Changes
first use
As of Nov. 18, a total of 608 court decisions -- 408 federal and 200 state -- refer to this bogus, unscientific theory. The [[U.S. Supreme Court]] has never used this term.
The first court decision to use the term "positional asphyxiation" was in 1981, by an appellate state court in [[Massachusetts]] which simply repeated what a coroner alleged was a cause of death for someone found badly beaten with his face down with his head in a gutter:{{cquote|At some point the defendant returned to the bar alone. At approximately 10:00 P.M. police arrived and found the victim lying in the gutter outside the bar. He was pronounced dead on arrival at Boston City Hospital. The cause of death was "positional asphyxia," apparently the result of his having lain face down in the gutter. He had been rendered unconscious by multiple blows.}}''Commonwealth v. McDonald'', 11 Mass. App. Ct. 944, 945, 416 N.E.2d 992, 993-94 (1981).
==False basis for denying compensation for vaccine injury==