Federal bankruptcy law allows debtors to discharge tax penalties if they meet certain criteria. The Internal Revenue Service (IRS) may penalize individual taxpayers for failing to file a tax return by the April 15 due date, 26 U.S.C. § 6651(a)(1). These penalties are dischargeable in bankruptcy if the “transaction or event” that resulted in the penalty happened at least three years before the filing date. 11 U.S.C. § 523(a)(7)(B). A California bankruptcy court recently considered when the “transaction or event” leading to penalties for a late-filed tax return actually occurred. The court agreed with the debtor’s argument, which placed the event more than three years before the filing date. In re Wilson, No. 12-11995, Adv. No. 14-1106, memorandum (Bankr. N.D. Cal., Feb. 25, 2015). The federal government is appealing the decision.
Individual and family federal income tax returns for a particular tax year are due on or before April 15 of the following year, but a taxpayer may obtain an extension of the due date to October 15. The debtor in the present case obtained this extension for tax year 2008, but he did not file the return until 2011. The IRS imposed penalties under § 6651(a)(1). The debtor filed for Chapter 7 bankruptcy in July 2012. The assets recovered by the trustee were sufficient to pay the debtor’s 2008 tax but not the penalties. The debtor then claimed that the penalties were subject to discharge.
In a motion for summary judgment, the debtor argued that the event leading to the imposition of penalties by the IRS occurred on April 15, 2009, the due date for his 2008 tax return. Since this date was more than three years before he filed for bankruptcy, he claimed, the penalties were dischargeable under § 523(a)(7)(B). The federal government argued, however, that since the debtor had obtained an extension, the penalties were not imposed until October 15, 2009, less than three years before the bankruptcy filing date. The court, somewhat incredulously, noted that this was a matter of first impression in the Ninth Circuit.
Both sides cited numerous cases in support of their arguments, but the court observed that none of them dealt with the exact same situation as this case. The debtor mainly relied on McKay v. United States, 957 F.2d 689 (9th Cir. 1992), which dealt with penalties imposed by the IRS for fraud under 26 U.S.C. § 6653. Although the facts were distinguishable from the present case, the court held that the ruling was applicable. The cases cited by the federal government, on the other hand, were “merely dicta as to the issue before the court.” Wilson, mem. at 2.
The Ninth Circuit held in McKay that, based on the language of § 523(a)(7)(B), any “penalty imposed on unpaid taxes accruing more than three years before the filing of the bankruptcy petition is dischargeable.” McKay, 957 F.2d at 693. Personal income tax debts accrue on the April 15 following the tax year at issue. Applying McKay, the court held that April 15, 2009 was the relevant date and that the penalties were dischargeable.
Bankruptcy attorney Devin Sawdayi has practiced in the Los Angeles area since 1997. We help individuals and families use the the Chapter 7 and Chapter 13 bankruptcy processes to repair and rebuild their finances. Contact us online or at (310) 475-939 to schedule a free and confidential consultation with an experienced financial advocate, who can help you get started today.


Yesterday morning, the full Federal Circuit issued its en banc opinion in Suprema, Inc. v. ITC and reversed the controversial Federal Circuit opinion that had effectively precluded the International Trade Commission from finding induced infringement in most cases involving method claims. No. 12-1170, slip op. at 4 (Fed. Cir. Aug. 10, 2015). In a 6-4 opinion, the en banc Federal Circuit disagreed with the panel opinion and confirmed that the ITC has jurisdiction over allegations of induced infringement of method claims. This decision is particularly important for cases involving the software and high tech industries, which often rely heavily on induced infringement allegations.
The underlying case in this appeal was an investigation before the U.S. International Trade Commission in which Cross Match Technologies, Inc. accused Mentalix, a domestic importer of fingerprint scanners, of infringing its U.S. Patent No. 7,203,344 (“the ’344 patent”). Cross Match also accused Suprema, the Korean developer of the imported scanners, of inducing Mentalix’s infringement. Cross Match contended that its ’344 patent was infringed when Suprema’s scanners were used in combination with Mentalix software after importation into the United States. The Commission agreed, finding that Mentalix’s operation of its software on the scanners after importation directly infringed Cross Match’s patent and that Suprema induced Mentalix’s direct infringement by actively encouraging incorporation of Mentalix’s software with its scanners. Based on this finding, the Commission issued an exclusion order preventing importation of the accused scanners into the United States. Mentalix and Suprema appealed to the Federal Circuit the Commission decision finding them in violation of §337 and the accompanying exclusion order.
A Federal Circuit panel overturned the ITC’s decision. Construing §337 under the Chevron framework, the panel found that the Commission’s authority to adjudicate matters of patent infringement only extends to “articles that — infringe” a U.S. patent, and that “[t]he focus is on the infringing nature of the articles at the time of importation, not on the intent of the parties with respect to the imported goods.” Suprema, Inc. v. ITC, 742 F.3d 1350, 1358 (Fed. Cir. 2013). The panel concluded that a violation of §337 “may not be predicated on a claim of induced infringement where the attendant direct infringement of the claimed method does not occur until post-importation.” Id. at 1353. This holding greatly curtailed the Commission’s authority to find induced infringement in cases involving method claims as such claims are generally infringed post-importation. The panel decision was controversial and, though it only explicitly applied to induced infringement, caused uncertainty regarding whether or not any allegations of indirect infringement of method claims would be successful at the ITC.
Yesterday, the en banc Federal Circuit overturned the panel decision. The Court conducted an analysis under the Chevron framework and determined that the Commission was correct in determining that goods qualify as “articles that infringe” where they are used, after importation, to directly infringe at the inducement of the sellers of the goods. The Chevron framework, used to determine what deference a reviewing court should give to an agency’s construction of a statue it administers, has two steps. Suprema, Inc. v. ITC, No. 2012-1170, Slip Op. at 14 (Fed. Cir. Aug. 10, 2015). First, the reviewing court must determine “whether Congress has directly spoken to the precise question at issue.” Id. If Congress has spoken to the issue, the inquiry ends and Congress’ guidance is followed. But, if Congress has not addressed the issue, the court must determine “whether the agency’s answer [to the precise question at issue] is based on a permissible construction of the statute.” Id.
Under step one of the Chevron framework, the Federal Circuit stated that the term “articles that infringe” does not narrow the term to exclude inducement or post-importation infringement, but instead introduces textual uncertainty. Id. at 15. Because Congress has not provided “unambiguous resolution” of the issue at hand, the Court proceeded to the second Chevron step.
