, UCI v. Valjavec & OC Slovenia, para. 79.

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Entitlement to a disability rating higher than 30 for adjustment disorder with mixed anxiety/depressed mood is denied.
Entitlement to a disability rating higher than 10 percent for bilateral plantar fasciitis with left foot calcaneal spur is remanded.
Entitlement to service connection for obstructive sleep apnea, to include as secondary to service-connected disabilities is remanded.
Entitlement to an earlier effective date for bilateral plantar fasciitis with left foot calcaneal spur is remanded.
The Veteran’s adjustment disorder with mixed anxiety/depressed mood has been manifest by occupational and social impairment with occasional decrease in work efficiency and intermittent periods of inability to perform occupational tasks.
The criteria for a schedular rating for adjustment disorder with mixed anxiety/depressed mood in excess of 30 percent disabling have not been met.  38 U.S.C. §§ 1155, 5103, 5103A, 5107, 5110; 38 C.F.R. §§ 3.102, 4.130 Diagnostic Code 9440.
The Veteran served on active duty in the United States Army from May 2008 to July 2012.  For his service, the Veteran was awarded (among other decorations) the Army Commendation Medal.
Disability ratings are determined by comparing a Veteran’s symptomatology during the pertinent period on appeal with criteria set forth in VA’s Schedule for Rating Disabilities, which is based on average impairment in earning capacity.  38 U.S.C. § 1155; 38 C.F.R. Part 4.  When a question arises as to which of two ratings applies under a particular diagnostic code, the higher rating is assigned if the disability more closely approximates the criteria for the higher rating.  38 C.F.R. § 4.7.  Otherwise, the lower rating will be assigned. Id.  Moreover, an appeal from the initial assignment of a disability rating, such as the appeal in this case, requires consideration of the entire time period involved, and contemplates staged ratings where warranted.
50 percent - Occupational and social impairment with reduced reliability and productivity due to such symptoms as: flattened affect; circumstantial, circumlocutory, or stereotyped speech; panic attacks more than once a week; difficulty in understanding complex commands; impairment of short- and long-term memory (e.g., retention of only highly learned material, forgetting to complete tasks); impaired judgment; impaired abstract thinking; disturbances of motivation and mood; difficulty in establishing and maintaining effective work and social relationships.
70 percent - Occupational and social impairment, with deficiencies in most areas, such as work, school, family relations, judgment, thinking, or mood, due to such symptoms as: suicidal ideation; obsessional rituals which interfere with routine activities; speech intermittently illogical, obscure, or irrelevant; near-continuous panic or depression affecting the ability to function independently, appropriately and effectively; impaired impulse control (such as unprovoked irritability with periods of violence); spatial disorientation; neglect of personal appearance and hygiene; difficulty in adapting to stressful circumstances (including work or a worklike setting); inability to establish and maintain effective relationships.
100 Percent - Total occupational and social impairment, due to such symptoms as: gross impairment in thought processes or communication; persistent delusions or hallucinations; grossly inappropriate behavior; persistent danger of hurting self or others; intermittent inability to perform activities of daily living (including maintenance of minimal personal hygiene); disorientation to time or place; memory loss for names of close relatives, own occupation, or own name.
When evaluating a mental disorder, the rating agency shall consider the frequency, severity, and duration of psychiatric symptoms, length of remissions, and the Veteran’s capacity for adjustment during periods of remission.  38 C.F.R. § 4.126(a).  The rating agency shall assign a rating based on all the evidence of record that bears on occupational and social impairment rather than solely on the examiner’s assessment of the level of disability at the moment of the examination. Id.  However, when evaluating the level of disability from a mental disorder, the rating agency will consider the extent of social impairment, but shall not assign a rating solely on the basis of social impairment.  38 C.F.R. § 4.126 (b).
When determining the appropriate disability rating to assign, the Board of Veterans’ Appeals (Board) primary consideration is a veteran’s symptoms, but it must also make findings as to how those symptoms impact a veteran’s occupational and social impairment.  Vazquez-Claudio v. Shinseki, 713 F.3d 112 (Fed. Cir. 2013); Mauerhan v. Principi, 16 Vet. App. 436, (2002).  Because the use of the term “such as” in the rating criteria demonstrates that the symptoms after that phrase are not intended to constitute an exhaustive list, the Board need not find the presence of all, most, or even some, of the enumerated symptoms to award a specific rating.  Id. at 442; see also Sellers v. Principi, 372 F.3d 1318 (Fed. Cir. 2004).  Nevertheless, all ratings in the general rating formula are also associated with objectively observable symptomatology and the plain language of the regulation makes it clear that the veteran’s impairment must be “due to” those symptoms; a veteran may only qualify for a given disability rating by demonstrating the particular symptoms associated with that percentage, or others of similar severity, frequency, and duration.  Vazquez-Claudio, 713 F.3d at 118.
