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John Marshall Harlan II

John Marshall Harlan (May 20, 1899 – December 29, 1971) was an American lawyer and jurist who served as an associate justice of the U.S. Supreme Court from 1955 to 1971. Harlan is usually called John Marshall Harlan II to distinguish him from his grandfather, John Marshall Harlan, who served on the U.S. Supreme Court from 1877 to 1911.

Harlan was a student at Upper Canada College and Appleby College and then at Princeton University. Awarded a Rhodes Scholarship, he studied law at Balliol College, Oxford. Upon his return to the U.S. in 1923 Harlan worked in the law firm of Root, Clark, Buckner & Howland while studying at New York Law School. Later he served as Assistant U.S. Attorney for the Southern District of New York and as Special Assistant Attorney General of New York. In 1954 Harlan was appointed to the United States Court of Appeals for the Second Circuit, and a year later president Dwight Eisenhower nominated Harlan to the United States Supreme Court following the death of Justice Robert H. Jackson.

Harlan is often characterized as a member of the conservative wing of the Warren Court. He advocated a limited role for the judiciary, remarking that the Supreme Court should not be considered "a general haven for reform movements". In general, Harlan adhered more closely to precedent, and was more reluctant to overturn legislation than many of his colleagues on the Court. He strongly disagreed with the doctrine of incorporation, which held that the provisions of the federal Bill of Rights applied to the state governments, not merely the Federal. At the same time, he advocated a broad interpretation of the Fourteenth Amendment's Due Process Clause, arguing that it protected a wide range of rights not expressly mentioned in the United States Constitution. Justice Harlan was gravely ill when he retired from the Supreme Court on September 23, 1971. He died from spinal cancer three months later on December 29, 1971. After Harlan's retirement, President Nixon appointed William Rehnquist to replace him.

Early life and career
John Marshall Harlan was born on May 20, 1899, in Chicago. He was the son of John Maynard Harlan, a Chicago lawyer and politician, and Elizabeth Flagg. He had three sisters. Historically, Harlan's family had been politically active. His forebear George Harlan served as one of the governors of Delaware during the seventeenth century; his great-grandfather James Harlan was a congressman during the 1830s; his grandfather, also John Marshall Harlan, was an associate justice of the United States Supreme Court from 1877 to 1911; and his uncle, James S. Harlan, was attorney general of Puerto Rico and then chairman of the Interstate Commerce Commission.

In his younger years, Harlan attended The Latin School of Chicago. He later attended two boarding high schools in the Toronto Area, Canada: Upper Canada College and Appleby College. Upon graduation from Appleby, Harlan returned to the U.S. and in 1916 enrolled at Princeton University. There, he was a member of the Ivy Club, served as an editor of The Daily Princetonian, and was class president during his junior and senior years. After graduating from the university in 1920 with an Artium Baccalaureus degree, he received a Rhodes Scholarship to attend Balliol College, Oxford, making him the first Rhodes Scholar to sit on the Supreme Court. He studied jurisprudence at Oxford for three years, returning from England in 1923. Upon his return to the United States, he began work with the law firm of Root, Clark, Buckner & Howland (which became Dewey & LeBoeuf), one of the leading law firms in the country, while studying law at New York Law School. He received his Bachelor of Laws in 1924 and earned admission to the bar in 1925.

Between 1925 and 1927, Harlan served as Assistant United States Attorney for the Southern District of New York, heading the district's Prohibition unit. He prosecuted Harry M. Daugherty, former United States Attorney General. In 1928, he was appointed Special Assistant Attorney General of New York, in which capacity he investigated a scandal involving sewer construction in Queens. He prosecuted Maurice E. Connolly, the Queens borough president, for his involvement in the affair. In 1930, Harlan returned to his old law firm, becoming a partner one year later. At the firm, he served as chief assistant for senior partner Emory Buckner and followed him into public service when Buckner was appointed United States Attorney for the Southern District of New York. As one of "Buckner's Boy Scouts", eager young Assistant United States Attorneys, Harlan worked on Prohibition cases, and swore off drinking except when the prosecutors visited the Harlan family fishing camp in Quebec, where Prohibition did not apply. Harlan remained in public service until 1930, and then returned to his firm. Buckner had also returned to the firm, and after Buckner's death, Harlan became the leading trial lawyer at the firm.

As a trial lawyer Harlan was involved in a number of famous cases. One such case was the conflict over the estate left after the death in 1931 of Ella Wendel, who had no heirs and left almost all her wealth, estimated at $30–100 million, to churches and charities. However, a number of claimants, most of them imposters, filed suits in state and federal courts seeking part of her fortune. Harlan acted as the main defender of her estate and will as well as the chief negotiator. Eventually a settlement among lawful claimants was reached in 1933. In the following years Harlan specialized in corporate law dealing with the cases like Randall v. Bailey, concerning the interpretation of state law governing distribution of corporate dividends. In 1940, he represented the New York Board of Higher Education unsuccessfully in the Bertrand Russell case in its efforts to retain Bertrand Russell on the faculty of the City College of New York; Russell was declared "morally unfit" to teach. The future justice also represented boxer Gene Tunney in a breach of contract suit brought by a would-be fight manager, a matter settled out of court.

In 1937, Harlan was one of five founders of a eugenics advocacy group called the Pioneer Fund, which had been formed to introduce Nazi ideas on eugenics to the United States. He had likely been invited into the group due to his expertise in non-profit organizations. Harlan served on the Pioneer Fund's board until 1954. He did not play a significant role in the fund.

During World War II, Harlan volunteered for military duty, serving as a colonel in the United States Army Air Forces from 1943 to 1945. He was the chief of the Operational Analysis Section of the Eighth Air Force in England. He won the Legion of Merit from the United States, and the Croix de Guerre from both France and Belgium. In 1946 Harlan returned to private law practice representing Du Pont family members against a federal antitrust lawsuit. In 1951, however, he returned to public service, serving as Chief Counsel to the New York State Crime Commission, where he investigated the relationship between organized crime and the state government as well as illegal gambling activities in New York and other areas. During this period Harlan also served as a committee chairman of the Association of the Bar of the City of New York, and to which he was later elected vice president. Harlan's main specialization at that time was corporate and antitrust law.

Personal life
In 1928, Harlan married Ethel Andrews, who was the daughter of Yale history professor Charles McLean Andrews. This was the second marriage for her. Ethel was originally married to New York architect Henry K. Murphy, who was twenty years her senior. After Ethel divorced Murphy in 1927, her brother John invited her to a Christmas party at Root, Clark, Buckner & Howland, where she was introduced to John Harlan. They saw each other regularly afterwards and married on November 10, 1928, in Farmington, Connecticut.

Harlan, a Presbyterian, maintained a New York City apartment, a summer home in Weston, Connecticut, and a fishing camp in Murray Bay, Quebec, a lifestyle he described as "awfully tame and correct". The justice played golf, favored tweeds, and wore a gold watch which had belonged to the first Justice Harlan. In addition to carrying his grandfather's watch, when he joined the Supreme Court he used the same furniture which had furnished his grandfather's chambers.

John and Ethel Harlan had one daughter, Evangeline Dillingham (born on February 2, 1932). She was married to Frank Dillingham of West Redding, Connecticut, until his death, and had five children. One of Eve's children, Amelia Newcomb, is the international news editor at The Christian Science Monitor and has two children: Harlan, named after John Marshall Harlan II, and Matthew Trevithick. Another daughter, Kate Dillingham, is a professional cellist and published author.

Second Circuit service
Harlan was nominated by President Dwight D. Eisenhower on January 13, 1954, to a seat on the United States Court of Appeals for the Second Circuit vacated by Judge Augustus Noble Hand. Harlan knew this court well, as he had often appeared before it and was friendly with many of the judges. He was confirmed by the United States Senate on February 9, 1954, and received his commission on the next day. His service terminated on March 27, 1955, due to his elevation to the Supreme Court.

Supreme Court service
Harlan was nominated by President Eisenhower on January 10, 1955, as an associate justice of the Supreme Court of the United States, to succeed Robert H. Jackson. On being nominated, the reticent Harlan called reporters into his chambers in New York, and stated, in full, "I am very deeply honored." He was confirmed by the Senate on March 16, 1955, by a 71–11 vote, and was sworn into office on March 28, 1955. Despite the brevity of his stay on the Second Circuit, Harlan would serve as the Circuit Justice responsible for the Second Circuit throughout his Supreme Court capacity, and, in that capacity, enjoyed attending the Circuit's annual conference, bringing his wife and catching up on the latest gossip. Additionally, he served as Circuit Justice for the Ninth Circuit from June 25 to June 26, 1963. He assumed retired status on September 23, 1971, serving in that capacity until his death on December 29, 1971.

Harlan's nomination came shortly after the Supreme Court handed down its landmark decision in Brown v. Board of Education, declaring segregation in public schools unconstitutional. James Eastland (the chairman of the United States Senate Committee on the Judiciary) and several other southern senators delayed his confirmation, because they (correctly) believed that he would support desegregation of the schools and civil rights. Unlike almost all previous Supreme Court nominees, Harlan appeared before the Senate Judiciary Committee to answer questions relating to his judicial views. Every Supreme Court nominee since Harlan has been questioned by the Judiciary Committee before confirmation. The Senate finally confirmed him on March 17, 1955, by a vote of 71–11. He took his seat on March 28, 1955. Of the eleven senators who voted against his appointment, nine were from the South. He was replaced on the Second Circuit by J. Edward Lumbard.

On the Supreme Court, Harlan often voted alongside Justice Felix Frankfurter, who was his principal mentor on the court. Some legal scholars even viewed him as "Frankfurter without mustard", though others recognize his own important contributions to the evolution of legal thought. Harlan was an ideological adversary—but close personal friend—of Justice Hugo Black, with whom he disagreed on a variety of issues, including the applicability of the Bill of Rights to the states, the Due Process Clause, and the Equal Protection Clause.