Under Chevron step two, the Federal Circuit found that the Commission’s interpretation of Section 337 was reasonable because it was “consistent with the statutory text, policy, and legislative history of Section 337.” Id. at 20. Specifically, the Court found that “Section 337 contemplates that infringement may occur after importation.” Id. The Court also found the Commission’s interpretation consistent with the legislative history of Section 337, noting that Section 337 was meant, like its precursor Section 316, to be “broad enough to prevent every type and form of unfair practice,” (Id. at 21-22) and that for decades the Federal Circuit has “affirmed the Commission’s determination that a violation of Section 337 may arise from an act of induced infringement.” Id. at 25. For these reasons, the full Federal Circuit reversed the panel’s decision and reinstated the ITC’s decision.
The panel decision was controversial and caused public uncertainty regarding whether or not any allegations of indirect infringement of method claims would be successful at the ITC. It was also believed to offer infringers a significant loophole by allowing them to evade findings of infringement by doing the majority of a patented method overseas and then doing one small step post-importation. This decision strongly affirmed that the ITC has jurisdiction over the indirect infringement of method claims, and puts potential infringers on notice that they cannot evade ITC jurisdiction by performing the majority of the patented steps outside of the United States and having the final step performed either inside the United States or by the end user.
In addition, the opinion contains a number of statements implying that the Federal Circuit views the ITC’s jurisdiction broadly, which may have important ramifications for both upcoming cases and proposed causes of actions before the ITC, including the upcoming decision regarding whether the ITC has importation over digital imports, and thus could address subjects such as pirated movies, books, and software.
Nicholas W. Armington is an intellectual property attorney at Mintz who focuses on patent and trade secret litigation. Nick represents clients before the International Trade Commission and in US District Courts. His work involves network devices, semiconductors, converged devices, and LED lighting.


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[295 U.S. 89, 90] Messrs. Isadore Paul and S. Frederick Placer, both of New York City, for appellant.
Appellant, a retail dealer in automobiles in the city of New York, brought this suit to restrain the district attorney of New York county from instituting a criminal prosecution for alleged violation of the 'Code of Fair Competition for the Motor Vehicle Retailing Trade.' Appellant alleged that he was threatened with prosecution under chapter 781 of the Laws of 1933, Ex. Sess., of the state of New York, which made it a misdemeanor to violate any provision of a code of fair competition as approved by the President of the United States under Title 1, 1 et seq. of the National Industrial Recovery Act. 48 Stat. 195 (15 USCA 701 et seq.) It appears that the charge of violation of the code related to the provisions which limited the amount to be allowed for an old car 'traded in' as part payment for a new car and required the maintenance of factory list prices, plus certain charges, with a prohibition against discounts, gratuities, etc., for the purpose of inducing purchases. The state statute was challenged as repugnant to the Constitution of the state, by reason of an improper delegation of legislative power, and also as effecting a deprivation of liberty and property without due process of law in contravention of the Fourteenth Amendment of the Constitution of the United States.
Appellant's application for an interlocutory injunction was heard in the District Court by three judges. Jud. Code, 266, 28 U.S.C. 380 (28 USCA 380). There was also a motion by the defendant to dismiss the bill of complaint upon the grounds, among others, that it failed to allege facts constituting an equitable cause of action, and that the District Court was without jurisdiction. Pursuant to notice, the Attorney General of the state appeared in support of the state act. Affidavits were submitted on both sides and, on hearing, the District Court sustained the [295 U.S. 89, 92] validity of the statute and, on that ground, denied the motion for injunction, and granted the motion to dismiss the bill. An order to that effect was entered and the case comes here on appeal.
Upon the argument at this bar, the questions were raised (1) whether the district attorney was an officer of the state within the meaning of section 266 of the Judicial Code (28 USCA 380), and (2) whether the complaint stated a cause of action within the equitable jurisdiction of the District Court. The case was continued to permit the parties to file briefs upon these questions, and the briefs are now in.
In the Public Officers Law of 1892, c. 681 (now Laws 1909, c. 51, chapter 47 of the Consolidated Laws of New York, article 1, 2) a different classification was made and public officials were defined as either 'state officers' or 'local officers,' the latter embracing officers chosen 'by the electors of a portion only of the state.' District attorneys fall within this description of local officers. Notwithstanding the change in classification, they are still to be deemed a part of the judicial system of the state, each performing within his county a distinctively state function. Lincoln's Constitutional History of New York, loc. cit. See Opinions, Attorney General of New York, 1924, p. 120.
In this view we cannot regard the local description, or the method of selecting the officer, as decisive with respect to the application of section 266 of the Judicial Code (28 USCA 380). That section relates to suits in which an interlocutory injunction is sought to restrain, on constitutional grounds, the enforcement 'of any statute of a State by restraining the action of any officer of such State in the enforcement or execution of such statute, or in the enforcement or execution of an order made by an administrative board or commission acting under and pursuant to the statutes [295 U.S. 89, 94] of such State.' To determine the application of this provision, we must have regard both to the nature of the legislative action which is assailed and to the function of the officer who is sought to be restrained. We have said that the reference is not to every legislative action, regardless of its nature and scope, but to a statute 'of general application' or an order of a state board or commission. Thus, the section does not apply to suits to restrain the enforcement of municipal ordinances or the orders of a city board. Ex parte Collins, supra. And, although the constitutionality of a statute is challenged, the provision is inapplicable where the defendants are local officers and the suit 'involves matters of interest only to the particular municipality or district.' Id. Accordingly, a suit against local officials to enjoin the collection of taxes assessed against shares in a national banking association, in pursuance of a state law but 'by, and for the sole use of, the city,' was found not to be within the section. Ex parte Public National Bank, supra. We pointed out that the suit must not only seek to have a state statute declared unconstitutional, or that in effect, but to restrain the action 'of an officer of the state.' But the court was careful to reserve the question whether so-called local officers might not in fact represent the state or exercise 'state functions in the matters involved,' so as to bring the suit to restrain their action within the provision for three judges and direct appeal. Id., 278 U.S. 101 , page 105, 49 S.Ct. 43.