At an initial psychological evaluation with his private treatment psychiatrist in October 2014, the treatment psychiatrist found the Veteran to be cooperative, dressed normally, oriented to time place and person, and without suicidal or homicidal ideation.  The Veteran reported symptoms of anxiety, depression, and hyperarousal.  His affect was congruent, his thought process displayed no flight of ideas or circumstantial thought.  The Veteran denied auditory and visual hallucinations, and he had no paranoia or delusions.  The Veteran reported no problems with his memory.  His private examiner diagnosed him with mood disorder and anxiety disorder.
At a January 2015 VA examination, the Veteran endorsed suffering from depressed mood, anxiety, and chronic sleep impairment.  On examination, the examiner reported that the Veteran was well groomed, presented with appropriate eye contact, was alert, oriented and had normal speech.  The Veteran was without suicidal or homicidal ideation.  The Veteran denied delusional thinking, his thought process was logical, he had no apparent attention or memory difficulties, and he had adequate insight and judgment.   The VA examiner found the Veteran’s symptoms had the functional impact of occupational and social impairment due to mild or transient symptoms which decrease work efficiency and ability to perform occupational tasks only during periods of significant stress, or; symptoms controlled by medication.
After careful review of the evidence, the Board finds that based on the preponderance of the evidence, an evaluation in excess of 30 percent disabling for an adjustment disorder is not warranted.  The Veteran’s reported symptoms do not rise to the level of those described by the 50 percent rating.  Further, the symptoms that the Veteran does have do not result in occupational and social impairment with reduced reliability and productivity.  Absent such findings, the criteria for a 50 percent rating (or even higher ratings) for the Veteran’s psychiatric disorder are not met.
This appeal involves consideration of the claim on both a direct and secondary basis. That is, consideration must be given to whether the Veteran’s sleep apnea was incurred in or aggravated by service and, alternatively, whether it is proximately due to or the result of a service connected disability, namely an adjustment disorder.  See 38 C.F.R. §§ 3.303, 3.310.
The Veteran’s initial claim for sleep apnea stated that his symptoms began in service.  The Veteran further included a buddy statement from a fellow service member attesting to sleep apnea symptoms that occurred while the Veteran was in service.  The Veteran’s VA treatment records include a diagnosis of obstructive sleep apnea confirmed by a sleep study.  The Veteran also included an etiology opinion from his private treatment psychiatrist claiming the Veteran’s service connected adjustment disorder aggravates the Veteran’s sleep apnea.  At a subsequent VA examination in September 2015 for sleep apnea, the examiner was only asked to render a nexus opinion on a secondary service connection basis in connection with the Veteran’s service connected adjustment disorder.
In light of the above, the Board finds that this case must be remanded so that the Veteran may be afforded a new VA examination to consider entitlement to service connection for sleep apnea on a direct basis and to directly address literature submitted by the Veteran in support of his secondary claim.
With regard to the Veteran’s bilateral plantar fasciitis claims, he has contended that his symptoms are more severe than reflected by the most recent VA examination conducted in June 2014.  A contemporaneous examination is warranted.
As to the effective date issue, the RO provided a Statement of the Case to the Veteran denying his claim for an increased rating, but it did not address the issue of the Veteran’s disagreement with the effective date of his initial rating.  While the actual Notice of Disagreement (NOD) form submitted by the Veteran did not clearly specify his disagreement with the effective date, the supporting statement did.  And since the Veteran filed his NOD in September 2014, prior to the March 2015 deadline requiring all expressions of dissatisfaction be submitted on a standard VA form, the Veteran’s accompanying letter expressing dissatisfaction with the effective date must be addressed in a Statement of the Case.
1.  Schedule the Veteran for an appropriate VA examination to determine the nature and possible relationship to service or to other service-connected disabilities of the Veteran’s sleep apnea.
The examiner should opine whether it is at least as likely as not that the Veteran’s sleep apnea was caused by, or otherwise related to, the Veteran’s active duty service to include if it was caused OR aggravated by any of the Veteran’s service-connected disabilities.  In answering this question, the examiner must specifically address the positive aggravation opinion submitted by the Veteran and the accompanying medical literature.
A clear and complete rationale should be provided for any opinions expressed.
2.  Schedule the Veteran for an appropriate VA examination to determine the current severity of his service-connected bilateral plantar fasciitis.