Justice Harlan was very close to the law clerks whom he hired, and continued to take an interest in them after they left his chambers to continue their legal careers. The justice would advise them on their careers, hold annual reunions, and place pictures of their children on his chambers' walls. He would say to them of the Warren Court, "We must consider this only temporary," that the Court had gone astray, but would soon right itself.

Justice Harlan is remembered by people who worked with him for his tolerance and civility. He treated his fellow Justices, clerks and attorneys representing parties with respect and consideration. While Justice Harlan often strongly objected to certain conclusions and arguments, he never criticized other justices or anybody else personally, and never said any disparaging words about someone's motivations and capacity. Harlan was reluctant to show emotion, and was never heard to complain about anything. Harlan was one of the intellectual leaders of the Warren Court. Harvard Constitutional law expert Paul Freund said of him:

"His thinking threw light in a very introspective way on the entire process of the judicial function. His decisions, beyond just the vote they represented, were sufficiently philosophical to be of enduring interest. He decided the case before him with that respect for its particulars, its special features, that marks alike the honest artist and the just judge."

Jurisprudence
Harlan's jurisprudence is often characterized as conservative. He held precedent to be of great importance, adhering to the principle of stare decisis more closely than many of his Supreme Court colleagues. Unlike Justice Black, he eschewed strict textualism. While he believed that the original intention of the Framers should play an important part in constitutional adjudication, he also held that broad phrases like "liberty" in the Due Process Clause could be given an evolving interpretation.

Harlan believed that most problems should be solved by the political process, and that the judiciary should play only a limited role. In his dissent to Reynolds v. Sims, he wrote:

"These decisions give support to a current mistaken view of the Constitution and the constitutional function of this court. This view, in short, is that every major social ill in this country can find its cure in some constitutional principle and that this court should take the lead in promoting reform when other branches of government fail to act. The Constitution is not a panacea for every blot upon the public welfare nor should this court, ordained as a judicial body, be thought of as a general haven of reform movements."

However, Harlan was not a social conservative. He wrote the plurality opinion in Manual Enterprises, Inc. v. Day, ruling that photographs of nude men are not obscene, one of the first major victories for the early gay rights movement. Despite Harlan's conservatism, he opposed the Vietnam War and along with Justices William O. Douglas, Potter Stewart and William J. Brennan Jr. unsuccessfully pushed for the Court to hear challenges to its legality.

Equal Protection Clause
The Supreme Court decided several important equal protection cases during the first years of Harlan's career. In these cases, Harlan regularly voted in favor of civil rights—similar to his grandfather, the only dissenting justice in the infamous Plessy v. Ferguson case.

He voted with the majority in Cooper v. Aaron, compelling defiant officials in Arkansas to desegregate public schools. He joined the opinion in Gomillion v. Lightfoot, which declared that states could not redraw political boundaries in order to reduce the voting power of African-Americans. Moreover, he joined the unanimous decision in Loving v. Virginia, which struck down state laws that banned interracial marriage.

Due Process Clause
Justice Harlan advocated a broad interpretation of the Fourteenth Amendment's Due Process Clause. He subscribed to the doctrine that the clause not only provided procedural guarantees, but also protected a wide range of fundamental rights, including those that were not specifically mentioned in the text of the Constitution. (See substantive due process.) However, as Justice Byron White noted in his dissenting opinion in Moore v. East Cleveland, "no one was more sensitive than Mr. Justice Harlan to any suggestion that his approach to the Due Process Clause would lead to judges 'roaming at large in the constitutional field'." Under Harlan's approach, judges would be limited in the Due Process area by "respect for the teachings of history, solid recognition of the basic values that underlie our society, and wise appreciation of the great roles that the doctrines of federalism and separation of powers have played in establishing and preserving American freedoms".

Harlan set forth his interpretation in an often cited dissenting opinion to Poe v. Ullman, which involved a challenge to a Connecticut law banning the use of contraceptives. The Supreme Court dismissed the case on technical grounds, holding that the case was not ripe for adjudication. Justice Harlan dissented from the dismissal, suggesting that the Court should have considered the merits of the case. Thereafter, he indicated his support for a broad view of the due process clause's reference to "liberty". He wrote, "This 'liberty' is not a series of isolated points pricked out in terms of the taking of property; the freedom of speech, press, and religion; the right to keep and bear arms; the freedom from unreasonable searches and seizures; and so on. It is a rational continuum which, broadly speaking, includes a freedom from all substantial arbitrary impositions and purposeless restraints." He suggested that the due process clause encompassed a right to privacy, and concluded that a prohibition on contraception violated this right.

The same law was challenged again in Griswold v. Connecticut. This time, the Supreme Court agreed to consider the case, and concluded that the law violated the Constitution. However, the decision was based not on the due process clause, but on the argument that a right to privacy was found in the "penumbras" of other provisions of the Bill of Rights. Justice Harlan concurred in the result, but criticized the Court for relying on the Bill of Rights in reaching its decision. "The Due Process Clause of the Fourteenth Amendment stands," he wrote, "on its own bottom." The Supreme Court would later adopt Harlan's approach, relying on the due process clause rather than the penumbras of the Bill of Rights in right to privacy cases such as Roe v. Wade and Lawrence v. Texas.

Harlan's interpretation of the Due Process Clause attracted the criticism of Justice Black, who rejected the idea that the Clause included a "substantive" component, considering this interpretation unjustifiably broad and historically unsound, one of the few issues in which Black was more conservative than Harlan. The Supreme Court has agreed with Harlan, and has continued to apply the doctrine of substantive due process in a wide variety of cases.

Incorporation
Justice Harlan was strongly opposed to the theory that the Fourteenth Amendment "incorporated" the Bill of Rights—that is, made the provisions of the Bill of Rights applicable to the states. His opinion on the matter was opposite to that of his grandfather, who supported the full incorporation of the Bill of Rights. When it was originally ratified, the Bill of Rights was binding only upon the federal government, as the Supreme Court ruled in the 1833 case Barron v. Baltimore. Some jurists argued that the Fourteenth Amendment made the entirety of the Bill of Rights binding upon the states as well. Harlan, however, rejected this doctrine, which he called "historically unfounded" in his Griswold concurrence.

Instead, Justice Harlan believed that the Fourteenth Amendment's due process clause only protected "fundamental" rights. Thus, if a guarantee of the Bill of Rights was "fundamental" or "implicit in the concept of ordered liberty," Harlan agreed that it applied to the states as well as the federal government. Thus, for example, Harlan believed that the First Amendment's free speech clause applied to the states, but that the Fifth Amendment's self-incrimination clause did not.

Harlan's approach was largely similar to that of Justices Benjamin Cardozo and Felix Frankfurter. It drew criticism from Justice Black, a proponent of the total incorporation theory. Black claimed that the process of identifying some rights as more "fundamental" than others was largely arbitrary, and depended on each Justice's personal opinions.

The Supreme Court has eventually adopted some elements of Harlan's approach, holding that only some Bill of Rights guarantees were applicable against the states—the doctrine known as selective incorporation. However, under Chief Justice Earl Warren during the 1960s, an increasing number of rights were deemed sufficiently fundamental for incorporation (Harlan regularly dissented from these rulings). Hence, the majority of provisions from the Bill of Rights have been extended to the states; the exceptions are the Third Amendment, the grand jury clause of the Fifth Amendment, the Seventh Amendment, the Ninth Amendment, and the Tenth Amendment. Thus, although the Supreme Court has agreed with Harlan's general reasoning, the result of its jurisprudence is very different from what Harlan advocated.

First Amendment
Justice Harlan supported many of the Warren Court's landmark decisions relating to the separation of church and state. For instance, he voted in favor of the Court's ruling that the states could not use religious tests as qualifications for public office in Torcaso v. Watkins. He joined in Engel v. Vitale, which declared that it was unconstitutional for states to require the recitation of official prayers in public schools. In Epperson v. Arkansas, he similarly voted to strike down an Arkansas law banning the teaching of evolution.

In many cases, Harlan took a fairly broad view of First Amendment rights such as the freedom of speech and of the press, although he thought that the First Amendment applied directly only to the federal government. According to Harlan the freedom of speech was among the "fundamental principles of liberty and justice" and therefore applicable also to states, but less stringently than to the national government. Moreover, Justice Harlan believed that federal laws censoring "obscene" publications violated the free speech clause. Thus, he dissented from Roth v. United States, in which the Supreme Court upheld the validity of a federal obscenity law. At the same time, Harlan did not believe that the Constitution prevented the states from censoring obscenity. He explained in his Roth dissent:

"The danger is perhaps not great if the people of one State, through their legislature, decide that Lady Chatterley's Lover goes so far beyond the acceptable standards of candor that it will be deemed offensive and non-sellable, for the State next door is still free to make its own choice. At least we do not have one uniform standard. But the dangers to free thought and expression are truly great if the Federal Government imposes a blanket ban over the Nation on such a book. ... The fact that the people of one State cannot read some of the works of D. H. Lawrence seems to me, if not wise or desirable, at least acceptable. But that no person in the United States should be allowed to do so seems to me to be intolerable, and violative of both the letter and spirit of the First Amendment."

Harlan concurred in New York Times Co. v. Sullivan, which required public officials suing newspapers for libel to prove that the publisher had acted with "actual malice." This stringent standard made it much more difficult for public officials to win libel cases. He did not, however, go as far as Justices Hugo Black and William O. Douglas, who suggested that all libel laws were unconstitutional. In Street v. New York, Harlan wrote the opinion of the court, ruling that the government could not punish an individual for insulting the American flag. In 1969 he noted that the Supreme Court had consistently "rejected all manner of prior restraint on publication."

