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Friday, August 10, 2012

The Angsting Thread (Law Review Edition, Autumn 2012)

Friends, the time has come when Redyip is visible.  You know what that means. Feel free to use the comments to share your information (and gripes or praise) about which law reviews have turned over, which ones haven't yet, and where you've heard from, and where you've not, and what you'd like Santa to bring you this coming Xmas, etc. It's the semi-annual angsting thread for the law review submission season. Have at it. And do it reasonably nicely, pretty please.

Update: Here is a link to the last page of comments.

 

Posted by Administrators on August 10, 2012 at 04:08 PM in Blogging, Law Review Review, Life of Law Schools, Peer-Reviewed Journals | Permalink

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Comments

Chicago ding

Posted by: Responder | Sep 18, 2012 12:05:55 PM

or to clarify, SCal Law, the most likely way that the young scholar with the top 10 article actually gets published in a top 10 journal is by submitting way outside the top 10 and expediting. the system is broken, but i'm not sure i see how this is unethical on an individual basis, anymore than it is unethical for me to take deductions on my tax returns despite knowing that the tax system is unfair.

Posted by: Anono | Sep 18, 2012 12:01:54 PM

SCal Law, you are describing a prisoner's dilemma (or maybe a stag hunt). The point is that the current system penalizes young scholars who don't play by the unwritten rules (submit everywhere).

Let me throw out another proposition: it is equally "unethical" to invest in corporations, investments, conduits, etc. that benefit from tax shelters that the rest of us don't have access to. Or to purchase goods and/or services from companies that engage in inhumane animal treatment practices or less-than-pristine labor practices. Discuss.

Posted by: Anono | Sep 18, 2012 11:58:46 AM

I think those who see no moral problem with it miss the point. Maybe there's no wrong done to the law review board, but there's a wrong done to other profs, especially young scholars.
For the sake of the argument, Let's assume there are two profs. One is a tenured prof at a top-10 law school that would take only a top-20 offer, but nevertheless submits to all the top-100. Because he is well-known, his article gets to be read quickly, and gets plenty of offers. However, his article is not that good to receive a top-20 offer, so he eventually withdraw all the offers he didn't intend to accept in the first place.
Then, there's a young scholar who just submitted the most innovative and wonderful article, which deserves to be published in a top-10 journal. However, since this young scholar is unknown, his article only gets to be read at the end. By the time he finally gets the top-70 offer, he expedites, but all the top-50 journals are already full.
Had the first prof not submitted his article to the top-100, the second article would have been read earlier, and receive the offer at a time when the top-50 journals are not yet full.

Posted by: SCalLaw | Sep 18, 2012 10:00:42 AM

But assuming the author expedited, that better offer didn't just fall out of the sky. That is, many if not most authors submit to low-ranked journals with the primary intention of generating expedites, knowing that it is extremely likely that they will, in fact, end up getting and accepting a better offer. Given that, does it really matter to the editor putting in time reading the article whether or not there was a remote theoretical possibility that the author would have published there had the better offer not come through? Editors know the drill. They realize that yields are low and that the large majority of authors will trade up. Further, they get the benefits of the job (a line on their resume and whatever intellectual value there is in reading and discussing law review articles) no matter how many of their offers are accepted.

I have always considered most behavior in this process to be a matter of courtesy, not ethics - i.e., it may be rude to waste editors' time, but no fraud is involved. The vehemence of the opinions to the contrary surprises me, however, and I guess it might cause me to rethink my position if this ever becomes a real issue for me.

At any rate, I'm out of this discussion, back to waiting to learn whether anyone can top the OK-but-not-great offer I'm now sitting on.

Posted by: expeditious | Sep 18, 2012 7:49:42 AM

@anon 4:53:11 exactly!

Posted by: anoff | Sep 18, 2012 5:00:51 AM

expeditious,

I find it amazing that you see no moral difference between turning down an offer because you got a better one (assuming that you would have taken the offer otherwise), and submitting with no intention of accepting any offer at all. The difference is quite plain: in one case, the editor is investing his time and effort in a gamble, which may or may not turn out well; in the other, there was never any chance of his effort having any reward.

If you see no moral difference, then you should see no moral difference between your stockbroker making a bad bet on your behalf and losing the money, and your stockbroker defrauding you out of the money. After all, in both cases you end up with no money at the end. But most people think there is a very significant difference between losing a good faith bet, and being the victim of bad faith fraud.