Where a statute embodies a policy of state-wide concern, an officer, although chosen in a political subdivision and acting within that limited territory, may be charged with the duty of enforcing the statute in the interest of the state and not simply in the interest of the locality where he serves. This is especially true in the case of a prosecuting officer who acts for the entire state, as a part of its machinery of enforcement, in proceedings against violators of the state statute. The function of [295 U.S. 89, 95] such an officer, in enforcing a statute of general application, is of controlling importance in giving effect to the intent of the Congress.
In the instant case it is manifest that the statute under attack attempted to establish a state-wide policy, and not one merely in the interest of the particular county. The defendant is charged with the duty of enforcing the statute by prosecuting those who disobey it, and in performing that duty he acts not merely in the local interest, but in the name of the people of the state in compelling observance of its laws. In that enforcement, he is acting in a true sense as an officer of the state. Appellant sought to restrain his action in that aspect, and hence we think that the case fell within section 266 of the Judicial Code (28 USCA 380) and was properly heard by three judges.
The general rule is that equity will not interfere to prevent the enforcement of a criminal statute even though unconstitutional. Hygrade Provision Co. v. Sherman, 266 U.S. 497, 500 , 45 S.Ct. 141. See, also, In re Sawyer, 124 U.S. 200 , 209-211, 8 S.Ct. 482; Davis & Farnum Manufacturing Co. v. Los Angeles, 189 U.S. 207, 217 , 23 S. Ct. 498. To justify such interference there must be exceptional circumstances and a clear showing that an injunction is necessary in order to afford adequate protection of constitutional rights. See Terrace v. Thompson, 263 U.S. 197, 214 , 44 S.Ct. 15; Packard v. Banton, 264 U.S. 140, 143 , 44 S.Ct. 257; Tyson & Bros. United Theatre Ticket Offices v. Banton, 273 U.S. 418, 428 , 47 S.Ct. 426, 58 A.L.R. 1236; Cline v. Frink Dairy Co., 274 U.S. 445, 452 , 47 S.Ct. 681; Ex parte Young, 209 U.S. 123, 161 , 162 S., 28 S.Ct. 441, 13 L.R.A.(N.S.) 932, 14 Ann.Cas. 764. We have said that it must appear that 'the danger of irreparable loss is both great and immediate'; otherwise, the accused should first set up his defense in the state court, even though the validity of a statute is challenged. There is ample oppor- [295 U.S. 89, 96] tunity for ultimate review by this Court of federal questions. Fenner v. Boykin, 271 U.S. 240, 243 , 244 S., 46 S.Ct. 492, 493.
Appellant's bill of complaint failed to meet this test. Appellant alleged that the district attorney had applied to a magistrate of the city of New York for the issue of a summons directing the appearance of the appellant, to the end that an investigation should be made of a complaint against him for violation of the provisions of the 'Motor Vehicle Retailing Code,' and that an information charging violation should be drawn. He alleged that the district attorney intended, unless restrained, to institute criminal proceedings. The state statute made any violation of the provisions of the code a misdemeanor punishable by a fine not exceeding $500 for each offense. The bill contained general allegations of irreparable damage and deprivation of 'rights, liberties, properties, and immunities' without due process of law, if the statute were enforced. But the bill failed to state facts sufficient to warrant such conclusions, which alone were not enough. The bill alleged that appellant had a large business in buying and selling motor vehicles, but the statute did not prohibit the continuance of that business and the bill gave no facts to show that the particular requirements of the code, which were in question, would create such a serious interference as to require equitable relief. Aside from the statement of general and unsupported conclusions, the case presented by the bill was the ordinary one of a criminal prosecution which would afford appropriate opportunity for the assertion of appellant's rights. So far as the bill disclosed, nothing more than a single prosecution was in contemplation, a point which the district attorney emphasized by his disclaimer, on the hearing below, of any intention to institute any further prosecution against appellant until his rights, constitutional or otherwise, had been adjudicated in the pending criminal proceeding. [295 U.S. 89, 97] The bill should have been dismissed upon the ground that it failed to state a case within the equitable jurisdiction of the District Court. The decree is modified accordingly, and, as modified, the decree is affirmed.

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OBJECTIVE. This study investigated the contribution of perceptual-motor dysfunction and cognitive planning problems to the quality or speed of handwriting in children with handwriting problems (HWP).
of handwriting in the control group.
CONCLUSIONS. Results suggest that two different mechanisms underlie the quality of handwriting in children with and without handwriting problems. Poor quality of handwriting of children with HWP seems particularly related to a deficiency in visual-motor integration.
search for underlying mechanisms. American Journal of Occupational Therapy, 60, 451–460.
activities, with writing as the predominant task (McHale & Cermak, 1992).
Maeland, 1992; Mojet, 1991; Smits-Engelsman & Van Galen, 1997).