When Harlan was a Circuit Judge in 1955, he authorized the decision upholding the conviction of leaders of the Communist Party USA (including Elizabeth Gurley Flynn) under the Smith Act. The ruling was based on the previous Supreme Court's decisions, by which the Court of Appeals was bound. Later, when he was a Supreme Court justice, Harlan, however, wrote an opinion overturning the conviction of Communist Party activists as unconstitutional in the case of Yates v. United States. Another such case was Watkins v. United States.

Harlan penned the majority opinion in Cohen v. California, holding that wearing a jacket emblazoned with the words "Fuck the Draft" was speech protected by the First Amendment. His opinion was later described by constitutional law expert Professor Yale Kamisar as one of the greatest ever written on freedom of expression. In the Cohen opinion, Harlan famously wrote "one man's vulgarity is another's lyric," a quote that was later denounced by Robert Bork as "moral relativism".

Justice Harlan is credited for establishing that the First Amendment protects the freedom of association. In NAACP v. Alabama, Justice Harlan delivered the opinion of the court, invalidating an Alabama law that required the NAACP to disclose membership lists. However he did not believe that individuals were entitled to exercise their First Amendment rights wherever they pleased. He joined in Adderley v. Florida, which controversially upheld a trespassing conviction for protesters who demonstrated on government property. He dissented from Brown v. Louisiana, in which the Court held that protesters were entitled to engage in a sit-in at a public library. Likewise, he disagreed with Tinker v. Des Moines, in which the Supreme Court ruled that students had the right to wear armbands (as a form of protest) in public schools.

Criminal procedure
During the 1960s the Warren Court made a series of rulings expanding the rights of criminal defendants. In some instances, Justice Harlan concurred in the result, while in many other cases he found himself in dissent. Harlan was usually joined by the other moderate members of the Court: Justices Potter Stewart, Tom Clark, and Byron White.

Most notably, Harlan dissented from Supreme Court rulings restricting interrogation techniques used by law enforcement officers. For example, he dissented from the Court's holding in Escobedo v. Illinois, that the police could not refuse to honor a suspect's request to consult with his lawyer during an interrogation. Harlan called the rule "ill-conceived" and suggested that it "unjustifiably fetters perfectly legitimate methods of criminal law enforcement." He disagreed with Miranda v. Arizona, which required law enforcement officials to warn a suspect of his rights before questioning him (see Miranda warning). He closed his dissenting opinion with a quotation from his predecessor, Justice Robert H. Jackson: "This Court is forever adding new stories to the temples of constitutional law, and the temples have a way of collapsing when one story too many is added."

In Gideon v. Wainwright, Justice Harlan agreed that the Constitution required states to provide attorneys for defendants who could not afford their own counsel. However, he believed that this requirement applied only at trial, and not on appeal; thus, he dissented from Douglas v. California.

Harlan wrote the majority opinion in Leary v. United States—a case that declared the Marijuana Tax Act unconstitutional based on the Fifth Amendment protection against self-incrimination.

Justice Harlan's concurrence in Katz v. United States set forth the test for determining whether government conduct constituted a search. In this case the Supreme Court held that eavesdropping on the petitioner's telephone conversation constituted a search in the meaning of the Fourth Amendment and thus required a warrant. According to Justice Harlan, there is a two-part requirement for a search: (1) that the individual have a subjective expectation of privacy; and (2) that the individual's expectation of privacy is "one that society is prepared to recognize as 'reasonable.'"

Voting rights
Justice Harlan rejected the theory that the Constitution enshrined the so-called "one man, one vote" principle, or the principle that legislative districts must be roughly equal in population. In this regard, he shared the views of Justice Felix Frankfurter, who in Colegrove v. Green admonished the courts to stay out of the "political thicket" of reapportionment. The Supreme Court, however, disagreed with Harlan in a series of rulings during the 1960s. The first case in this line of rulings was Baker v. Carr. The Court ruled that the courts had jurisdiction over malapportionment issues and therefore were entitled to review the validity of district boundaries. Harlan, however, dissented, on the grounds that the plaintiffs failed to demonstrate that malapportionment violated their individual rights.

Then, in Wesberry v. Sanders, the Supreme Court, relying on the Constitution's requirement that the United States House of Representatives be elected "by the People of the several States," ruled that congressional districts in any particular state must be approximately equal in population. Harlan vigorously dissented, writing, "I had not expected to witness the day when the Supreme Court of the United States would render a decision which casts grave doubt on the constitutionality of the composition of the House of Representatives. It is not an exaggeration to say that such is the effect of today's decision." He proceeded to argue that the Court's decision was inconsistent with both the history and text of the Constitution; moreover, he claimed that only Congress, not the judiciary, had the power to require congressional districts with equal populations.

Harlan was the sole dissenter in Reynolds v. Sims, in which the Court relied on the Equal Protection Clause to extend the one man, one vote principle to state legislative districts. He analyzed the language and history of the Fourteenth Amendment, and concluded that the Equal Protection Clause was never intended to encompass voting rights. Because the Fifteenth Amendment would have been superfluous if the Fourteenth Amendment (the basis of the reapportionment decisions) had conferred a general right to vote, he claimed that the Constitution did not require states to adhere to the one man, one vote principle, and that the Court was merely imposing its own political theories on the nation. He suggested, in addition, that the problem of malapportionment was one that should be solved by the political process, and not by litigation. He wrote:

"This Court, limited in function in accordance with that premise, does not serve its high purpose when it exceeds its authority, even to satisfy justified impatience with the slow workings of the political process. For when, in the name of constitutional interpretation, the Court adds something to the Constitution that was deliberately excluded from it, the Court, in reality, substitutes its view of what should be so for the amending process."

For similar reasons, Harlan dissented from Carrington v. Rash, in which the Court held that voter qualifications were subject to scrutiny under the equal protection clause. He claimed in his dissent, "the Court totally ignores, as it did in last Term's reapportionment cases ... all the history of the Fourteenth Amendment and the course of judicial decisions which together plainly show that the Equal Protection Clause was not intended to touch state electoral matters." Similarly, Justice Harlan disagreed with the Court's ruling in Harper v. Virginia Board of Elections, invalidating the use of the poll tax as a qualification to vote.

Retirement and death
John M. Harlan's health began to deteriorate towards the end of his career. His eyesight began to fail during the late 1960s. To cover this, he would bring materials to within an inch of his eyes, and have clerks and his wife read to him (once when the Court took an obscenity case, a chagrined Harlan had his wife read him Lady Chatterley's Lover). Gravely ill, he retired from the Supreme Court on September 23, 1971.

Harlan died from spinal cancer three months later, on December 29, 1971. He was buried at the Emmanuel Church Cemetery in Weston, Connecticut. President Richard Nixon considered nominating Mildred Lillie, a California appeals court judge, to fill the vacant seat; Lillie would have been the first female nominee to the Supreme Court. However, Nixon decided against Lillie's nomination after the American Bar Association found Lillie to be unqualified. Thereafter, Nixon nominated William Rehnquist (a future Chief Justice), who was confirmed by the Senate.

Despite his many dissents, Harlan has been described as one of the most influential Supreme Court justices of the twentieth century. He was elected a Fellow of the American Academy of Arts and Sciences in 1960. Harlan's extensive professional and Supreme Court papers (343 cubic feet) were donated to Princeton University, where they are housed at the Seeley G. Mudd Manuscript Library and open to research. Other papers repose at several other libraries. Ethel Harlan, his wife, outlived him by only a few months and died on June 12, 1972. She suffered from Alzheimer's disease for the last seven years of her life.

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Hashimoto's thyroiditis

Hashimoto's thyroiditis, also known as chronic lymphocytic thyroiditis and Hashimoto's disease, is an autoimmune disease in which the thyroid gland is gradually destroyed. A slightly broader term is autoimmune thyroiditis, identical other than that it is also used to describe a similar condition without a goiter.

Early on, symptoms may not be noticed. Over time, the thyroid may enlarge, forming a painless goiter. Some people eventually develop hypothyroidism with accompanying weight gain, fatigue, constipation, depression, hair loss, and general pains. After many years the thyroid typically shrinks in size. Potential complications include thyroid lymphoma. Furthermore, because it is common for untreated patients of Hashimoto's to develop hypothyroidism, further complications can include, but are not limited to, high cholesterol, heart disease, heart failure, high blood pressure, myxedema, and potential pregnancy problems.

Hashimoto's thyroiditis is thought to be due to a combination of genetic and environmental factors. Risk factors include a family history of the condition and having another autoimmune disease. Diagnosis is confirmed with blood tests for TSH, T4, and antithyroid autoantibodies. Other conditions that can produce similar symptoms include Graves' disease and nontoxic nodular goiter.

Hashimoto's thyroiditis is typically treated with levothyroxine. If hypothyroidism is not present, some may recommend no treatment, while others may treat to try to reduce the size of the goiter. Those affected should avoid eating large amounts of iodine; however, sufficient iodine is required especially during pregnancy. Surgery is rarely required to treat the goiter.

Hashimoto's thyroiditis affects about 5% of Caucasians at some point in their lives. It is the most common cause of hypothyroidism in iodine-sufficient areas of the world. It typically begins between the ages of 30 and 50 and is much more common in women than men. Rates of the disease appear to be increasing. It was first described by the Japanese physician Hakaru Hashimoto in 1912. In 1957, it was recognized as an autoimmune disorder.

Signs and symptoms

Many symptoms are attributed to the development of Hashimoto's thyroiditis. The most common symptoms include: fatigue, weight gain, pale or puffy face, feeling cold, joint and muscle pain, constipation, dry and thinning hair, heavy menstrual flow or irregular periods, depression, panic disorder, a slowed heart rate, and problems getting pregnant and miscarriages.

Some patients in the early stage of the disease may experience symptoms of hyperthyroidism due to the release of thyroid hormones from intermittent thyroid destruction.