Posted by: anon | Sep 18, 2012 4:53:11 AM

Oh, and I should add that in my experience in the appointments process, candidates fairly frequently interview with lower-ranked schools purely as leverage to get a better offer. While I think that those people are jerks, I've never considered an ethical violation to be involved.

Posted by: expeditious | Sep 17, 2012 10:54:16 PM

I'm still not clear why it's OK to turn down a journal for a higher-ranked offer after expediting but not OK to get an offer, expedite unsuccessfully, and then decline it. If the second author is "using" the low-ranked journal, why isn't the first? It's just that the first author got luckier than the second. And I repeat: Offers often come with deadlines that preclude reasoned consideration with higher-ranked journals. If a low-ranked journal gives you a deadline too short for other journals to give your article reasoned consideration, is it OK to decline it on that basis?

From having worked on a journal as a law student and advised one as a professor, I can also say that the time input per article (even accepted ones) is often relatively modest, and that students sometimes find it worthwhile to discuss articles, even if they don't end in a publication. I can also say that the yield of most journals, especially those that do not use manipulative tactics, is quite low even well up in the first tier. Given those realities - and the fact that student editors generally know them - it is hard to make the case that much, if any, morally consequential "use" is involved.

The expedite process is distasteful in itself. But the problem seems to me with the whole system, and I find it hard to see why it's ethically required to put oneself at a significant disadvantage by refusing to do what is commonly done. Student editors could certainly put a stop to the whole thing by disregarding expedites.

(No offers, dings, or acknowledgements in ages here, so I have nothing to contribute to the on-topic portion of this thread.)

Posted by: expeditious | Sep 17, 2012 10:47:14 PM

I am with optimized. I do not submit to journals if I would not accept an offer from them. I am still untentured, but have done fine while adhering to this policy, which I recognize is not the norm. That does not mean the norm is justified, however. Imagine applying to a job that one has no intention of accepting, merely to leverage a better offer from a competitor or from one's current employer -- the suitor expends resources, holds off on making offers to legitimate candidates (who may choose something less desirable in the meantime), etc. One is pretty clearly using someone else as a means to one's ends, with no intention of ever, under any circumstances, making their effort and expenditure of resources worth it. Using someone solely as a means to one's end I have always thought was the definition of an ethical transgression, but maybe I am misinformed.

In any event, as to the purpose of this thread, I took a very high risk strategy this round and only submitted to T-20 (I submitted in a couple of waves from 8/7-8/15). Dings from Yale, HLR, Mich, Minn, Vandy, Chicago, UVA, Gtown. Vandy did not get to it before they were full, even though I submitted about an hour after they opened for business (I suppose they might actually have read it had I had an offer to expedite from, but such is life). The ding from Vandy was a couple of days ago but otherwise things have been silent for the past couple of weeks. I suppose I am still alive at a few places but I expect to be resubmitting in the Spring, perhaps not with the same strategy.

Good luck to everyone who is still looking for a happy home for their work.

Posted by: Alex Reinert | Sep 17, 2012 9:45:39 PM

G'town ding. Didn't even tell me how much they enjoyed reading my article. Refreshingly honest.

Posted by: anon | Sep 17, 2012 8:26:00 PM

Sorry to redivert the conversation, but I read the most recent page of comments with interest, since I've often had the same debate in real life. I'm one of those who believe there's something morally problematic about submitting to journals whose offers you would not accept. I believe this, partly, because I know it to be false that "everyone trades up." I do not always receive additional offers after a first offer. I do not like how I've felt when I have declined offers without better offers in hand; regardless of how many other people do this, I don't want to be the kind of person who does it. For this reason I've stopped submitting to journals I wouldn't publish in. That's why I accepted an offer a while ago this fall, even though I'd briefly hoped to receive an offer from a more prestigious school's journal. I'm heartened to see there are so many people out there who feel the same way. Best of luck to everyone still in the race.

Posted by: optimized | Sep 17, 2012 8:14:01 PM

Fine, anoff. Back to the purpose of this thread:

I received an offer from a top three specialty journal over the weekend. Then I expedited and received an immediate ding from Washington (Seattle) Law Review. Hastings and Boston College Law Reviews both acknowledged my expedite request, which I took to mean they are not yet full. I originally submitted late August.

