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Generalists and specialists generally become independent of their parents much quicker than partly specialised species who may have to learn skills over long periods as various resources become seasonally available. A hybrid of professional continuing education and Carl Rogers's humanistic philosophy supporting freedom in learning is proposed, and the five principles of the philosophy are examined for their potential for transfer to professional education. Since the only fact relevant to the retroactivity determination was the date on which the petitioner's conviction became final, which was in the record and uncontested, the habeas court did not abuse its discretion in determining that the pure question of law presented by this habeas claim could be resolved solely on the recorded matters and a plenary hearing was unnecessary.