Hashimoto's disease is about seven times more common in women than in men. It can occur in teens and young women, but more commonly appears in middle age, particularly for men. People who develop Hashimoto's disease often have family members who have thyroid or other autoimmune diseases, and sometimes have other autoimmune diseases themselves.

Early stages of autoimmune thyroiditis may have a normal physical exam with or without a goiter. A goiter is a diffuse, often symmetric, swelling of the thyroid gland visible in the anterior neck that may develop. The thyroid gland may become firm, large, and lobulated in Hashimoto's thyroiditis, but changes in the thyroid can also be nonpalpable. Enlargement of the thyroid is due to lymphocytic infiltration and fibrosis, rather than tissue hypertrophy. While their role in the initial destruction of the follicles is unclear, antibodies against thyroid peroxidase  or thyroglobulin are relevant, as they serve as markers for detecting the disease and its severity. They are thought to be the secondary products of the T cell-mediated destruction of the gland.

As lymphocytic infiltration progresses, patients may exhibit signs of hypothyroidism in multiple bodily systems, including, but not limited to, a larger goiter, weight gain, cold intolerance, fatigue, myxedema, constipation, menstrual disturbances, pale or dry skin, and dry, brittle hair, depression, ataxia, and muscle weakness.

Patients with goiters who have had autoimmune thyroiditis for many years might see their goiter shrink in the later stages of the disease due to destruction of the thyroid.

While rare, more serious complications of the hypothyroidism resulting from autoimmune thyroiditis are pericardial effusion, pleural effusion, both of which require further medical attention, and myxedema coma, which is an endocrine emergency.

Relationship to other autoimmune conditions
Graves disease may occur before or after the development of autoimmune thyroiditis. Patients may also have coexisting autoimmune conditions of other organs. These may include Addison disease, type 1 diabetes, Sjogren's syndrome, Celiac disease, and rheumatoid arthritis. Autoimmune thyroiditis has also been seen in patients with autoimmune polyendocrine syndromes type 1 and 2.

Genetics
Thyroid autoimmunity can be familial. Many patients report a family history of autoimmune thyroiditis or Graves disease. Twin studies have revealed a concordance of Hashimoto's disease in monozygotic twins.

Risk factors
The strong genetic component is borne out in studies on monozygotic twins, with a concordance of 38–55%, with an even higher concordance of circulating thyroid antibodies not in relation to clinical presentation (up to 80% in monozygotic twins). Neither result was seen to a similar degree in dizygotic twins, offering strong favour for high genetic aetiology.

Medications that influence thyroid function
Certain medications or drugs have been associated with altering and interfering with thyroid function. Of these drugs, there are two main mechanisms of interference that they can have.

One of the mechanisms of interference is when a drug alters thyroid hormone serum transfer proteins. Estrogen, tamoxifen, heroin, methadone, clofibrate, 5-flurouracile, mitotane, and perphenazine all increase thyroid binding globulin (TBG) concentration. Androgens, anabolic steroids such as danazol, glucocorticoids, and slow release nicotinic acid all decrease TBG concentrations. Furosemide, fenoflenac, mefenamic acid, salicylates, phenytoin, diazepam, sulphonylureas, free fatty acids, and heparin all interfere with thyroid hormone binding to TBG and/or transthyretin.

The other mechanism that medications can utilize to interfere with thyroid function would be to alter extra-thryoidal metabolism of thyroid hormone. Propylthiouracil, glucocorticoids, propranolol, iondinated contrast agents, amiodarone, and clomipramine all inhibit conversion of T4 and T3. Phenobarbital, rifampin, phenytoin and carbamazepine all increase hepatic metabolism. Finally, cholestryamine, colestipol, aluminium hydroxide, ferrous sulphate, and sucralfate are all drugs that decrease T4 absorption or enhance excretion.

HLA genes
The first gene locus associated with autoimmune thyroid disease was major histocompatibility complex (MHC) region on chromosome 6p21. It encodes HLAs. Specific HLA alleles have a higher affinity to autoantigenic thyroidal peptides and can contribute to autoimmune thyroid disease development. Specifically, in Hashimoto's disease, aberrant expression of HLA II on thyrocytes has been demonstrated. They can present thyroid autoantigens and initiate autoimmune thyroid disease. Susceptibility alleles are not consistent in Hashimoto's disease. In Caucasians, various alleles are reported to be associated with the disease, including DR3, DR5 and DQ7.

CTLA-4 genes
This gene is the second major immune-regulatory gene related to autoimmune thyroid disease. CTLA-4 gene polymorphisms may contribute to the reduced inhibition of T-cell proliferation and increase susceptibility to autoimmune response. CTLA-4 is a major thyroid autoantibody susceptibility gene. A linkage of the CTLA-4 region to the presence of thyroid autoantibodies was demonstrated by a whole-genome linkage analysis. CTLA-4 was confirmed as the main locus for thyroid autoantibodies.

Protein tyrosine phosphatase nonreceptor-type 22 gene
PTPN22 is the most recently identified immune-regulatory gene associated with autoimmune thyroid disease. It is located on chromosome 1p13 and expressed in lymphocytes. It acts as a negative regulator of T-cell activation. Mutation in this gene is a risk factor for many autoimmune diseases. Weaker T-cell signaling may lead to impaired thymic deletion of autoreactive T cells, and increased PTPN22 function may result in inhibition of regulatory T cells, which protect against autoimmunity.

Immune-related genes
IFN-γ promotes cell-mediated cytotoxicity against thyroid mutations causing increased production of IFN-γ were associated with the severity of hypothyroidism. Severe hypothyroidism is associated with mutations leading to lower production of IL-4 (Th2 cytokine suppressing cell-mediated autoimmunity), lower secretion of TGF-β (inhibitor of cytokine production), and mutations of FoxP3, an essential regulatory factor for the Tregs development. Development of Hashimoto's disease was associated with mutation of the gene for TNF-α (stimulator of the IFN-γ production), causing its higher concentration.

Preventable environmental factors, including high iodine intake, selenium deficiency, and infectious diseases and certain drugs, have been implicated in the development of autoimmune thyroid disease in genetically predisposed individuals.

Iodine
Excessive iodine intake is a well-established environmental factor for triggering thyroid autoimmunity. Thyroid autoantibodies are found to be more prevalent in geographical areas with a higher dietary iodine levels. Several mechanisms by which iodine may promote thyroid autoimmunity have been proposed. Iodine exposure leads to higher iodination of thyroglobulin, increasing its immunogenicity by creating new iodine-containing epitopes or exposing cryptic epitopes. It may facilitate presentation by APC, enhance the binding affinity of the T-cell receptor, and activate specific T-cells.

Iodine exposure has been shown to increase the level of reactive oxygen species. They enhance the expression of the intracellular adhesion molecule-1 on the thyroid follicular cells, which could attract the immunocompetent cells into the thyroid gland.

Iodine is toxic to thyrocytes since highly reactive oxygen species may bind to membrane lipids and proteins. It causes thyrocyte damage and the release of autoantigens. Iodine also promotes follicular cell apoptosis and has an influence on immune cells (augmented maturation of dendritic cells, increased number of T cells, stimulated B-cell immunoglobulin production).

Data from the Danish Investigation of Iodine Intake and Thyroid Disease shows that within two cohorts (males, females) with moderate and mild iodine deficiency, the levels of both thyroid peroxidase and thyroglobulin antibodies are higher in females, and prevalence rates of both antibodies increase with age.

Sex
Study of healthy Danish twins divided to three groups (monozygotic and dizygotic same sex, and opposite sex twin pairs) estimated that genetic contribution to thyroid peroxidase antibodies susceptibility was 61% in males and 72% in females, and contribution to thyroglobulin antibodies susceptibility was 39% in males and 75% in females.

The high female predominance in thyroid autoimmunity may be associated with the X chromosome. It contains sex and immune-related genes responsible for immune tolerance. A higher incidence of thyroid autoimmunity was reported in patients with a higher rate of X-chromosome monosomy in peripheral white blood cells.

Another potential mechanism might be skewed X-chromosome inactivation, leading to the escape of X-linked self-antigens from presentation in the thymus and loss of T-cell tolerance.

Having other autoimmune diseases is a risk factor for developing Hashimoto's thyroiditis, and the opposite is also true. Autoimmune diseases most commonly associated to Hashimoto's thyroiditis include celiac disease, type 1 diabetes, vitiligo, and alopecia.

The genes implicated vary in different ethnic groups and the incidence is increased in people with chromosomal disorders, including Turner, Down, and Klinefelter syndromes usually associated with autoantibodies against thyroglobulin and thyroperoxidase. Progressive depletion of these cells as the cytotoxic immune response leads to higher degrees of primary hypothyroidism, presenting with low T3/T4 levels, and compensatory elevations of TSH.

Pathophysiology
The mechanism of autoimmune thyroiditis is not well understood, but is thought to develop as a result of a complex interaction of genetics and environmental factors. Thyroid autoantibodies appear mostly with the presence of lymphocytes in the targeted organ. Lymphocytes produce antibodies targeting three different thyroid proteins: Thyroid peroxidase Antibodies (TPOAb), Thyroglobulin Antibodies (TgAb), and Thyroid stimulating hormone receptor Antibodies (TRAb). The antibody attacks ultimately lead to hypothyroidism, which is caused by replacement of follicular cells with parenchymatous tissue.

The two antibodies most commonly implicated in autoimmune thyroiditis are antibodies against thyroid peroxidase (TPOAb) and thyroglobulin (TgAb). They are hypothesized to develop as a result of thyroid damage, where T-lymphocytes are sensitized to residual thyroid peroxidase and thyroglobulin, rather than as the cause of thyroid damage. However, they may exacerbate further thyroid destruction by binding the complement system and triggering apoptosis of thyroid cells. Environmental factors that may predispose patients to this type of immune dysregulation include toxins, medications, dietary factors, and infectious agents.