Posted by: Midwest Prof | Sep 17, 2012 5:18:33 PM

I would happily respond and elaborate on some of these issues when this season is over. In the meanwhile, I'd appreciate some info about dings, offers, and full volumes. This was the original purpose of our angsting.

Posted by: anoff | Sep 17, 2012 5:09:03 PM

Last comment on this from my end.

@pleepleus: The biggest problem with the current system seems to be the overwhelming number of submissions out there. Everyone submits everything everywhere. I am assuming that a $20 fee would significantly reduce the total number of submissions. I would posit that if your work was good and well vetted, the old assumptions about how many journals you needed to submit to to get an acceptance would no longer hold.

Posted by: Another 8/15 Submitter | Sep 17, 2012 4:53:29 PM

I'm an aspiring scholar. I very thoroughly (some might say obsessively) vet my work before submitting it. If the fee for submitting an article were as high as you suggest, I wouldn't be able to afford to submit to journals, or at least not nearly enough journals to have a decent shot at getting an offer. Even the $2ish Expresso charges adds up to a fairly painful sum for those of us who don't have institutional support for submission fees.

Posted by: pleepleus | Sep 17, 2012 4:40:56 PM

@ILlaw, I have heard that argument. My counterargument: it would simply force new scholars to: a) more thoroughly vet their pieces before they submitted; and b) be more strategic about where they submit. This scheme might result in fewer SUBMISSIONS from young scholars, but I actually think it wouldn't negatively impact PLACEMENTS (and might actually help by ensuring that young scholars are read more by AEs).

As a recent entry to the Academy, I think the system right now is totally slanted towards established scholars. Young scholars have a tough time merely getting read. Anything to change that dynamic would be welcome.

Posted by: Another 8/15 Submitter | Sep 17, 2012 4:33:09 PM

@Another 8/15 Submitter - The problem is, that for tenured and other well-published professors this suggested fee will be paid for in full by the law school. You will end up deterring young scholars from submitting to higher-ranked journals, rather than deterring famous professors from submitting to lower-ranked journals they would not publish in.

Posted by: ILlaw | Sep 17, 2012 4:28:37 PM

Agree with expeditious and others. It's the rules of the game. I also have not yet done this (being new and not having had to do so yet), but it seems pretty clear that most top 50 journals don't read most articles without an expedite. Is this flawed? Absolutely. But I don't see how it's unethical.

My solution btw: Journals should charge some nominal fee ($20?) per submission, and also pay their articles editors some payment as well. Every article should thus be guaranteed a reading, and there would be less gaming of the system. Would there be inequity as far as who could afford to submit more? Sure, but I don't think any more than already exists.

Posted by: Another 8/15 Submitter | Sep 17, 2012 4:13:16 PM

But isn't the students' time equally wasted when an offeree successfully expedites to a higher-ranked journal and accepts the better offer? Since everyone trades up, students have some expectation that most of the work they do evaluating articles will not yield acceptances. Indeed, they can take that into account; editors at low-ranked journals can decide they won't waste time reviewing the work of Harvard professors.

I can see a much better case that it is unethical (or at least thoughtless) to _expedite_ to journals from which you wouldn't accept an offer, because then you are making a much bigger affirmative claim on someone's time.

Posted by: expeditious | Sep 17, 2012 3:41:24 PM

Isn't "It's unethical" argument pretty obvious? Reviewing submissions takes students' scarce time, which is valuable to editors and to other authors who want those students to consider their pieces. It's true that the non-intending submitter isn't promising to accept (or even consider accepting) any offer extended, but it can still be wrong to use up someone else's time, to the detriment not only of those people but also others, solely for the sake of ends they have no reason to share (viz. the submitter's publishing at a more desirable journal), without giving those whose time is being wasted any indication that that is what the non-intending submitter is doing.

Posted by: anonymous | Sep 17, 2012 3:29:21 PM

In the past I had to decline two offers from T2 journals w/o another offer at hand. I didn't feel I was doing anything unethical, and all the senior professors at my law school with whom I advised thought the same. In fact every one I talk to admits they submit to journals they would not accept offers from. These are the well-known rules of the game and the lower-ranked journals know the rules and act accordingly.
In fact, I know of only one professor who does not do that, but he is so well-published, and writes so perfectly, that he has the luxury of submitting only to the top 10 journals and he clearly states in his cover letter that he will accept the first offer that he gets, w/o expediting. But he's the exception. Everyone I talk to submit to journals from which they would not even consider to accept an offer, and everyone knows that. It is what it is.