3.  Provide the Veteran with a SOC regarding the issue of entitlement to an earlier effective date for the grant of service-connected bilateral plantar fasciitis.  Advise the Veteran of the time period in which to perfect his appeal. If the appeal is perfected in a timely fashion, return the case to the Board for review as appropriate.


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In this parable, the manager “could no longer be manager”; however, for a season, he still had some use and control over the master’s property. What does this period of time represent?
What does it mean to “make friends” using “wealth” so that I will be received into “eternal dwellings”?
According to this passage, what constitutes being “faithful” with money? Have I been trustworthy in this sense?
Why is it impossible to serve both God and money?
When does the prodigal son come to his senses?
What is the attitude of the prodigal son as he returns home?
What does genuine repentance look like, as depicted in the prodigal son’s return home?
What does the father’s surprising response reveal about the essence of our relationship with God?
Identify the reasons for the older brother’s anger.
How can obedience (“never disobeyed your command”) produce bitterness and resentment?
What makes for a “celebration” for the older brother? Who is there, and who is not there?
How do my causes for “celebration” compare with those of God? What lessons can I learn from this?
What might have been the older son’s response to the father’s statement, “You are always with me, and everything I have is yours”?
Compare and contrast how the “tax collectors and sinners” and the Pharisees approached Jesus. What does this reveal about the Pharisees’ attitude toward “sinners” and their view of themselves?
How does my view of myself affect how I will approach Jesus?
What are two ways you can see the value of the lost items in these parables?
What is God’s view of me?
How should this parable change my view of myself and others?
What does it mean for a person to “hate” his father and mother, his wife and children, his brothers and sisters, and even his own life?
What lessons can I learn from the parable of the Great Banquet about why Jesus asks for such radical commitment?
Jesus does not hide the cost of discipleship. Why does he tell the crowd to count the cost of following him before they follow?
Compare the salt that loses its saltiness (v. 34) with the fellow who began to build but was not able to finish (v. 30).
What warning does this provide for those who claim to be disciples of Christ but have not counted the cost? What would be the outcome?
In this passage, Jesus says, “You cannot be my disciple,” three times. Given that every Christian is by definition a disciple of Christ (cf. Acts 11:26), what does this reveal about the nature of Christian discipleship?
Have you counted the cost of following Christ?
What cost have I paid since following Christ? Is following Christ worth the cost?
What is the cost of not following Christ?
What have I gained in Christ?
Reflect on the fact that in this story that Jesus told, he shows the primary impediment to responding to God’s invitation to be things that everyone recognizes as good. What are some “good” things that I am seeking (or experiencing) that get in the way of responding to God’s invitation to fellowship with him at the banquet?
What good thing can potentially deafen my ears to God’s calling?
Think about how the owner of the house might have felt in v. 17, v. 21, and then v. 23.
What does this reveal about his heart?
What did these people who did not come to the banquet gain?
1 One Sabbath, when he went to dine at the house of a ruler of the Pharisees, they were watching him carefully. 2 And behold, there was a man before him who had dropsy. 3 And Jesus responded to the lawyers and Pharisees, saying, “Is it lawful to heal on the Sabbath, or not?” 4 But they remained silent. Then he took him and healed him and sent him away.
5 And he said to them, “Which of you, having a son or an ox that has fallen into a well on a Sabbath day, will not immediately pull him out?” 6 And they could not reply to these things.
The Pharisees and experts in the law use a man suffering from dropsy to scrutinize Jesus. What does this reveal about them?
What did the Pharisees and experts in the law maintain by not answering Jesus’ questions? What did they forfeit through their silence?
How is the scene of the guests vying for the place of honor at the table a portrait of the world today?
How much do I value status and reputation? How is this manifested in the way I relate to people around me?
Who are “the poor, the crippled, the lame, and the blind” that God is asking me to take care of without being repaid?
What does it mean to be “repaid at the resurrection”?
Jesus says being saved is like entering through a narrow door. Why would this be the case? Or, in what ways is this true in my life?
To Jesus’ audience who believed that only Jews could enter the kingdom of God, what would be their response to what Jesus said in v. 29?
Who are the “last who will be first” and who are the “first who will be last” in v. 30?
Who are the “prophets” sent to me today?
Do I welcome or resist Jesus’ longing to gather me under his wings?
The synagogue ruler became indignant at Jesus’ healing on the Sabbath. Is there a relationship between what angers a person and what “cripples” a heart from functioning as God intended? How does this apply to me?
How has this parable worked out in history and in my life?
What false notion was Jesus addressing by asking two rhetorical questions about the victims of these tragic events?