Some patients who are healthy or asymptomatic may be positive for more than one of these antibodies. Doctors who attend to such patients will most likely monitor these patients as there is a chance that they will develop some type of dysfunction with time.

Gross morphological changes within the thyroid are seen in the general enlargement, which is far more locally nodular and irregular than more diffuse patterns (such as that of hyperthyroidism). While the capsule is intact and the gland itself is still distinct from surrounding tissue, microscopic examination can provide a more revealing indication of the level of damage.

Pathology
Gross pathology of a thyroid with autoimmune thyroiditis may show an symmetrically enlarged thyroid. It is often paler in color, in comparison to normal thyroid tissue which is reddish-brown. Microscopic examination will show infiltration of lymphocytes and plasma cells. The lymphocytes are predominately T-lymphocytes with a representation of both CD4 positive and CD8 positive cells. The plasma cells are polyclonal, with present germinal centers resembling the structure of a lymph node. Fibrous tissue may be found throughout the affected thyroid as well. Generally, pathological findings of the thyroid are related to the amount of existing thyroid function - the more infiltration and fibrosis, the less likely a patient will have normal thyroid function. In late stages of the disease, the thyroid may be atrophic.

Histologically, the hypersensitivity is seen as diffuse parenchymal infiltration by lymphocytes, particularly plasma B-cells, which can often be seen as secondary lymphoid follicles (germinal centers, not to be confused with the normally present colloid-filled follicles that constitute the thyroid). Atrophy of the colloid bodies is lined by Hürthle cells, cells with intensely eosinophilic, granular cytoplasm, a metaplasia from the normal cuboidal cells that constitute the lining of the thyroid follicles. Severe thyroid atrophy presents often with denser fibrotic bands of collagen that remains within the confines of the thyroid capsule.

It is also characterized by invasion of the thyroid tissue by leukocytes, mainly T-lymphocytes. A rare but serious complication is thyroid lymphoma, generally the B-cell type, non-Hodgkin lymphoma.

Diagnosis

Diagnosis is usually made by detecting elevated levels of antithyroid peroxidase antibodies in the serum, but seronegative (without circulating autoantibodies) thyroiditis is also possible. An ultrasound may be useful in detecting Hashimoto thyroiditis, especially in those with seronegative thyroiditis, due to key features detected in the ultrasound of a person with Hashimoto's thyroiditis, such as "echogenicity, heterogeneity, hypervascularity, and presence of small cysts."

Various tests can be chosen depending on the presenting symptoms. For patients with autoimmune thyroiditis, while it is known that many patients may have circulating antibodies before they present with any symptoms, patients may present to their doctors for evaluation with symptoms of hypothyroidism. Physicians will often start by assessing reported symptoms and performing a thorough physical exam, including a neck exam.

Given the relatively nonspecific symptoms of initial hypothyroidism, Hashimoto's thyroiditis is often misdiagnosed as depression, cyclothymia, premenstrual syndrome, chronic fatigue syndrome, fibromyalgia, and less frequently, as erectile dysfunction or an anxiety disorder. On gross examination, a hard goiter that is not painful to the touch often presents; other symptoms seen with hypothyroidism, such as periorbital myxedema, depend on the current state of progression of the response, especially given the usually gradual development of clinically relevant hypothyroidism. Testing for thyroid-stimulating hormone (TSH), free T3, free T4, and the antithyroglobulin antibodies (anti-Tg), antithyroid peroxidase antibodies (anti-TPO, or TPOAb) and antimicrosomal antibodies can help obtain an accurate diagnosis. Earlier assessment of the person may present with elevated levels of thyroglobulin owing to transient thyrotoxicosis, as inflammation within the thyroid causes damage to the integrity of thyroid follicle storage of thyroglobulin; TSH secretion from the anterior pituitary increases in response to a decrease in negative feedback inhibition secondary to decreased serum thyroid hormones. Typically, T4 is the preferred thyroid hormone test for hypothyroidism. This exposure of the body to substantial amounts of previously isolated thyroid enzymes is thought to contribute to the exacerbation of tolerance breakdown, giving rise to the more pronounced symptoms seen later in the disease. Lymphocytic infiltration of the thyrocyte-associated tissues often leads to the histologically significant finding of germinal center development within the thyroid gland.

Hashimoto's when presenting as mania is known as Prasad's syndrome after Ashok Prasad, the psychiatrist who first described it.

Laboratory values
The initial diagnostic evaluation will start with plasma thyroid-stimulating hormone (TSH) concentration. If elevated, it signifies hypothyroidism. The elevation is usually a marked increase over the normal range and is generally greater than 20 mg/dl. Free T4 levels will usually be lowered, but sometimes might be normal.

Doctors may check thyroglobulin antibodies (TgAb) whenever a thyroglobulin test is performed to see if the antibody is interfering. TgAb may also be ordered in regular intervals after a person has been diagnosed with thyroid cancer, and just like TPOAb, it can be associated with Hashimoto's thyroiditis. The most common complement of lab values in patients with autoimmune thyroiditis are high TSH, low T4, and positive TPO antibodies.

Ultrasound
When patients have normal laboratory values but symptoms of autoimmune thyroiditis, ultrasound plays a role in diagnosis. Images obtained with ultrasound can evaluate the size of the thyroid and further support the diagnosis of autoimmune thyroiditis, reveal the presence of nodules, or provide clues to the diagnosis of other thyroid conditions. A nuclear medicine Thyroid uptake and scan can also be helpful in diagnosing thyroid function.

Managing hormone levels
Hypothyroidism caused by Hashimoto's thyroiditis is treated with thyroid hormone replacement agents such as levothyroxine, triiodothyronine, or desiccated thyroid extract. A tablet taken once a day generally keeps the thyroid hormone levels normal. In most cases, the treatment needs to be taken for the rest of the person's life. If hypothyroidism is caused by Hashimoto's thyroiditis, the TSH levels may be recommended to be kept under 3.0 mIU/l.

The standard of care is levothyroxine therapy, which is an oral medication structured like endogenous T4. Levothyroxine can be dosed based upon weight, most commonly, or TSH elevation. Usually the dose prescribed ranges from 1.6 mcg/kg to 1.8 mcg/kg, but can be adjusted based upon each patient. For example, the dose may be lowered for elderly patients or patients with certain cardiac conditions, but should be increased in pregnant patients. It should be administered on a consistent schedule. Some patients elect combination therapy with both levothyroxine and liothyronine, which is a synthetic T3, however studies of combination therapy are limited.

Side effects of thyroid replacement therapy are associated with iatrogenic hyperthyroidism. Symptoms to watch out for include, but are not limited to, anxiety, tremor, weight loss, heat sensitivity, diarrhea, and shortness of breath. More worrisome symptoms include atrial fibrillation and bone density loss.

Monitoring
TSH is the laboratory value of choice for monitoring response to treatment with levothyroixine. When treatment is first initiated, TSH levels may be monitored as often as a frequency of every 6–8 weeks. Each time the dose is adjusted, TSH levels may be measured at that frequency until the correct dose is determined. Once titrated to a proper dose, TSH levels will be monitored yearly.

Surgery considerations
Surgery is not the initial treatment of choice for autoimmune disease, and uncomplicated Hashimoto's thyroidits is not an indication for thyroidectomy. Patients generally may discuss surgery with their doctor if they are experiencing significant pressure symptoms, or cosmetic concerns, or have nodules present on ultrasound. One well-conducted study of patients with troublesome general symptoms and with anti-thyroperoxidase (anti-TPO) levels greater than 1000 IU/ml (normal <100 IU/ml) showed that total thyroidectomy caused the symptoms to resolve, but there were post-operative complications in 14%.

Prognosis
Overt, symptomatic thyroid dysfunction is the most common complication, with about 5% of people with subclinical hypothyroidism and chronic autoimmune thyroiditis progressing to thyroid failure every year. Transient periods of thyrotoxicosis (over-activity of the thyroid) sometimes occur, and rarely the illness may progress to full hyperthyroid Graves' disease with active orbitopathy (bulging, inflamed eyes). Rare cases of fibrous autoimmune thyroiditis present with severe shortness of breath and difficulty swallowing, resembling aggressive thyroid tumors, but such symptoms always improve with surgery or corticosteroid therapy. Although primary thyroid B-cell lymphoma affects fewer than one in 1000 persons, it is more likely to affect those with long-standing autoimmune thyroiditis, as there is a 67- to 80-fold increased risk of developing primary thyroid lymphoma in patients with Hashimoto's thyroiditis.

Epidemiology
Hashimoto's thyroiditis disorder is thought to be the most common cause of primary hypothyroidism in North America. Within person, place, and time descriptive trends of epidemiology, it becomes more clear on how Hashimoto's thyroiditis develops in and impacts differing populations.

Autoimmune thyroiditis is the most common cause of hypothyroidism in settings of sufficient iodine. It is estimated to affect 2% of the world's population. It may affect up to 5% of the United States' population. Anyone may develop this disease, but autoimmune thyroiditis affects women more often than men by about 10 times. The difference in prevalence amongst genders is due to the effects of sex hormones. Incidence peaks in the fifth decade of life, but patients are usually diagnosed between age 30–50.

High iodine consumption
Autoimmune thyroiditis has a higher prevalence in societies that have a higher intake of iodine in their diet, such as the United States and Japan. It is the most common cause of hypothyroidism in areas of sufficient iodine. Also, the rate of lymphocytic infiltration increased in areas where the iodine intake was once low, but increased due to iodine supplementation.

Age
It has been shown that "the prevalence of positive tests for thyroid antibodies increases with age, with a frequency as high as 33 percent in women 70 years old or older." Incidence peaks in the fifth decade of life and the prevalence increases with age.

