The majority in Coleman relied on the reasoning of Tivis, which the court interpreted to mean that a conviction for second-degree robbery requires that the defendant "communicated, through affirmative conduct and/or words, an intent to immediately use physical force if the victim fails to deliver up the property or otherwise resists his taking of the property." (81) The Tivis opinion, summarized above, does not include the phrase "affirmative conduct," which makes the reasoning applied by a majority of the Western District especially novel.
(113) These factors include the presence of a weapon or behavior that would indicate the defendant had a weapon and the use of phrases such as "[t his is a holdup" or "stickup." (114) The court also noted Brooks's use of Tivis, (115) where the Western District held that there was not a threat of force sufficient for a conviction of second-degree robbery when the defendant yanked a purse off of the victim's shoulder.
Systemic barriers and issues that impact the rehabilitation of individuals with traumatic brain injury include difficulties in finding (1) access to services (Johnstone, Price, Bounds, Schopp, Schootman, & Schumate, 2003; Spearman, Stamm, & Tivis, 2007), (2) TBI expertise (Johnstone, Nossaman, Schopp, Holmquist, & Rupright, 2002), (3) coordinated approach to provide early access to services (Johnstone et al., 2002), and (4) employment (Sample & Langlois, 2005).
Not knowing about available services and resources was cited by Corrigan (2001) for Georgia, cited by Sample, Johns, Gabella, and Langlois (2004) for Colorado, cited by Leith, Phillips, and Sample (2004) for South Carolina, and cited by Spearman, Stamm, and Tivis (2007) for Idaho.
Participants were asked to rate the importance of substance abuse issues in their communities and to reflect on how effective carious approaches were in intervening in substance misuse (Jones-Saumty, Thomas, Phillips, Tivis
, & Nixon, 2003).
North, C., Tivis, L., McMillen, J., Pfefferbaum, B., Spitznagel, E.
Pfefferbaum, B., Nixon, S., Krug, R., Tivis, R., Moore, V., Brown, J., et al.
Pfefferbaum, B., Nixon, S., Tucker, P., Tivis
, R., Moore, V., Gurwitch, R.
NIXON, S.J.; LAWTON-CRADDOCK, A.; TIVIS
, R.; AND CEBALLOS, N.
and Galaver (1994) hypothesized that alcohol-hormone interaction may influence the development of alcohol-induced liver disease in postmenopausal women who are moderate to heavy drinkers.
Thus, alcohol use may exert its effects on the risk of CHD, osteoporosis, and breast cancer in part through increasing the production of endogenous estrogens (Tivis
and Gavaler 1994).
These deficits are most evident on tests of relatively complex cognitive function, such as the ability to follow abstract concepts or to adapt quickly to changing conditions (Tivis