2000) or slow speed of handwriting (Tseng & Chow. such as cognitive planning or working memory processes (McCutchen. An interesting question is whether a deficiency in higher-level encoding processes (e. 1992. Graham & Harris.. phonological or orthographic coding) affects the quality or speed of handwriting. 1991. According to these authors. In the study by Maeland (1992). 1982. & Van Galen. such as phonological and orthographic coding (Berninger & Swanson. or due to slow speed only (Karlsdottir & Stefansson. Tseng & Murray. but also parallel processing. 1996. 1997. 1994). Graham et al. It is assumed that when a child knows what to write. 1991). Empirical evidence exists that problems in handwriting relate to a deficit in perceptual-motor function. 2000.g. Van Galen. this slow speed of handwriting could be traced back mainly to a dysfunction in the quality of handwriting.g. 2001). it is further assumed that handwriting involves not only serial hierarchical processing. 1994). a significant correlation was also found between quality of handwriting and visual perception in the group classified as clumsy. fine motor coordination. Weintraub & Graham. 1992. 1988. and visual-motor integration (e. 1998). a group of children classified as clumsy (half of them being dysgraphic and half of them non-dysgraphic). 1993. Smits-Engelsman & Van Galen. Smits-Engelsman.the variables at all (Graham et al. speed of handwriting does not seem to differ significantly between children with and without HWP (Hamstra-Bletz & Blöte.. before the corresponding motor program can be selected and executed (lower level processes). during the evaluation and revision of what was written (Berninger & Swanson. Weintraub and Graham (1998) reported that instruction to write neatly did result in a decreased speed of handwriting. One study reported that about 16% of children with HWP in grade 3 and grade 5 showed handwriting problems due to slow speed and poor quality. Indeed. Several studies have reported that handwriting legibility of children with handwriting problems (HWP) is clearly worse compared to children without HWP (Hamstra-Bletz & Blöte. As far as we know. Number 4 ... and convert phonemes into graphemes (higher level processes). 1997. 1995). who were found to be slower compared to controls (Jongmans. 2000). Niemeijer. or both. the group classified as non-clumsy dysgraphic in the 1992 study by Maeland) remains therefore unsolved. except for children with HWP attending special education. 1994. 1993. for example. 2000). with visual-motor integration. Although higher-level processes precede lower-level ones. Rubin & Henderson. whereas other studies reported that visual-motor integration contributes significantly to poor quality (Maeland. Several studies have found that children with HWP show a deficit in fine motor control (Maeland. Arntzen. 2002). Maeland. 1998. hand–eye coordination). in particular. Smits-Engelsman. Missiuna. 1994). 2001.g. 1994). 1995. & Macnab. 1994. copying text) or auditory (e. On average. and matched control were compared with regard to their quality of handwriting. or both. he or she first has to retrieve the correct letters or words from memory.g. & Schomaker.. The question as to what the underlying mechanism is for the handwriting difficulties of children who do not show distinct general motor problems (e. Karlsdottir & Stefansson. Interestingly. but not in the group classified as non-clumsy dysgraphic and the control group. These findings suggest that the correlation between visual perception or visual-motor integration and handwriting performance in dysgraphic children might be specifically related to coinciding developmental coordination disorder (DCD) (American Psychiatric Association. but again not in the groups classified as non-clumsy dysgraphic and normal. Rubin & Henderson. put them in the right order. It was found that quality of handwriting significantly correlated with visual-motor integration in the group classified as clumsy. Furthermore. non-clumsy dysgraphic. dictation) information. Tseng & Murray. 1987. It is known that young novice writers require full use of their attention resources on the lower-level processes of handwriting. Sovik & Arntzen. Perceptualmotor processes in handwriting consist of perception of either visual (e. & Thygesen. and more 452 specific language processes.g. Handwriting is a complex activity in which lower-level perceptual-motor processes and higher-level cognitive processes continuously interact (Berninger & Swanson. Volume 60. (1998) found that handwriting speed did explain only 1% of the variance in handwriting legibility (when accounting for grade). in children with HWP has not yet been investigated. Weintraub & Graham. Abott and Berninger (1993) found that orthographic coding July/August 2006. Mandich. Van Galen. Smits-Engelsman & Van Galen. The underlying mechanisms responsible for handwriting difficulties are not yet understood. Sovik. Graham & Weintraub. no other studies examined the relationship between legibility and speed specific in children with handwriting difficulties. 2003). Linthorst-Bakker. Portier. McCutchen.. it is known that a majority of children with DCD appear to have problems with their handwriting (Miller. 2002. and that this may be detrimental for fluent higher-level encoding processes during writing (Graham et al. The role of a deficiency in cognitive function as another possible variable to explain poor quality or slow speed. 1992. 1997. Cognitive processes involved in handwriting can be divided in more generic processes. & SmitsEngelsman. A study by Schoemaker et al. Polatajko.. Westerberg. (2001) found that children with DCD also had problems with visual perception. 1993). 1982).
Incorrect relative height of letters 10. and scores in between are labeled intermediate. (b) how is quality of handwriting associated with speed of handwriting in children with or without HWP. or fast writers. In the present study.4 11/3 97. indicating that The American Journal of Occupational Therapy Table 1.3 16/4 100. p < . Informed consent of parents was obtained for all 29 children with HWP and for 20 control children. Letter size too large for the child’s age 2. the first child on the class list that matched for age and gender. teachers were asked to select a control child. and the Movement Assessment Battery for Children (Movement ABC) (Henderson & Sugden. In the control group. M-ABC = Movement Assessment Battery for Children (Henderson & Sugden. To confirm the classroom teachers’ judgment. Method Participants A total of 49 children (29 children with HWP and 20 control children) participated in the study. gender. visual-motor integration. a high score indicating deviance. In Table 1. Irregularities in joining letters 7. a pencil-and-paper test that taps cognitive planning ability and working memory capacity will be used to investigate the contribution of cognitive planning to handwriting quality and speed of children with HWP. Unsteady writing trace These features are scored on an ordinal scale from 0 to 5. and General Motor Coordination Ability of Participating Children HWP Group (N = 29) Control Group (N = 20) Grade 2 (N = 20) Grade 3 (N = 9) Grade 2 (N = 14) Grade 3 (N = 6) Age (months) Gender (boys/girls) 91. and 3 children scored above the 15th percentile. Correction of letter forms 13.e.3) 4.1 (1. Children were asked to write in their usual style. Gender. at least the first five sentences). 1987) is a standardized norm-referenced instrument to identify children with HWP. The following research questions were addressed: (a) what are the significant differences between children with and without HWP on the abovementioned variables. the copying speed score was also transformed to a deciles score related to the child’s grade. For each child with handwriting difficulties.e..001). 1987). and higher level processes (cognitive planning) involved in a handwriting task (i.. & den Brinker. visual perception. Scores falling within the lower two deciles are considered to represent slow writers.6 4/2 Mean M-ABC score (SD) 16. resulting in a total group of 20 control children. 1 child was identified as borderline.5 (4. Handwriting quality (legibility) was evaluated according to 13 dysgraphia handwriting features: 1. including letter corrections. The two groups did not significantly differ in age. Age. 1992) score for the HWP and control group are presented. Ambiguous letter forms 12.60. for slow writers. Acute turns in connecting letters 6.4) 4. To classify children as slow. Insufficient word spacing 5.e. Left margin widening 3. 6 children scored between the 5th and 15th percentile (borderline). all children were evaluated on the Concise Assessment Scale for Children’s Handwriting (Hamstra-Bletz. Purpose and research questions. Thirty children were pre-selected by the class teachers from a total sample of 687 children. First.0) 16.. that is. intermediate. It has also been suggested that in elementary school children. The aim of the present study is to investigate the role of lower level processes (i. Instruments Handwriting. de Bie.contributed directly to the speed of copying text. The Concise Assessment Scale for Children’s Handwriting (BHK) (Hamstra-Bletz et al. 2000). 20 children scored below the 5th percentile. copying text) in children with HWP and matched controls. For various reasons. higherlevel processes involved in writing are constrained by limitations in working memory capacity (McCutchen.8 (5. Inconsistent letter size 9. The handwriting task consists of copying a standard text presented on a printed card as neatly as possible within a time frame of 5 min (or. Copying speed was determined by counting the number of letters completed within 5 min. not all of the teachers selected a control child. In the HWP group.1) Note.1 6/3 88.. HWP = Handwriting problems.1 (2. The 453 . 10th percentile). and fine motor coordination). A child is considered dysgraphic if the overall score exceeds 28 (i. Poor word alignment 4. Letter distortion 11. scores in the upper two deciles represent fast writers. Twenty-nine children were diagnosed as dysgraphic on this assessment and were included in the study. class teachers of grades 2 and 3 from 23 regular schools were asked to screen children on distinct handwriting difficulties. age. The HWP group scored significantly worse on the Movement ABC total score (t = 12. 1992) they had serious (general) motor problems. and (c) which of the aforementioned variables is the best predictor of quality and speed of handwriting in children with or without HWP. They wrote the text on an unlined A4 sheet of paper. Collision of letters 8. A two-step procedure was applied to select children with HWP.