Posted by: ILlaw | Sep 17, 2012 3:28:20 PM

Unethical how? Under the Model Rules of Professional Conduct? Under Contract law? Under something else? When I send an article to various journals, I am inviting offers. I am not making an offer. Nor am I making a promise. Some of you seem to be suggesting that my invitation to receive offers contains some sort of implied promise to accept should that be the only or "best" offer I receive. Is there a parallel for that in any other context? It does not work that way in admissions, in job searches, in well...nothing I can think of. So, I'm stuck. Although the practice of sending to T4 schools w/o an intention of accepting seems to trigger some level of discomfort, I can't put my finger on the source of that discomfort.

Posted by: tin man | Sep 17, 2012 3:22:31 PM

Midwest Prof: You agree that submitting to low-ranked journals with no intention of publishing with them is wrong. How is not withdrawing from low(er)-ranked journals one has no intention of publishing with any different? Sure, it may be beneficial for expediting to have multiple offers in hand, but obviously it's also beneficial for expediting to have one offer in hand, even if that offer comes from a low-ranked journal, and that's exactly why people submit to journals they have no intention to publish with in the first place. The two cases look ethically indistinguishable to me.

Posted by: anonymous | Sep 17, 2012 3:20:02 PM

I'm not making excuses. I just don't see how it's unethical in the first place. No submission letter I've ever seen contains a promise to accept an offer if made. Given that, how is declining all offers worse than expediting and receiving a better offer which you then accept? Would it be unethical to decline an offer if it's accompanied by a deadline that precludes it remaining under consideration at other journals?

I am genuinely curious and willing to be convinced. I've never done this (that is, decline an offer without a better one in hand) myself, so have no personal stake in the matter. But I would say that over half of my colleagues have done it, and the standard advice given by our administration to someone unhappy with an offer is to resubmit the next cycle.

And as an author, I only wish that I had any power to "set the rules of the game."

Posted by: expeditious | Sep 17, 2012 3:16:14 PM

Midwest Prof: I think the best course is to withdraw. That's usually the first thing I do when I get an offer--withdraw from all the journals I wouldn't accept an offer from anymore. It saves the journals needless time and effort reviewing a piece they won't get and frees up editor time to review submissions from folks not lucky enough to have an offer yet. Also, I doubt that higher ranked journals will be all that impressed by multiple offers from journals ranked about the same, or from an additional acceptance at a lower-ranked journal. There's surely some positive signal from multiple offers, but the signal is weak if there's no prestige gain from the new offer. And with little chance that your deadline will change materially, you risk irritating editors with too many/frequent expedites that provide too little information/change in circumstances.

Posted by: pleepleus | Sep 17, 2012 3:10:22 PM

I have to insist. Law professors should not respond to 22 y/o students' manipulations with counter-manipulations. They should be the role models and set the rules of the game. Submitting to journals with which you would not consider publishing is unethical. Trying to provide excuses for unethical practices is in itself an interesting intellectual exercise. But they remain excuses, not justifications.

Posted by: anoff | Sep 17, 2012 3:05:29 PM

I side with anoff @ 2:25:13 PM here. Just because folks do it, expeditious, does not make it acceptable as a normative matter.

Related to this question, I struggle with whether I should withdraw my submission from less desireable journal after I have received an offer that I am willing to accept, but have not yet accepted, from a more desireable journal. On one hand, once I have received the offer from a more desireable journal, the less desireable journal is not going to get my piece. On the other, additional offers (even from less desireable journals) will make my expedite requests up the ladder more appealing. Moreover, I originally submitted to the less desireable journal in good faith, with the intent to publish with them if I did not receive a better offer. Do I have an ethical obligation to withdraw or can I wait until my expedite process plays out?

Posted by: Midwest Prof | Sep 17, 2012 3:00:57 PM

So far, I have never had to decline an offer without a better one in hand, but I find the apparent consensus that the practice is unethical to be odd. My experience is that law review editors know the drill, and that many law reviews must make 4 or 5 offers for every one accepted. The practice of using low-ranked offers solely for expedites seems similar to me to the practice, on the journal side, of setting offer deadlines to pressure the author into accepting rather than because of any genuine need for a timely response. Both are certainly indicators of a broken system, but I don't see them as per se unethical.

