article, as described in an accompanying editorial, Berry The editorial closes, saying "Nature believes that accepting 'legal limits' of specific metabolites without such rigorous verification goes against the foundational standards of modern science, and results in an arbitrary test for which the rate of false positives and false negatives can never be known." Defense G. Pascal Zachary argues in a Wired essay that legalizing performance-enhancing substances, as well as genetic enhancements once they became available, would satisfy society's need for übermenschen and reverse the decline in public interest in sports. Sports scholar Verner Moller argues that society is hypocritical when it holds athletes to moral standards, but do not conform to those morals themselves. Fox Sports writer Jen Floyd Engel stated in an article, "We live in a pharmacological society. We live in a society of short cuts, of fake this and enhanced that, and somehow we keep trying to sell the line that sports has become this evil empire of cheating. The reality is athletes are merely doing what so many of us do and celebrate and watch every single day of our lives." Sociologist Ellis Cashmore argues that what is considered doping is too arbitrary: transfusing blood cells is not allowed, but other methods of boosting blood cell count, such as hypobaric chambers, are allowed. Other scholars have advanced similar arguments. Legal Anti-doping policies instituted by individual sporting governing bodies may conflict with local laws. A notable case includes the National Football League (NFL)'s inability to suspend players found with banned substances, after it was ruled by a federal court that local labor laws superseded the NFL's anti-doping regime. The challenge was supported by the National Football League Players Association. Athletes caught doping may be subject to penalties from their local, as well from the individual sporting, governing body. The legal status of anabolic steroids varies from country to country. Fighters found using performance-enhancing drugs in mixed martial arts competitions (e.g. the UFC) could face civil and/or criminal charges once Bill S-209 passes. Under certain circumstances, when athletes need to take a prohibited substance to treat a medical condition, therapeutic use exemptions may be granted. See also Cheating in sports McLaren Report Mitchell Report Doping at the Olympic Games Cheating at the Paralympic Games Doping in Russia Doping in China Doping in the United States Doping in East Germany BALCO scandal Caffeine use for sport Cannabis and sports