The Chad Green case has again focused national and international attention on the unproven cancer remedy known as laetrile. Laetrile has attracted considerable attention in recent years as a result of claims that it is a nontoxic form of cancer treatment. Twenty-one states have legalized prescription of laetrile within their borders, despite the efforts of the Food and Drug Administration (FDA) to keep laetrile off the market.

The authors examine the claims about laetrile’s effectiveness and comment upon scientific tests concerning its efficacy. They maintain that scientific support for the use of laetrile is almost totally absent and that evidence of the dangers of laetrile is substantial. After reviewing the medical evidence concerning laetrile, the authors describe the efforts of laetrile proponents to use the courts as the battleground to legalize laetrile. In early skirmishes, laetrile proponents were successful in opposing the efforts of the FDA; under a constitutional privacy theory several courts upheld the right of competent adults to select laetrile therapy.

Subsequently, however, as the authors demonstrate, the U.S. Supreme Court, in United States v. Rutherford, and the California Supreme Court, in People v. Privitera, narrowed the federal constitutional privacy right by declining to read into it a right to take laetrile. Finally, the Massachusetts Supreme Judicial Court, in the Chad Green case, considered the question of laetrile’s toxicity to a recipient of the drug.

The authors discuss the interrelationship among the three cases. They argue that the overwhelming proof in Chad Green that laetrile is harmful undermines any statutory or constitutional claims supporting legalization, because such claims assume that even if laetrile is not truly therapeutic outside of the placebo effect, it is not toxic. In light of the three decisions, the authors conclude that supporters of laetrile should not expect that the courts will be sympathetic to future legal efforts to approve or to permit use of laetrile therapy.

The relations between physicians and lawyers have deteriorated rapidly over the past several decades, most particularly since the early 70s when the perception that a medical malpractice crisis existed in America became widespread. Some believe that the factors dividing the two professions are linked (1) to professional jealousy, (2) to sometimes conflicting economic interests, or (3) to difficulties in communication, since both professions use many of the same words, or terms of art, but with different intended meanings.

While the authors agree that these factors may have aggravated the problem, they believe that the conflict’s real roots are in the very different ways in which physicians and lawyers are trained and in the different epistemologies that each profession has accepted, as a result of which each reasons and solves problems in a manner that not only diverges from but sometimes contradicts the other’s. The authors conclude that only as the varying epistemologies begin to converge can physicians and lawyers begin to approach problems in more similar ways, and to discover the underlying compatibility of many of their interests and goals.

In Payton v. Abbott Laboratories, U.S. District Court Judge Walter J. Skinner recently granted class certification to an action brought by twentyseven Massachusetts women against major manufacturers of DES. This is the first case in which a judge has interpreted the requirements of Rule 23 of the Federal Rules of Civil Procedure to allow women exposed in utero to DES to sue as a class to determine liability for their injuries.

This Note reviews the Payton certification in light of prior class action decisions involving DES and other types of claims, and of legal commentary on Rule 23. This Note contends that Judge Skinner’s application of the Rule 23 requirements in Payton was procedurally correct, and recommends the class action device as an effective method for litigating such controversies. Finally, this Note analyzes the implications of this landmark ruling for plaintiffs seeking class certification in DES suits and in suits presenting analogous factual situations.

The Internal Revenue Service typically grants health maintenance organizations (HMOs) an I.R.C. section 501(c)(4) exemption from federal income taxation. If these prepayment group medical providers were classified as section 501 (c) (3) tax exempt organizations, however, they would receive many additional advantages including increases in private funding and decreases in material and operating costs.

This Note contends that most nonprofit HMOs—whether or not they have qualified under the federal HMO Act—should be granted 501(c)(3) status because they conform with all the specific requisites and general theoretical justifications of a “charitable purpose” tax exempt organization. Specifically, HMOs serve a tax exempt purpose by providing health care, by benefiting the community as a whole, and relieving the government of some of its public health burdens. HMOs comply with further requirements of section 501 (c)(3) and its accompanying I.R.C. regulations by serving a broad membership while avoiding insider control or commercial dealings. Therefore, if an organization is a nonprofit prepayment group practice health provider that serves a broad community and provides health benefits without insider control, it should receive a 501 (c)(3) tax exemption.

Several Massachusetts laws, including the recently enacted Patients’ Bill of Rights, protect the rights of nursing home patients. Although these laws address many of the problems that such patients face, they do not adequately meet all of the unique needs of this vulnerable group.

This Comment discusses safeguards afforded by current Massachusetts law that are particularly important for nursing home patients, and recommends improvements that would secure more adequate protection for their rights. The Comment also analyzes some of Massachusetts law’s shortcomings in implementation and enforcement, in forum selection and in limitations on standing, and suggests improvements in these areas. Finally, the Comment proposes the enactment of a comprehensive Bill of Rights for Nursing Home Patients in order to address their unique needs more adequately, and to eliminate the duplicative, vague, and confusing provisions contained in current law.