Posted by: expeditious | Sep 17, 2012 2:46:45 PM

Submitting to journals with which one knows one would never publish is as unethical as faking expedites. Both cases involve fraudulent representations. You cannot play the pious with respect to latter while being manipulative and dishonest with respect to the former. If I were a journal editor, and a person to whom I extended an offer told me "I did not get other offers, so I withdraw" I would immediately put him/her on my black list.

Posted by: anoff | Sep 17, 2012 2:25:13 PM

This probably goes without saying, but submitting to the top 100, when one will only accept publication in the top 50, is equally unethical. Yet I suspect it happens quite a bit, in the hopes of an expedite. I am aware of several "seasoned" authors who have done just that.

Posted by: anon | Sep 17, 2012 1:06:17 PM

Faking an offer is probably grounds for dismissal or revocation of tenure. On top of being really, incredibly, amazingly, stupid.

Submitting to a journal that you have absolutely no present intention of ever publishing with likely doesn't rise to that level of opprobrium, but only because of the evidentiary problems. Seems to me, morally at least, your obligation is not to send it to a review you know ab initio you won't publish in. All instrumental rationalization to the contrary notwithstanding.

Posted by: Lurker | Sep 17, 2012 12:47:18 PM

Faking an offer is probably grounds for dismissal or revocation of tenure. On top of being really, incredibly, amazingly, stupid.

Submitting to a journal that you have absolutely no present intention of ever publishing with likely doesn't rise to that level of opprobrium, but only because of the evidentiary problems. Seems to me, morally at least, your obligation is not to send it to a review you know ab initio you won't publish in. All instrumental rationalization to the contrary notwithstanding.

Posted by: Lurker | Sep 17, 2012 12:47:14 PM

Well I'm glad we got that cleared up. Yes, submitting to journals from which you would likely not accept an offer feels a little unclean, but nothing of the magnitude of faking an offer. That would be academic suicide, agreed.

Posted by: Naive Nancy | Sep 17, 2012 12:42:33 PM

thanks for the clarification, Anon 12:03. I didn't mean to fan the flames of a rumor/misunderstanding. In any event, to the extent that one may believe submissions to T3/T4 schools when there's no intention to take an offer, if given, are necessary to earn a read from a T2 school, I hope my experience serves as evidence to the contrary.

Posted by: ericblair | Sep 17, 2012 12:14:12 PM

Someone needs to be amazingly stupid to fabricate an offer. Just for the mere chance that someone from an editorial board personally knows someone from another editorial board (which is not out of realm of possibilities), and says "hey, how come you made an offer to this guy." News about such things spread fast, and can bury one's career *forever*.
I would this an academic suicide-attempt.

Posted by: Arthur Dee Too | Sep 17, 2012 12:07:51 PM

To the extent I may have been interpreted as talking about fake expedites, I want to be clear - I was talking about SUBMISSIONS to T3 and T4 schools when there isnt an intention to take the offer (if given), not fake expedites. I believe they are a mythical wrong that do not actually happen, for obvious reasons. At least I hope they dont truly exist.

Posted by: Anon | Sep 17, 2012 12:03:31 PM

Oh my.

Posted by: anon | Sep 17, 2012 11:27:08 AM

I had never heard of such a creature until several days ago on this thread (in a comment by someone who confessed to being both drunk and despondent, as I recall), but yes, I assume that is what it means. But we could be talking about an entirely mythical being here. I hope that's the case.

Posted by: Naive Nancy | Sep 17, 2012 11:22:21 AM

Can you clarify what you mean by "fake expedite"? Surely you're not talking about fabricating an offer.

Posted by: anon | Sep 17, 2012 11:19:58 AM

@eb - We are on the same page; I just don't want the idea of fake expedites to gain any currency as an option. Call me naive (haha), but I like to think that a prof from a T3 or T4 school, or a practitioner, can get a placement by focusing on relevance and readability, and also by polishing the piece so that it looks as close to ready-to-publish as possible. As someone suggested earlier, strong cover letters and abstracts don't hurt, either.

Posted by: Naive Nancy | Sep 17, 2012 11:17:03 AM

Top 5 specialty offer off an expedite. Think this process may still have a little life left in it.