Personal characteristic trends
Overall, Hashimoto's thyroiditis affects up to 2% of the general population. About 5% of Caucasians will develop Hashimoto's at some point in their lives. In the US, the African-American population experiences it less commonly but has greater associated mortality. It is also less frequent in Asian populations. About 1.0 to 1.5 in 1000 people have this disease at any time. It occurs between 8 and 15 times more often in women than in men. Some research suggests a connection to the role of the placenta as an explanation for the sex difference. Though it may occur at any age, including in children, it is most often observed in women between 30 and 60 years of age. The highest prevalence from one study was found in the elderly members of the community.

Those that already have an autoimmune disease are at greater risk of developing Hashimoto's as the diseases generally coexist with each other. Common diseases seen coexisting with Hashimoto's include celiac disease, multiple sclerosis, type 1 diabetes, vitiligo, and rheumatoid arthritis.

Congenital hypothyroidism affects 1 in 3500-4000 newborns at birth and is a version of intellectual disability that can be treated if caught early, but can be hard to diagnose given that symptoms are minimal at a young age. Congenital hypothyroidism is generally caused by defects of the thyroid gland, but for most cases in Europe, Asia, and Africa, the iodine intake can cause hypothyroidism in newborns.

Geographic influence of dietary trends
Diets consisting of low or high iodine intake determine a population's risk of developing thyroid-related disorders. It is more common in regions of high iodine dietary intake, and among people who are genetically susceptible. Geography plays a large role in which regions have access to diets with low or high iodine. Iodine levels in both water and salt should be heavily monitored in order to protect at-risk populations from developing hypothyroidism.

Geographic trends of hypothyroidism vary across the world as different places have different ways of defining disease and reporting cases. Populations that are spread out or defined poorly may skew data in unexpected ways.

Iodine deficiency disorder (IDD) is combated using an increase in iodine in a person's diet. When a dramatic change occurs in a person's diet, they become more at-risk of developing hypothyroidism and other thyroid disorders. Combatting IDD with high salt intakes should be done carefully and cautiously as risk for Hashimoto's may increase. If making modifications to one's diet, it is important to use a clinician's discretion to ensure that the dietary changes are the best option as recommendations can vary person to person.

Secular trends
The secular trends of hypothyroidism reveal how the disease has changed over the course of time given changes in technology and treatment options. Even though ultrasound technology and treatment options have improved, the incidence of hypothyroidism has increased according to data focused on the US and Europe. Between 1993 and 2001, per 1000 women, the disease was found varying between 3.9 and 4.89. Between 1994 and 2001, per 1000 men, the disease increased from 0.65 to 1.01.

Changes in the definition of hypothyroidism and treatment options modify the incidence and prevalence of the disease overall. Treatment using levothyroxine is individualized, and therefore allows the disease to be more manageable with time but does not work as a cure for the disease.

History
Also known as Hashimoto's disease, Hashimoto's thyroiditis is named after Japanese physician Hakaru Hashimoto (1881−1934) of the medical school at Kyushu University, who first described the symptoms of persons with struma lymphomatosa, an intense infiltration of lymphocytes within the thyroid, in 1912 in the German journal called Archiv für Klinische Chirurgie. This paper was made up of 30 pages and 5 illustrations all describing the histological changes in the thyroid tissue. Furthermore, all results in his first study were collected from four women. These results explained the pathological characteristics observed in these women especially the infiltration of lymphoid and plasma cells as well as the formation of lymphoid follicles with germinal centers, fibrosis, degenerated thyroid epithelial cells and leukocytes in the lumen. He described these traits to be histologically similar to those of Mikulic's disease. As mentioned above, once he discovered these traits in this new disease, he named the disease struma lymphomatosa. This disease emphasized the lymphoid cell infiltration and formation of the lymphoid follicles with germinal centers, neither of which had ever been previously reported.

Despite Dr. Hashimoto's discovery and publication, the disease was not recognized as distinct from Reidel's thyroiditis, which was a common disease at that time in Europe. Although many other articles were reported and published by other researchers, Hashimoto's struma lymphomatosa was only recognized as an early phase of Reidel's thyroiditis in the early 1900s. It was not until 1931 that the disease was recognized as a disease in its own right, when researchers Allen Graham et al. from Cleveland reported its symptoms and presentation in the same detailed manner as Hakaru.

In 1956, Drs. Rose and Witebsky were able to demonstrate how immunization of certain rodents with extracts of other rodents' thyroid resembled the disease Hakaru and other researchers were trying to describe. These doctors were also able to describe anti-thyroglobulin antibodies in blood serum samples from these same animals.

Later on in the same year, researchers from the Middlesex Hospital in London were able to perform human experiments on patients who presented with similar symptoms. They purified anti-thyroglobulin antibody from their serum and were able to conclude that these sick patients had an immunological reaction to human thyroglobulin. From this data, it was proposed that Hashimoto's struma could be an autoimmune disease of the thyroid gland.

In 1957, it was recognized as an autoimmune disorder and was the first organ-specific autoimmune disorder identified.

Following this recognition, the same researchers from Middlesex Hospital published an article in 1962 in The Lancet that included a portrait of Hakaru Hashimoto. The disease became more well known from that moment, and Hashimoto's disease started to appear more frequently in textbooks.

Since those discoveries, a number of autoimmune diseases have been discovered, with several of them having to do with thyroid-specific antibodies.

Pregnancy
Pregnant women who are positive for Hashimoto's thyroiditis may have decreased thyroid function or the gland may fail entirely. If a woman is TPOAb-positive, clinicians can inform her of the risks for herself and her infant if the disease goes untreated. "Thyroid peroxidase antibodies (TPOAb) are detected in 10% of pregnant women", which presents risks to those pregnancies. Women who have low thyroid function that has not been stabilized are at greater risk of having an infant with: low birth weight, neonatal respiratory distress, hydrocephalus, hypospadias, miscarriage, and preterm delivery. The embryo transplantion rate and successful pregnancy outcomes are improved when Hashimoto's is treated. Recommendations are to treat pregnant women only if they are TPOAb-positive throughout the entirety of their pregnancies and to screen all pregnant women for thyroid levels. Close cooperation between the endocrinologist and obstetrician benefits the woman and the infant. The Endocrine Society recommends screening in pregnant women who are considered high-risk for thyroid autoimmune disease.

Thyroid peroxides antibodies testing is recommended for women who have ever been pregnant regardless of pregnancy outcome. "[P]revious pregnancy plays a major role in development of autoimmune overt hypothyroidism in premenopausal women, and the number of previous pregnancies should be taken into account when evaluating the risk of hypothyroidism in a young women [sic]."

Hormonal changes and trophoblast expression of key immunomodulatory molecules lead to immunosuppression and fetal tolerance. Main players in regulation of the immune response are Tregs. Both cell-mediated and humoral immune responses are attenuated, resulting in immune tolerance and suppression of autoimmunity. It has been reported that during pregnancy, levels of thyroid peroxidase and thyroglobulin antibodies decrease. After giving birth, Tregs rapidly decrease and immune responses are re-established. It may lead to the occurrence or aggravation of the autoimmune thyroid disease. In up to 50% of females with thyroid peroxidase antibodies in the early pregnancy, thyroid autoimmunity in the postpartum period exacerbates in the form of postpartum thyroiditis. Higher secretion of IFN-γ and IL-4, and lower plasma cortisol concentration during pregnancy has been reported in females with postpartum thyroiditis than in healthy females. It indicates that weaker immunosuppression during pregnancy could contribute to the postpartum thyroid dysfunction.

Fetal microchimerism
Several years after the delivery, the chimeric male cells can be detected in the maternal peripheral blood, thyroid, lung, skin, or lymph nodes. The fetal immune cells in the maternal thyroid gland may become activated and act as a trigger that may initiate or exaggerate the autoimmune thyroid disease. In Hashimoto's disease patients, fetal microchimeric cells were detected in thyroid in significantly higher numbers than in healthy females.

Other organisms
Hashimoto's disease is also known in chickens (Gallus domesticus), rats (Rattus rattus), mice (Mus musculus), dogs (Canis familiaris), and marmosets (Callitrichidae).

title: Hashimoto's thyroiditis


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Mark Whiten

Mark Anthony Whiten (born November 25, 1966) is an American former professional baseball outfielder and switch-hitting batter, who played in Major League Baseball (MLB) for the Toronto Blue Jays (1990–1991), Cleveland Indians (1991–1992, 1998–2000), St. Louis Cardinals (1993–1994), Boston Red Sox (1995), Philadelphia Phillies (1996), Atlanta Braves (1996), Seattle Mariners (1996), and New York Yankees (1997). He became known by the nickname "Hard-Hittin'" Mark Whiten. In 1993, Whiten became the 12th player in major league history to hit four home runs in a single game and tied the all-time single game RBI record with 12.

Early life
Whiten was born in Pensacola, Florida on November 25, 1966. He did not play baseball competitively until his senior year at Pensacola High School but managed to earn a scholarship to play baseball at Pensacola State College.

Toronto Blue Jays and Cleveland Indians
He was selected by Toronto in the 1986 amateur draft and made his major league debut in the 1990 season. Whiten was an up-and-down player. He had one of the best outfield arms in the 1990s. He hit for power too, but his mental lapses hurt him in the field and at the plate. The Blue Jays had little patience with his development and sent him to Cleveland. After two seasons with the Indians he was sent to the Cardinals.

St. Louis Cardinals
In his first season with St. Louis, Whiten recorded nine outfield assists, fifth-best in the National League. On September 7, 1993, he gained notability with his performance against the Cincinnati Reds in the second game of a doubleheader. Whiten hit four home runs and drove in 12 runs, tying the all-time single-game records in both categories in the process. He also tied the major league mark for runs batted in in a doubleheader (13), set by Nate Colbert in 1972. Whiten became the 12th player in major league history to hit four home runs in one game; he and Jim Bottomley are the only two players with 12 RBI in one game.