“Unless you repent…” With these words repeated twice, Jesus emphasizes that the issue of ultimate importance is that they repent. In what ways do I need to heed this warning?
The gardener represents Jesus, whose intervention helps us avoid judgment. The gardener says that he’ll dig around and fertilize the tree. What would it look like for me to respond to these efforts of the gardener?
Why would living a life for Jesus cause division?
Why does Jesus use the family context to describe the division he brings?
What is the proper interpretation of the present time, according to v. 58?
If going before the judge refers to the final judgment at the end of one’s life, what does settling with your accuser “on the way” to the judge refer to?

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Oct 03, 2013 GTA 5 ONLINE Tutorial Angifa NextGen. Loading Unsubscribe from Angifa NextGen? BROMA A MIS AMIGOS Grand Theft Auto VI ELITE TEAM Duration: 12: 53. Makiman131 8, 019, 350 views. It tells you what GTA 5 is, how to get up and running, what to expect from GTA Online and how to get used to the controls.
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Contains over 100 pages covering everything from Game Controls, and Features to a tour through the local neighborhoods and activities across Los Santos and Blaine County plus a special interactive version of the game map to zoom in and explore. Aug 20, 2018 Watch video GTA Online, the multiplayer component of GTA 5 launched October 1, 2013.
GTA Online was free to play for everyone who purchased a copy of GTA 5. GTA Online was enabled by a software download patch. Subscribe to the Rockstar Mailing List Welcome to the Rockstar Games Subscription Management page. Rockstar mailing lists are the best way to get the early word on all our game announcements, official launches, contests, special events, and more.
Jul 31, 2018 GTAV: The Manual is the official manual app for Grand Theft Auto V. Contains over 100 pages covering everything from Game Controls, and Features to a tour through the local neighborhoods and activities across Los Santos and Blaine County plus a special interactive version of the game map to zoom in and explore. Feb 01, 2016 Manual Transmission for GTA V This mod will enable manual transmission for vehicles, using the games' real gear box!
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This article considers representations of disability in Russian fairytales. More particularly, the author focuses on anomalies of speech and muteness in fairytale characters. The article refers to classic collections of Russian fairytales, regional publications of the 20th and 21st centuries, and archival records of field materials. Considering the intricate genre interaction, multi-functionality, and correspondence of literary and oral traditions, the author makes an attempt to reveal the peculiarities of the representation of disability in Russian fairytales and folklore tradition. She demonstrates that contrary to other disabilities, muteness in fairytales is always imaginary or simulated. The inability of characters to speak is either a means of disguise, a way to hide their true nature, or a form of ritual behaviour necessary to carry out a magical act. Upon achieving the desired result, the characters begin to speak. Using elements of everyday or ritual practices, fairytale fantasy tends to change or intensify them. When it comes to speech, it copies the ritual and only changes the context and manner of the deed. A prohibition against speaking is only actualised when the characters find themselves in another world and when they have to communicate with supernatural forces. Both in life and in fairytales, silence is regarded as a form of universal protection and as a prerequisite for the successful implementation of a specified task. In fairytales, the imitation of muteness is always a voluntary act and silence is a choice of the character. In case of speech, it is the inability to speak which is the driving force of the plot: a silent fool defeats the serpent and liberates the tsarevna, while a numb beauty uses nettles to knit shirts and thus returns to her brothers their real appearance. In this case, muteness signifies that the characters have been chosen for their mission because of their capacity to perform a magical feat. Other forms of disability usually result from actions of the character’s enemy and are a real loss which cannot be repaired.
PhD (Philology), Head of the Sector of Intangible Cultural Heritage of the Centre of Culture of the Peoples of Russia, Polenov State Russian House of Folk Art of the Ministry of Culture of the Russian Federation.
8, bldg. 3, Sverchkov Lane, 101000, Moscow, Russia.
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Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from Georgia State Senator Judson Hill can be seen here and downloaded below.
Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from Oklahoma Majority Whip, State Senator Kim David can be seen here and downloaded below.
Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from New Hampshire State Representative Kenneth Weyler can be seen here and downloaded below.
Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from New Hampshire State Representative Josh Moore can be seen here and downloaded below.
Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from South Dakota State Representative Isaac Latterell can be seen here and downloaded below.
Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from South Dakota State Representative Jim Stalzer can be seen here and downloaded below.
Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from South Dakota State Representative Larry Zikmund can be seen here and downloaded below.
Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from North Dakota State Representative Vicky Steiner can be seen here and downloaded below.
Letters from state legislators from around the country continue to pour in leading up to the Supreme Court’s decision on King v. Burwell. The letter sent to Congress from Ohio State Representative Andy Thompson can be seen here and downloaded below.

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