and Movement ABC test. (b) bimanual coordination.89. VMI–motor coordination. Data Analysis A 2 Group (HWP. The child has to alternate between numbers and letters as the numerical and alphabetical sequences progresses. non-slow) ANOVA was applied for the HWP group. BHK–speed. Visual perception. reflects not only cognitive planning.71 and 0. Manual Dexterity consists of three tasks that measure different aspects of fine motor ability. July/August 2006. Metsapelto. Fine motor coordination. Pearson product-moment correlation was calculated for the HWP and control group separately to determine the relationship between handwriting performance and the different tests. because in the control group there were no slow writers. The TMT-B measures the cognitive ability to shift between different kinds of tasks and. TMT-B. In the visual-motor integration task children are asked to copy 24 geometric figures starting with simple figures and ending with more complex ones. and TMT-B score. Neyens and Aldenkamp (1997) reported test–retest reliability for children between 4 and 12 years of age as . The TMT-B is sensitive to differences in cognitive planning between school-age children with and without academic difficulties (Naerhi. that is. Part B (TMT-B) (Reitan & Wolfson. Visual perception was measured with the VMI visual perception subtest (see previous paragraph for a description and scoring). After the VMI test. The Movement ABC test (Henderson & Sugden. The 454 TMT-B consists of tracing a line between circles containing letters and numbers. 1997) was used to measure visual-motor integration. Time taken to complete the task was measured. visual perception. Volume 60. 1964) is reported to be 0. we transformed the TMT-B scores to logarithmic scores. VMI–integration. The tests were administered and scored by the second author. 1997) was used as a second measure of fine motor coordination.interrater reliability of the BHK has been reported to vary between r = 0. 1997. (b) visual perception. which were then used for further analysis. Procedure All children were tested at their school in two sessions. we used Unimanual Dexterity (i. then to 2. & Ahonen. The Movement ABC test consists of eight motor tasks that are divided into three categories: (a) Manual Dexterity. therefore. and motor coordination processes. VMI–visual perception. Visual-motor integration. VMI–integration. The motor coordination subtest of the Developmental Test of Visual-Motor Integration (VMI) (Beery. In the visual perception task children are shown the same geometric figures. An additional Grade × Speed of handwriting (slow. 2004).. The number of correct responses is scored. Reitan & Wolfson. The number of responses without mistakes is scored. control) × 2 Grade (grade 2. The BHK was administered in the first session. and (c) motor coordination. Rasanen.78 (Hamstra-Bletz & Blöte. and TMT-B as predictor variables. 2000). Raw scores were converted to standardized scores. but also cognitive flexibility in particular (Arbuthnott & Frank. locates and draws a line to A. and so on. Results Differences Between the HWP and Control Group Table 2 presents the scores on all the tests for the HWP and control group. Because the TMT-B time scores were not normally distributed (left skewed). In the (fine) motor coordination task. Because we were not interested in bimanual coordination ability. The selected children with HWP and their matched controls were administered the VMI. 1992) was administered to determine general motor-coordination abilities in all children. 1998). Slow performance is indicative for problems in cognitive flexibility. namely (a) unimanual speed. either until the child fails at three successive items or the child runs out of time (3 min). VMI–visual perception. Number 4 . The Trail Making Test. The child begins at 1. The VMI has been reported to be a valid and reliable test (DickersonMayes & Calhoun. Correlation between the BHK and the Dysgraphia Scale (De Ajuriaguerra et al. either until the child fails at three successive items or the child runs out of time (5 min). children use a pen to make a trail within border lines derived from the same geometric figures. and for each figure they have to choose the correct one out of 6 alternatives. 1985) was used as a measure of cognitive planning. The revised version of the VMI (Beery. The second session took place within 4 weeks from the first session.. visualmotor integration. It took about 90 min to test each child.e. Children were instructed to perform the task fast but not necessarily with spatial accuracy. Stepwise linear regression analyses were applied to identify the strongest predictor of handwriting quality and handwriting speed for the HWP and control group separately with Unimanual Dexterity. and (c) Balance. Unimanual Dexterity. (b) Ball Skills. grade 3) analysis of variance (ANOVA) was applied on the BHK– quality. and (c) unimanual spatial accuracy. The VMI consists of three parts: (a) visual-motor integration.g.56 for the TMT-B. VMI–motor coordination. Cognitive planning. children were allowed a 15-min break. handwriting). the sum of task 1 and 3) as the first measure of fine motor coordination.. then to B. The revised version of the VMI is suitable to discern the different processes involved in hand–eye coordination tasks (e. 1993).