During the same season, he belted a 464-foot homer into the upper deck at Three Rivers Stadium, becoming the first visiting player to reach the right-field overhang. He finished that year with a .253 batting average, to go along with 25 home runs and 99 RBI.

Later career
Whiten suffered through pulled rib cage muscles early at the 1994 season that limited him to play in 92 games. Injuries would limit him to no more than 136 games a season. Over the following six seasons, he played for six teams, including a second stint with Cleveland. In 1997, Whiten faced sexual assault charges while playing with the New York Yankees. On July 31, 1998, Whiten pitched his only inning of professional ball, for Cleveland against the Oakland Athletics. He walked two and gave up a hit and an earned run, but also struck out the side (which included future AL MVP Miguel Tejada). He thus has a perfect career K/9 ratio of 27.

In his 11-year major-league career, Whiten had a .259 batting average, with 105 home runs, 423 RBIs, 465 runs scored, 804 hits, 129 doubles, 20 triples, and 70 stolen bases in 939 games. He resumed his playing career with the Long Island Ducks in the Atlantic League.

title: Mark Whiten


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SAP Center

The SAP Center at San Jose (originally known as San Jose Arena and the HP Pavilion at San Jose) is an indoor arena located in San Jose, California. Its primary tenant is the San Jose Sharks of the National Hockey League, for which the arena has earned the nickname "The Shark Tank".

History
Plans for a San Jose arena began in the mid-1980s, when a group of local citizens formed Fund Arena Now (FAN). The group contacted city officials and pursued potential sponsors and partners from the NHL and NBA. In the late 1980s, mayor Tom McEnery met with FAN, and subsequently a measure to allocate local taxes for arena construction came up for a public vote on June 7, 1988, passing by a narrow margin.

In 1991, soon after construction began, the NHL granted an expansion franchise to San Jose. After it was discovered that the arena would not be suitable for NBA or NHL use as originally designed, the Sharks requested an upgrade to NHL standards, including the addition of luxury suites, a press box, and increased seating capacity.

In 1993, the arena was completed and initially named the "San Jose Arena".

For the 1996–97 NBA season, the arena served as home to the Golden State Warriors while their regular home court in Oakland (now known as Oakland Arena) was under renovation.

In 2001, naming rights were sold to Compaq, and it was renamed "Compaq Center at San Jose" (not to be confused with the Compaq Center (formerly The Summit) in Houston, Texas). After HP purchased Compaq in 2002, the arena was renamed "HP Pavilion", the same name as one of its computer models.

In late April 2007, it was announced that the HP Pavilion at San Jose would be receiving several building improvements, including a new center-hung LED video display system from Daktronics similar to that of the TD Garden, home of the Boston Bruins of the NHL.

In June 2013, German software company SAP (co-founded by Sharks managing partner Hasso Plattner, who is also SAP's chairman of the board) purchased the naming rights to the facility in a five-year deal worth US$3.35 million per year. The arena was renamed "SAP Center at San Jose" upon approval by the San Jose City Council.

In September 2022, a new center-hung system from Daktronics that doubled the surface of the old video display system was debuted ahead of the 2022-23 NHL season. The four main LED displays measure approximately 23 feet high by 41 feet wide and the size of the 14 newly installed displays total at more than 9,300 square feet of surface area.

In April 2023, construction was announced on a new 10,000-square-foot penthouse lounge, with seven suites and three rows of regular seating being converted to accommodate the project. With the new premium seating completed, the arena's total attendance capacity for hockey games changed from 17,562 to 17,435.

Events
In 2006, the SAP Center sold the most tickets (633,435) to non-sporting events of any venue in the Western United States, and the fourth highest total in the world, after Madison Square Garden in New York City (US), the Manchester Arena in Manchester (UK), and Scotiabank Arena in Toronto (Canada).

Other events hosted at the arena include the 1996 United States Figure Skating Championships, the 47th National Hockey League All-Star Game in 1997, the 1999 NCAA Women's Final Four, ArenaBowl XVI in 2002, the 2007 USA Gymnastics Visa Championships, and UFC 139 on November 19, 2011. Intel Extreme Masters Season IX – San Jose in 2014 and Intel Extreme Masters Season X – San Jose were held at the venue. Prior to Super Bowl 50 in nearby Santa Clara, the arena housed introductory media activities for the event. The SAP Center hosted games 3, 4, and 6 of the 2016 Stanley Cup Finals in the Sharks' first appearance in franchise history, with the Cup being presented to the series-winning Pittsburgh Penguins after game 6. In 2012 and 2016, the arena played host to the USA Gymnastics Olympic Trials. The arena was the host to the West Regional semifinals and finals of the 2002, 2007, and 2017 NCAA men's basketball tournaments; as well as first- and second-round games of the 2010, 2013, and 2019 tournaments.

Mixed Martial Arts events have played a big role at the SAP Center. The MMA organization Strikeforce held many events in San Jose beginning with Strikeforce: Shamrock vs. Gracie in 2006, then Strikeforce: Carano vs. Cyborg in 2009, through 2012 with Strikeforce: Barnett vs. Cormier. The first Bellator MMA organization event at SAP was Bellator MMA & Glory: Dynamite 1 in September 2015 and since has held 6 total events with the most recent being Bellator 199 on May 16, 2018. SAP Center has also been the host of premiere MMA promotion the UFC. The first event was UFC 139 on November 19, 2011, then UFC on Fuel TV: Muñoz vs. Weidman on July 11, 2012, UFC on Fox: Henderson vs. Melendez on April 20, 2013, and most recently UFC on Fox: Lawler vs. Brown on July 26, 2014.

On September 18, 2016, the arena hosted the Kellogg's Tour of Gymnastics Champions.

The annual US Figure Skating Championships have been staged here in San Jose five times now — 1996, 2012, 2018, 2021 and 2023.

SAP Center has also hosted WWE Pay Per Views. Royal Rumble (1998), SummerSlam (2001), The Great American Bash (2007), Payback (2017) took place where Braun Strowman defeated Roman Reigns in the main event. TLC: Tables, Ladders & Chairs (2018) took place at SAP Center.

title: SAP Center


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San Jose SaberCats

The San Jose SaberCats were a professional arena football team based in San Jose, California. The SaberCats had been members of the Arena Football League (AFL) since 1995 (the year in which the team was founded); and until 2015, they belonged to the AFL's National Conference. Over nineteen seasons of play, the SaberCats emerged as one of the Arena Football League's most successful franchises; at the conclusion of the 2015 season, the SaberCats boasted a lifetime regular season record of 198–98. Moreover, the SaberCats had won a total of four AFL Championships (2002, 2004, 2007, and 2015). Their lifetime postseason record stood at 19–12.

In the club's first four seasons (1995–1998), the team played just above mediocre, but still qualified for the playoffs three out of the four years, losing in the opening round each time under the guidance of Todd Shell. In 1999, the SaberCats appointed eventual owner-general manager Darren Arbet to the position of head coach. Under Arbet's guidance, the team's fortunes improved dramatically. In 2000, the SaberCats won a post-season game.

The SaberCats' run of success intensified in the 2000s; during that time, they won seven division titles and played in three American Conference championship games. In 2002, the team captured its first ArenaBowl championship by defeating the Arizona Rattlers in ArenaBowl XVI. In 2004, the SaberCats won a second championship by defeating the Rattlers in ArenaBowl XVIII. In 2007, they defeated the Columbus Destroyers in ArenaBowl XXI to capture a third championship. In 2008, the SaberCats returned to the ArenaBowl, only to fall to the Philadelphia Soul. In 2015, the SaberCats returned to the ArenaBowl, defeating the Jacksonville Sharks.

The 2009 demise of the AFL caused the SaberCats to take a two-year hiatus. They returned to the re-formed Arena Football League in 2011 (along with several other franchises). The SaberCats posted a disappointing record of 7–11 in the season of their return. The losing season was the organization's first since 1999 and remained the worst in franchise history. While the SaberCats' regular season performance improved greatly over the following three seasons (between 2012 and 2014, they went 38–16), their postseason performance did not; over that span, they went 1–3 (with all three losses coming at the hands of the Arizona Rattlers, who subsequently won the ArenaBowl in each season). In 2015, the SaberCats finished the regular season with a franchise-best record of 17–1. After dispatching the Portland Thunder easily in the first round of the playoffs, they again faced the Rattlers; this time, however, San Jose emerged victorious. For a list of all seasons, see List of San Jose SaberCats seasons

On November 12, 2015, the league announced the SaberCats would be ceasing operations due to "reasons unrelated to League operations." A statement from the league indicated that the AFL was working to secure new, long-term owners for the franchise, but no such group has emerged. In 2019, it was announced that the Indoor Football League would be expanding to Oakland with of the Oakland Panthers, bringing arena football back to the Bay Area for the first time since the SaberCats demise. The Panthers ended up moving to the SAP Center itself in 2022 as the Bay Area Panthers.

Original AFL (1995–2008)
The SaberCats came into existence in December 1994, when the Arena Football League awarded an expansion team to businesswoman Ramune Ambrozaitis, Lafayette attorney David Frey and John Fry of Fry's Electronics. The group of three owners got a bargain when they were awarded the franchise, paying only US$750,000 of the $1.25 million the AFL typically requested of an expansion team. The team played at the San Jose Arena in San Jose, California, which is also home to the San Jose Sharks franchise of the National Hockey League. The SaberCats named Todd Shell, a former San Francisco 49ers linebacker, as the team's first head coach. The SaberCats competed in the Western Division of the American Conference. The SaberCats are one of Arena's premier organizations, having never drawn below 10,000 fans at any of their home games. The SaberCats were ArenaBowl champions in 2002, 2004, and 2007, beating the Arizona Rattlers for their first two titles and the Columbus Destroyers for the third. The San Jose SaberCats did play in a fourth ArenaBowl, ArenaBowl XXII, but lost to the Philadelphia Soul. ArenaBowl XXII would be the last game played in the originally incarnation of the AFL.

