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In reaching its decision, the Court relied on the doctrine of "presumption against preemption," stating that "when the test of a pre-emption clause is susceptible of more than one plausible reading, courts ordinarily 'accept the reading that disfavors pre-emption.'" 128 However, as the dissent emphasized, the Court's reliance on this doctrine has waned in recent preemption cases, citing decisions such as Rowe v

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Individual studies have reported that smoking only one to five cigarettes per day is associated with a higher than expected risk of heart disease

however, when one considers the longevity of these pipes, the expertise that goes into making them, and the possibility for resale, the investment worth of these pipes becomes clear