9 were classified as intermediate writers (45%). p-Values. p < .001) in comparison to the control group.62 .48) = 26.27. No significant effect for Grade was found on BHK– speed. Thirteen children scored more than 2 standard deviations below the mean standard score. Also.79 . No significant interaction effects were found. revealing that.001).0 (11. p = .2%) as intermediate writers. In both groups. dependent variable: TMT-B score) to check whether Item 1 of the Movement ABC test (i.16.1 (54. p < .87 .0 versus M = 71. In the HWP group.e.9) 150.g. a measure of unimanual speed) would significantly contribute to the explained variance in the TMT-B time score.48) = 251.09). t = 1. Note.4) 7.Table 2.26.44 . the difference in time between the two groups might be due to a motor component (e. VMI = Developmental Test of Visual-Motor Integration (Beery. No significant effect for Grade or significant interaction effect was found.3) 7.01).69. and 11 children (55%) were classified as fast writers.1 (2.1 (3. a significant Grade × Handwriting Speed interaction effect was found (F(1.28) = 4. Correlations Between Handwriting and Test Variables In Table 3.001). With regard to the different handwriting features of the BHK.001) in comparison to the control group. movement speed) instead of a more cognitive planning component. Mean Scores (SD).6 (9.0) 77.44 * p < . The American Journal of Occupational Therapy whereas this was not the case in grade 2 (respectively. 1985).7) 34. p < .1 (5.29. A significant effect for Grade (F(1.8 versus M = 69.8) 108. Handwriting.87 . The HWP group was significantly slower in completing the TMT-B (F(1.51.0 (26. and Effect Sizes of Tests for the HWP Group and Control Group BHK–quality BHK–speed (letters per min) BHK–speed (decile score) Unimanual Dexterity VMI–integration VMI–perception VMI–motor coordination TMT-B (sec) HWP Group (N = 29) Control Group (N = 20) p η2 38. In the HWP group. Visual motor integration.63.2%) as fast writers. 19 of the children with HWP (65.8) 19.2) 3. No significant effects for Grade or interaction effects were found.0 (7. 5 children (17.8 (0.48) = 307. Pearson correlations between handwriting quality and speed and the other test variables are presented for the HWP group and control group.4) 11. on average..5 (7.4) 89.73 .5 (2. HWP = handwriting problems.2) 0. In the control group. The HWP group scored significantly lower on VMI–integration (F(1.” Handwriting of the HWP group was also significantly slower (F(1.9 (3. No interaction effect was found. the VMI scores of children with HWP classified as intermediate writers and fast writers were better than that of slow writers in grade 3 (respectively. TMT-B = Trail Making Test.01) showed that the quality of handwriting of children in grade 3 was better compared to that of children in grade 2. a significant effect for Grade was found (F(1.71. indicating that children in grade 3 were faster in completing the TMT-B task than children in grade 2.69. Quality of handwriting in the HWP group was significantly lower compared to that of the control group (F(1.48) = 110.1 (8.63. M = 78. In the HWP group.48) = 34.48) = 7. M = 66.12. According to the BHK-norms. and on VMI–motor coordination (F(1. Cognitive planning.001).3) 114. Part B (Reitan & Wolfson..6%) were classified as slow writers.002) except for the features “left margin widening” and “collision of letters.001. Visual perception.2 (7. 1987). We therefore applied a regression analyses (entered variables: Group and Movement-ABC Item 1 score.001) than matched controls. and 5 children (17.2) * * * * * * * * .3).001) compared to the control group.48) = 137.48) = 58. p = . Because the trail-making task consists of a motor component and the HWP group also performed worse on unimanual dexterity. the additional Grade × Handwriting Speed ANOVA did not reveal significant main or interaction effects. p < . p < .20.4 (5. none of the children were classified as slow writers.. p < .9) 112. Fine motor coordination. the HWP group performed significantly less proficiently on all features (p < . p < .48) = 8. The HWP group scored significantly lower on Unimanual Dexterity (F(1. the additional Grade × Handwriting Speed ANOVA did not show significant main or interaction effects. handwriting quality was significantly correlated with Unimanual 455 .05). but Item 1 did not significantly contribute to the TMT-B time score differences between the two groups (beta = . A significant main effect of Group showed that the HWP group scored lower on the VMI–visual perception (F(1. No significant effect for Grade or significant interaction effect was found. Group and Movement-ABC Item 1 did together explain 49% of the variance of the TMT-B. 1997). BHK = Concise Assessment Scale for Children’s Handwriting (Hamstra-Bletz et al.39 . p < . p < .8 (10.2) 76. the additional Grade × Handwriting Speed ANOVA did not reveal significant main or interaction effects. Two children scored more than 2 standard deviations below the mean standard score. In the HWP group. Six children scored more than 2 standard deviations below the mean standard score on the VMI–motor coordination.4).3) 71.
Table 3. significant correlations were found between Unimanual Dexterity and VMI–integration. VMI–motor coordination and VMI–integration.05 –.25 –. Writing speed of participant #3 (BHK = 31) was classified as intermediate. BHK–quality 2.52** .01.11 –.48** –.46* .21 . one as an intermediate. VMI–integration 5. Two of them were identified as slow writers. and cognitive planning ability were evaluated. Unimanual Dexterity 4.21 . p < .13 –. Note. However.17 . pant #20.13 . beta = –.47. VMI = Developmental Test of Visual-Motor Integration (Beery. and VMI–motor coordination and VMI–visual perception. particularly on the VMI–perception. in the HWP group. Pearson Correlation Coefficients for HWP Group and Control Group 1 2 3 4 . Part B (Reitan & Wolfson.02 . VMI–perception 6. p = . Individual Differences in the Group With HWP Twenty children with HWP were identified as slow writers.07 . Only in the HWP group. 1997). Volume 60. 1985). TMT-B –.08 –. including lack of a significant correlation between quality and speed of handwriting.05). Number 4 . T-tests did not reveal significant differences between this group classified as slow and the groups classified as intermediate and fast (N = 9) on any of the other dependent variables.08 . Note.11 –. Participant #16 (BHK = 41) and participant #20 (BHK = 31) were both classified as fast writers.24 .56** .47* –. and two as fast writers.16 . ** p < .20 –.05. BHK = Concise Assessment Scale for Children’s Handwriting (Hamstra-Bletz et al.22.48** 5 6 7 HWP Group (N = 29) 1. compared to matched control children. Examples of individual profiles of children with handwriting problems (HWP) based on Z-scores of the dependent variables (note that the zero-line is the average score of the control group). Children with handwriting difficulties were less proficient on all of these tests. Fine motor coordination. VMI = Developmental Test of Visual-Motor Integration (Beery. Participant #24 scores relatively worse. VMI–integration was the best and only significant predictor of handwriting quality (R 2 = .45* –. No significant correlations were found for handwriting speed and other variables for both groups.28 . the profiles of five children writing with different speeds are presented in Figure 1.42 Control Group (N = 20) * p < . VMI–motor coordination. TMT-B = Trail Making Test.15 –. The present study investigated the role of different processes that might underlie poor performance of handwriting in a group of children with handwriting difficulties. and poor on VMI–motor coordination. In the control group. and TMT-B) were conducted.25 . Regression Analyses of Handwriting Variables on Test Variables Discussion Stepwise regression analyses of the quality and speed of handwriting on the different test variables (Unimanual Dexterity.32 .01).38* . 1997). VMI–integration. t = –2.21.04 . None of the dependent variables significantly predicted speed of handwriting in the HWP or control group. This participant scored relatively well on the TMT-B.01 –. July/August 2006.18 –. beta = . but the individual profiles are rather similar with both participants performing relatively better on the TMTB. TMT-B = Trail Making Test. VMI–perception.19 .18 . 1987).12 –. Participant #16 scored clearly worse compared to partici456 Figure 1.21 . Dexterity. Furthermore.34 –.45.15. Unimanual Dexterity was the best and only significant predictor of handwriting quality (R 2 = .43 . In the HWP group.10 –..06 . Part B (Reitan & Wolfson.18 –. 1985). VMI–motor coordination 7.74. Participants #24 (BHK = 46) and #28 (BHK = 41) were both classified as slow writers.13 –. visual-motor integration. whereas participant #28 scores relatively well compared to the other children with HWP except for VMI–integration. HWP = handwriting problems. As an illustration of the individual differences in the HWP group with regard to the performance on the different tests. BHK–speed 3. visual perception. quality of handwriting was significantly correlated with VMI–integration. Unimanual Dexterity and VMI–motor coordination. t = 2.