On June 5, 2004, the SaberCats were fined $20,000 for violations during their quarterfinal round playoff game against the Tampa Bay Storm. They were first fined $10,000 for distributing cow bells, without advance approval, to fans entering the building, which was cited as a violation by the AFL as an intentional competitive advantage generated by the creation of artificial noise. Also, during the game itself, the SaberCats refused to apply microphones to certain players and coaches during the NBC broadcast, which led to an additional $10,000 fine.

The cowbells went on to become a mainstay of many perennial season ticket holders, even though the SaberCats never again distributed cowbells to fans after the incident in 2004.

San Jose was 9–7 in 2005, earning the fourth seed in the American Conference playoffs. They lost to #1 seed Colorado Crush 56–48 in the first round, after failing to score on six goal line opportunities in the final minute of play.

The SaberCats went 10–6 in 2006 and won a division title in the process, along with the AC's #2 seed. They got a bye week from the wild-card round and then beat the Arizona Rattlers in the divisional round, 62–48. Because the Colorado Crush (the AC's #1 seed) lost in the divisional round to the Chicago Rush, they hosted the American Conference Championship game; however, they lost the game, 59–56.

In 2007, they got revenge against the Rush in the American Conference championship and advanced to ArenaBowl XXI, where they beat the Columbus Destroyers in front of a sellout crowd in New Orleans Arena and claimed their third Arena Bowl title in six seasons.

AFL collapse and revival (2009–2010)
On August 4, 2009, the Arena Football League announced that it was "suspending operations indefinitely" but likely to fold. The SaberCats announced shortly afterward that they intend to field a team for 2010, even if it means moving to a new indoor football league.

When the formation of a new arena football league, Arena Football 1 (renamed the new Arena Football League), was announced in 2009, the SaberCats were not one of the initial 16 teams announced. Bossier-Shreveport Battle Wings owner Dan Newman mentioned that the SaberCats were one of at least two former AFL franchises with which negotiations were in progress, the other being the Tampa Bay Storm. However, when AF1 announced its schedule in January 2010, the SaberCats were not among the 15 teams listed. At the time, it was unclear whether they would join another league, or join the new AFL later.

They would be replaced by the smaller and lesser-known San Jose Wolves of the AIFA as they contemplate their future. The Wolves do not play at HP Pavilion as the SaberCats have, rather at the Cow Palace in Daly City.

On June 16, it was officially announced that the SaberCats would be returning in 2011 as a member of the Arena Football League. The ownership once again consists of major executives from national electronics chain Fry's Electronics (John Fry, William Randy Fry, David Fry, and Kathryn J. Kolder), and in addition maintained former SaberCats coach Darren Arbet.

2011 season
The SaberCats opened their 2011 season with a 76–48 victory over the Spokane Shock. They went on to win against the Kansas City Command 60–57. The SaberCats lost the next two games, 54–41 against the Chicago Rush, and 76–69 against the Iowa Barnstormers. It looked like the 'Cats were going on a winning streak after they won the next three games (75–55 against the Utah Blaze, 42–33 against the Tulsa Talons, and 68–61 against the Philadelphia Soul), but after a bye week they went on a devastating seven game losing streak (65–43 against the Arizona Rattlers, 54–48 against the Pittsburgh Power, 76–68 against the Utah Blaze, 55–49 against the Georgia Force, 70–57 against the Dallas Vigilantes, 64–57 against the Arizona Rattlers, and 82–21 against the Cleveland Gladiators). This losing streak ended against the Jacksonville Sharks when they won 83–70. The SaberCats ended the season with a 7–11 record.

2012 season
Unlike their disappointing 2011 campaign, the SaberCats were able to clinch a playoff spot as the #3 seed, finishing the regular season with a 12–6 record. However, they were defeated 48–51 by the Arizona Rattlers in the first round of the playoffs.

2013 season
The SaberCats finished the regular season with a 13–5 record, earning the #4 seed in the National Conference. They lost the National Conference Semifinals to the Arizona Rattlers by a score of 59–49.

2014 season
The SaberCats finished the regular season with a record of 13–5 for the second consecutive year, winning the Pacific Division and earning the #2 seed in the National Conference. They won the National Conference Semifinals against the Spokane Shock in a 55–28 contest but lost the Conference Championship to the Arizona Rattlers by a 72–56 score.

2015 season
The SaberCats finished the regular season with a franchise best 17–1 record (their only loss was against the 4–14 L.A. Kiss), winning the Pacific Division and earning the #1 seed in the National Conference with homefield advantage throughout the playoffs. They won the National Conference Semifinals against the Portland Thunder by a score of 55–28 and then won the Conference Championship against the Arizona Rattlers in a 70–67 contest. They won ArenaBowl XXVIII against the Jacksonville Sharks, finishing the 2015 season with a combined 20–1 record and becoming the first team in league history to win twenty combined regular season and postseason games. However, due to scheduling conflicts at the SAP Center, the SaberCats were forced to play all but one playoff game–including the ArenaBowl–at Stockton Arena in Stockton, 80 mi north of San Jose. The Frys lobbied to move the game from its original August 29 date to August 31 so it could be played in San Jose. However, the league refused, citing its contract with ESPN.

Surprisingly, after the 2015 season, the AFL announced that the SaberCats were ceasing operations for non-football related reasons. According to Metro Silicon Valley, the Frys were concerned about the rampant instability that had prevailed in the league since it returned to the field.

Controversy surrounded the closing of the franchise in 2015. The SaberCats' franchise never returned the Foster Trophy to the league, the award handed out to each Arena Bowl champion throughout the league's history. Also, the players of the Arena Bowl XXVIII never received championship rings, becoming the first team in league history to never receive rings for the accomplishment.

Championships
The SaberCats won a total of four ArenaBowls, all while under Darren Arbet.

Rivals
The San Jose SaberCats had two primary rivals: Their divisional rival Spokane Shock, and their former division rival, the Arizona Rattlers. They also have rivalries with other teams that arose from playoff battles in the past, most notably with the Chicago Rush. The Los Angeles Avengers had an old rivalry with San Jose as well, but the rivalry became irrelevant when the Avengers became defunct in 2009.

Arizona Rattlers
The Rattlers and SaberCats were divisional rivals from 1995 to 2013, but the division alignment for 2014 put San Jose in the Pacific division and Arizona in the west. The SaberCats had a 7-game winning streak against the Rattlers from 2006 to 2008, lasted until May 7, 2011, when the Rattlers defeated the SaberCats 43–65. While the SaberCats still hold the advantage in the all-time series 26–22 (21–18 in the regular season and 5–4 in the playoffs), the Rattlers amassed 9 wins in 12 games, from the 1995 season before the arrival of SaberCats head coach Darren Arbet, through the 2000 season. On Saturday May 5, 2012 the SaberCats beat the Rattlers 77–70 (at US Airways Center), giving the SaberCats the most points scored in a game against the Rattlers in the team's history. The SaberCats' first ever ArenaBowl appearance (in the 2002 season) was a victory over the Rattlers.

Spokane Shock
The Shock and the SaberCats have been divisional rivals since the SaberCats re-joined the AFL in 2011. San Jose lost a Saturday June 23, 2012 game (63–90), and this game remains the highest ever point total scored against the SaberCats in franchise history. In 2011, the Shock won 63–61 on a last second Hail Mary from Kyle Rowley to Adron Tennell, clinching a playoff spot for the Shock and eliminating the SaberCats from playoff contention. San Jose led the overall series 5–4 when the Shock departed the AFL.

Broadcasting
The SaberCats game had been broadcast on KNBR AM 1050 out of San Mateo. However, on May 15, 2015, the SaberCats announced that they would have their games broadcast live on KDOW AM 1220 radio in San Francisco. This was the first broadcast of sports of any kind for that station.

All-Arena players
The following SaberCats players were named to All-Arena Teams:
 * QB Mark Grieb (3), Erik Meyer (1)
 * FB Brian Johnson (1), Chad Cook (1)
 * FB/LB Keala Keanaaina (1)
 * WR James Roe (1), Reggie Gray (1)
 * WR/DB Barry Wagner (2)
 * OL Mark Lewis (1), Rich Ranglin (4), Emmanuel Akah (1), George Bussey (1)
 * DL Ron Jones (1), Joe Sykes (1), Jason Stewart (3)
 * OL/DL Al Noga (1), Sam Hernandez (3), Joe Jacobs (1), Mike Ulufale (1)
 * LB Steve Watson (1), Francis Maka (4), Huey Whittaker (1)
 * DB Marquis Floyd (1), Clevan Thomas (1), Ken Fontenette (1)
 * K A. J. Haglund (2), Nich Pertuit (2)
 * OS Titus Dixon (1), Steve Papin (2), James Hundon (1), Ben Nelson (1)
 * DS Patrick McGurik (2), Tommy Jones (1), Clevan Thomas (5), Omarr Smith (1)

All-Ironman players
The following SaberCats players were named to All-Ironman Teams:
 * WR/DB Rashied Davis (1), James Roe (2)
 * WR/LB Barry Wagner (2), James Roe (1), Jason Geathers (2)
 * DS/KR Clevan Thomas (1)

All-Rookie players
The following SaberCats players were named to All-Rookie Teams:
 * FB/LB James Williams
 * WR/DB Shalon Baker
 * OL/DL Mike Ulufale
 * LB Steve Watson
 * OS Ben Nelson
 * DS Clevan Thomas
 * K A. J. Haglund

title: San Jose SaberCats