Posted by: Another 8/15 submitter | Sep 17, 2012 11:05:22 AM

T1 specialty journal offer yesterday; expedited; acknowledgment of expedite request and dings trickling in.

Question: can/should I withdraw from journals that have dinged me, to the end of cleaning up my list of school to expedite to so that I don't accidentally expedite to a school that has dinged me?

Posted by: Bacon Lover | Sep 17, 2012 11:03:29 AM

T3 offer this morning.

Posted by: Heavy | Sep 17, 2012 10:53:36 AM

Any dings or offers today?

Posted by: anoff | Sep 17, 2012 10:40:16 AM

Naive Nancy, I agree. I should be clear that I don't know whether this is happening (the fake expedites)--I am only referring to an earlier comment that seemed to suggest someone might be considering this. It was one comment and only speculative, so perhaps (and, like you, I hope) this is not actually happening and merely a subject of abstract musing. But, since someone suggested fake expediting might be necessary for law profs at T3 and T4 schools to get a look at their articles, I wanted to throw the fruits of my limited experience into the mix.

Posted by: ericblair | Sep 17, 2012 10:25:22 AM

Someone please tell me that fake expedites aren't a thing. That's awful. I mean, I realize what a horrible process this is, but that's fraud, essentially.

It never ceases to amaze me how incapable law students and law profs are at developing systems that are rational and fair. Shouldn't that be one of our strong points? We let systems evolve in perverse ways and then fiddle at the margins, instead of being bold enough to re-imagine them.

Posted by: Naive Nancy | Sep 17, 2012 10:04:12 AM

T2 offer over the weekend (not off an expedite). for what it's worth, in response to the comment suggesting T3 and T4 law profs might need to fake an expedite in order to get a read (I guess it depends where?), I am lower in the pecking order (teaching undergrads at a middle of the pack university) and this is the 2nd article that has been accepted (last one was in an earlier cycle). Not top 20 selections, but I am very happy.

Posted by: ericblair | Sep 17, 2012 9:42:12 AM

Cornell and Colorado full. Neither has rejected me, but they're full.

Posted by: Arthur Dee Too | Sep 17, 2012 7:07:20 AM

Columbia ding off an expedite.

Posted by: Pollyanna | Sep 17, 2012 4:00:55 AM

Common human decency and general rules of interaction between professional would say no. My inbox indicates otherwise...

Posted by: Anon | Sep 16, 2012 4:12:54 PM

Is it too much to ask that they send me a rejection notice when their journals are full, even if they never expedited my submission?

Posted by: another8/15 | Sep 16, 2012 2:10:29 PM

anoff's concerns have crossed my mind as well.

Posted by: anon | Sep 16, 2012 12:50:30 PM

Off an expedite.

Posted by: Another 8/15 submitter | Sep 16, 2012 12:39:36 PM

Rejections from Texas and Chicago over the weekend

Posted by: Another 8/15 submitter | Sep 16, 2012 12:39:28 PM

But are the journals sua sponte informing you that they're full or are these emails in response to expedites? I think many of us have articles submitted to some if these places and have heard nothing but silence.

Posted by: anon | Sep 16, 2012 9:50:44 AM

Their e-mails. I hope (for the sake of the entire profession) they are not telling some people that they are full, while extending publication offers to others.

Posted by: anoff | Sep 16, 2012 9:45:56 AM

Anoff - how are you getting this info?

Posted by: how | Sep 16, 2012 9:09:19 AM

UConn full.

Posted by: anoff | Sep 16, 2012 7:31:21 AM

Hmmm. Never thought about it that way, but it's certainly worth considering. One can always submit to a T4 with the hopes of a better expedite, and still decide to take the T4 if nothing materializes. Maybe expediting is, in itself, unethical. I thought, however, that the purpose of this game (and make no mistake, that's what it is) was to get the highest placement. T4 journals certainly know the game. They know that they will receive some excellent submissions from us no-names who teach at T4 schools. And they know that by making us an offer, they will likely not get to publish the article. "Thoughts," I admire your hard work and writing abilities, but I think you are wrong to suggest that a hard-working, intelligent T4 prof can get a high journal placement on ability alone. I'm not saying that it can't happen. Only that it is very unusul.

Posted by: Pollyanna | Sep 15, 2012 5:42:07 PM

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