Maeland. Weintraub & Graham. Further. 1992. 1992. Although visual perception is a prerequisite for copying a piece of text. visual-motor integration was the only significant predictor of handwriting quality in the HWP group. Interestingly. 1992. 1994). Karlsdottir & Stefansson. whereas upper limb speed and dexterity was a significant predictor in the normal-speed group.g. whereas unimanual dexterity was the best and only significant predictor in the control group.. their number was too small to compare them with children with poor general coordination abilities (Movement ABC test < 15th percentile).. Note that in the The American Journal of Occupational Therapy study by Maeland. Maeland. Tseng & Murray. 1997). visual-motor integration was not found to be a good predictor of handwriting performance (Marr & Cermak. but 5 children were even classified as fast writers.Stepwise linear regression analyses revealed that for quality of handwriting. unimanual dexterity was also significantly related to handwriting quality in the control group. Limitations of the Study First. However. were related to quality of handwriting in these children. In a recent study with children from grades 2 to 6. who found in kindergarten children a significant relationship between visual-motor integration and the ability to copy letters. The question is whether the underlying mechanism for both subtypes of children with handwriting problems is identical. Schoemaker et al. 1994. visual sequential memory and visual-motor integration were significant predictors of handwriting speed in the slow-speed group. No significant correlation between quality and speed of handwriting was found either in the HWP group or in the control group. the finding that 20 children with HWP scored below the 5th percentile and 6 children with HWP between the 5th and 15th percentile on the Movement ABC test indicates that deficits in motor execution dominate in this group of dysgraphic children. 2000). which is not in agreement with other studies (Hamstra-Bletz & Blöte. Rubin & Henderson. the sample consisted of a rather specific group. it did not explain inter-individual differences in the quality or speed of handwriting in children with handwriting problems (cf. it should be noted that the sample of children in the present study was rather small. 2002). no significant correlation between visual-motor coordination and quality of writing was found in the children classified as non-clumsy with handwriting difficulties. These results suggest that two different mechanisms underlie the handwriting performance in both groups. 2000) have often been suggested as an explanation for poor quality of handwriting. 1997. and findings cannot be generalized easily to children with handwriting difficulties who do not have distinct general motor-coordination problems (e. large inter-individual differences were found with regard to writing speed within the HWP group: the majority of the children were classified as slow writers. half of them showing handwriting difficulties as well. Smits-Engelsman et al. Although some of the children in the present study were classified as non-clumsy. Thus. The latter finding is in agreement with findings in the study by Maeland (1992). our findings are in agreement with the study by Tseng and Chow (2000) with respect to the strongest 457 . the present study confirms these findings. a group of slow and normal-speed writers were compared (Tseng & Chow. whereas unimanual dexterity was the only significant predictor in the control group. Quality of Handwriting Both a deficit in fine motor coordination (cf. Maeland also found that visual-motor integration was the best predictor of handwriting accuracy. SmitsEngelsman & Van Galen. Schoemaker & Smits-Engelsman. Maeland. Findings are also in agreement with those from the study by Weil and Amundson (1994). but not cognitive planning. besides age. The present study found that speed of handwriting was slower in children with handwriting difficulties. 2002. Speed of Handwriting There is no consensus in the literature whether children with handwriting difficulties have a slower speed of handwriting compared to matched controls. 2001). visual-motor integration was the best and only significant predictor in the HWP group. The finding that the HWP group scored lower on visual perception compared to controls is in agreement with other studies (Maeland. Given the fact that in the present study children with HWP that were—on average—slow-speed writers were compared with children with HWP who were normalspeed writers. However. because both fine motor coordination as measured by unimanual dexterity and visual-motor integration were significantly correlated with quality of handwriting in children with handwriting difficulties.. Moreover. in a more recent study with 5-year-old kindergartners. and that the underlying mechanism responsible for poor quality of handwriting in children with handwriting difficulties is related more to visual-motor integration processes than to fine-motor-control processes as such. This scoring might be an explanation for the finding that fine motor coordination and visual-motor integration. 1992. in this study it was found that. 1993. Tseng & Murray. 1982). 2001) and in visual-motor integration (cf. At first sight. in which a similar correlation between quality of handwriting and visual-motor integration was found in a group of children classified as clumsy (nowadays labeled DCD). However.
either in the HWP group or in the control group. Karlsdottir & Stefansson.. because of the small sample size. How this deficiency interferes with handwriting remains unclear. Weiss.. including visual-motor integration. and positive (association between fast handwriting and low handwriting quality scores) in the control group. however. this might explain why these subgroups of children with HWP did not differ on the trail-making test.g. but not in grade 2 (non-slow writers in grade 2 showed even lower scores). They suggested that slow writers rely strongly on visually directed processing. 1987).. Cognitive Function On average. 1993. Tseng and Chow (2000) concluded that the underlying mechanisms for the handwriting performance of slow-speed and normal-speed writers is different. might be indicative of visual-motor integration problems (e. Further. In other words. 2003). serial letter and number recall). Because accuracy in trail making was not demanded and unimanual movement speed did not significantly contribute to this difference. It is necessary to use more specific instruments to measure generic cognitive and specific language processes that might interfere with the handwriting quality and speed of children with handwriting difficulties. speed of handwriting was not related to quality of handwriting either in the HWP or in the control group. Suggestions for Further Research Because our sample consisted of a rather specific group of children with handwriting difficulties and distinct general July/August 2006. it seems that this result indeed reflects that cognitive planning (i. The present study. whereas long pauses in between writing down words or sentences might be indicative of more cognitive-related problems (e. negative (association between fast handwriting and poor quality) in the HWP group. Scores on the trail-making test did not significantly correlate with quality or speed of handwriting. but also should also focus on the process of handwriting (cf. One might have expected that these slow writers would perform also more slowly on the trail-making test. In the present study. As we explained earlier. Rosenblum. leading to slow speed of handwriting (cf. The HWP group and the control groups differed only with regard to the sign of the correlation.g. however. Furthermore. flexibility) in children with handwriting problems is less proficient compared to control children.predictors of handwriting performance. letter formation) rather than to handwriting speed. Number 4 . handwriting does not involve shifting between numerical and alphabetic sequences.. Wann. lack of working memory capacity). 5 out of 20 of the children with HWP who were identified as slow writers were grade 3 children. that is. Further (longitudinal) research is needed to investigate whether slow writers and non-slow writers represent two different subtypes of handwriting difficulties with different underlying mechanisms and developmental courses. this finding raises the question of whether slow writers remain impaired on visual-motor integration and whether non-slow writers do improve on visual-motor integration from grade 2 to grade 3. the finding that 4 out of 9 of the children with HWP who were classified as fast writers were all children from grade 2 raises the question of whether the handwriting quality of these children was not negatively influenced by their fast speed of writing. Comparison of the slow and non-slow writers in the group with HWP did not reveal any significant differences. in order to answer the question as to why children write slowly. 458 Rubin & Henderson. for example. children with HWP who were also classified as intermediate or fast writers clearly showed a deficit in visual-motor integration. showed that visual-motor integration is more related to the quality of handwriting (e. Volume 60. children with handwriting problems performed twice as long on the trail-making test than control children. It should be mentioned. Of course. 1986). but copying text as in the BHK does involve visual scanning and shifting between reading what to write and writing it onto paper. It has been suggested earlier that the quotient of the writing-down time and non-writing-down time might be a relevant predictor of handwriting difficulties (Wann & Jones. 2002. Relation Between Quality and Speed of Handwriting The finding of the present study that there is a low and nonsignificant relation between the quality and speed of handwriting both in children with and without handwriting difficulties is largely in line with other studies (HamstraBletz & Blöte. strong reliance on visual feedback). However. it was not reported in that study whether the slow-speed or normal-speed writers also suffered from poor quality of handwriting.e. Slowness during the writing down of words.e. However. Further research has to elucidate the role of cognitive function in children with handwriting difficulties.g. research not only should investigate the handwriting product. 1982). this shifting probably also taps working memory capacity (i. that the observed interaction effect of grade with speed of handwriting revealed that children with HWP who were non-slow writers performed better on the visual-motor integration task than slow writers in grade 3. Even the children with HWP who were identified as slow writers did not differ from the children with HWP who were classified as non-slow writers on any of the variables. Although we have to be cautious in drawing conclusions. Because we found an effect of grade on the TMT-B. & Parush..
Beery. 689–699. whereas visual-motor integration was the best predictor in children with handwriting problems. visual-motor integration. M. Journal of Educational Research. Graham. C. Karlsdottir. Denner. B. 22. (1964). (1993).. W.. & Swanson. 2 Children’s writing: Toward a process theory of the development of skilled writing (pp. and cognitive planning in comparison with children without handwriting problems. London: Psychological Corporation. another aspect that needs to be addressed in identifying underlying mechanisms of handwriting difficulties is the online analysis of the spatio-temporal processes of handwriting (i. (DSM-IV). & Stefansson. but also and foremost on improvement of visual-motor integration processes. Development of handwriting in primary school: A longitudinal study. L. children with handwriting difficulties who are classified as nonclumsy. W. A. Henderson. NJ: Modern Curriculum Press. & Sugden. Lisse.. 85. A. V. (2002). Y. D. Structural equation modelling of relationships among developmental skills and writing skills in primary. De Ajuriaguerra.. 759–770. Diagnostic and Statistical Manual of Mental Disorders. 518–528..). Rosenblum et al. DC: Author.. L. 57–81). W. Findings of this study suggest that intervention for children with handwriting difficulties should focus not only on improvement of fine motor coordination. & Berninger. 2003) in the handwriting of children with handwriting difficulties is one of the aspects that especially needs to be addressed. 87. (1993). D. L. S. Dickerson-Mayes. D. (1998). In J.. E. & Weintraub. 478–508. Hamstra-Bletz. Educational Psychology Review. Weintraub. R. (1997). no significant correlation between quality and speed of handwriting was found. Jongmans. de Bie. M. Graham. S. Graham. S. Berninger. Journal of Educational Psychology. Graham. The role of mechanics in composing of elementary school students: A new methodological approach. (1996). 8. & Schafer. R. (1994).g. V. B.. J. Hamstra-Bletz. Abott. & SmitsEngelsman. Washington. 1992) are needed to investigate whether the contribution of underlying mechanisms responsible for handwriting problems differ for such subtypes. The role of self-regulation and transcription skills in writing and writing development. Perceptual and Motor Skills. Conclusion Findings of the present study show that children with handwriting difficulties appear to perform less proficiently on measures of visual perception. Trail Making Test. V. Journal of Clinical and Experimental Neuropsychology. Maeland.. Abott. The best predictor of the quality of handwriting in children without handwriting problems appeared to be fine motor coordination. The American Journal of Occupational Therapy American Psychiatric Association.. (1998). L.. Hamstra-Bletz. cf. Butterfield (Vol.e. Berninger. Advances in cognition and educational practice: Vol.. replication studies that include different subtypes of dysgraphic children (e. P. M. 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