A Call for Stricter Appellate Review of Decisions on Forum Non Conveniens

Forum non conveniens has been criticized as anachronistic and unfair. Critics say that it amounts to little more than economic protectionism, serving as a pretext for the dismissal of suits brought against domestic corporate defendants. Even if one does not view the doctrine as inherently flawed, it is undeniable that its application has been extremely uneven owing to the broad discretion exercised by district courts’ ruling on the issue. Troubling in any circumstances, the misapplication of forum non conveniens is all the more so because of the high stakes at issue in such matters. When a case is dismissed for forum non conveniens, it usually goes away for good. Against this background, I argue that the appellate courts should adopt a stricter standard of review for decisions on forum non conveniens. The basic rubric (abuse of discretion) should remain, but appellate courts should apply this standard with heightened scrutiny in light of the serious consequences of the underlying decision. The courts have done so in the analogous context of rulings on class certification. Doing so in the context of forum non conveniens would significantly curb abuse, all the while demonstrating to litigants and the broader community that the judiciary understands the importance of these decisions in today’s world

Assuming Too Much: An Analysis of Brown v. Sanders

This Casenote analyzes the majority and dissenting opinions in Sanders in an attempt to determine which Justice, if any, offers and satisfying solution to the problem of death sentences partially based on subsequently invalidated factors. It argues that, while the dissenting opinions leave something to be desired, Justice Scalia\u27s majority opinion is unacceptable because it treats too lightly the real possibility that a jury may choose death due to the role played by a subsequently invalidated sentencing factor. In response, this Note offers an alternate approach-one that would accommodate the needs of judicial economy while simultaneously protecting against the substantial risks that Scalia erroneously ignores

IV-VI resonant cavity enhanced photodetectors for the midinfrared

A resonant-cavity enhanced detector operating in the mid-infrared at a wavelength around 3.6 micron is demonstrated. The device is based on a narrow-gap lead salt heterostructure grown by molecular beam epitaxy. Below 140 K, the photovoltage clearly shows a single narrow cavity resonance, with a relative line width of only 2 % at 80 K.Comment: 2 figure

Co-transport-induced instability of membrane voltage in tip-growing cells

A salient feature of stationary patterns in tip-growing cells is the key role played by the symports and antiports, membrane proteins that translocate two ionic species at the same time. It is shown that these co-transporters destabilize generically the membrane voltage if the two translocated ions diffuse differently and carry a charge of opposite (same) sign for symports (antiports). Orders of magnitude obtained for the time and lengthscale are in agreement with experiments. A weakly nonlinear analysis characterizes the bifurcation

Lipid membranes with an edge

Consider a lipid membrane with a free exposed edge. The energy describing this membrane is quadratic in the extrinsic curvature of its geometry; that describing the edge is proportional to its length. In this note we determine the boundary conditions satisfied by the equilibria of the membrane on this edge, exploiting variational principles. The derivation is free of any assumptions on the symmetry of the membrane geometry. With respect to earlier work for axially symmetric configurations, we discover the existence of an additional boundary condition which is identically satisfied in that limit. By considering the balance of the forces operating at the edge, we provide a physical interpretation for the boundary conditions. We end with a discussion of the effect of the addition of a Gaussian rigidity term for the membrane.Comment: 8 page

Extracellular electrical signals in a neuron-surface junction: model of heterogeneous membrane conductivity

Signals recorded from neurons with extracellular planar sensors have a wide range of waveforms and amplitudes. This variety is a result of different physical conditions affecting the ion currents through a cellular membrane. The transmembrane currents are often considered by macroscopic membrane models as essentially a homogeneous process. However, this assumption is doubtful, since ions move through ion channels, which are scattered within the membrane. Accounting for this fact, the present work proposes a theoretical model of heterogeneous membrane conductivity. The model is based on the hypothesis that both potential and charge are distributed inhomogeneously on the membrane surface, concentrated near channel pores, as the direct consequence of the inhomogeneous transmembrane current. A system of continuity equations having non-stationary and quasi-stationary forms expresses this fact mathematically. The present work performs mathematical analysis of the proposed equations, following by the synthesis of the equivalent electric element of a heterogeneous membrane current. This element is further used to construct a model of the cell-surface electric junction in a form of the equivalent electrical circuit. After that a study of how the heterogeneous membrane conductivity affects parameters of the extracellular electrical signal is performed. As the result it was found that variation of the passive characteristics of the cell-surface junction, conductivity of the cleft and the cleft height, could lead to different shapes of the extracellular signals

Efficient room-temperature light-emitters based on partly amorphised Ge quantum dots in crystalline Si

Semiconductor light emitters compatible with standard Si integration technology (SIT) are of particular interest for overcoming limitations in the operating speed of microelectronic devices 1-3. Light sources based on group-IV elements would be SIT compatible but suffer from the poor optoelectronic properties of bulk Si and Ge. Here, we demonstrate that epitaxially grown Ge quantum dots (QDs) in a fully coherent Si matrix show extraordinary optical properties if partially amorphised by Ge-ion bombardment (GIB). The GIB-QDs exhibit a quasi-direct-band gap and show, in contrast to conventional SiGe nanostructures, almost no thermal quenching of the photoluminescence (PL) up to room-temperature (RT). Microdisk resonators with embedded GIB-QDs exhibit threshold-behaviour and super-linear increase of the integrated PL-intensity (IPL) with increasing excitation power Pexc which indicates light amplification by stimulated emission in a fully SIT-compatible group-IV nano-system

A Bio-Polymer Transistor: Electrical Amplification by Microtubules

Microtubules (MTs) are important cytoskeletal structures, engaged in a number of specific cellular activities, including vesicular traffic, cell cyto-architecture and motility, cell division, and information processing within neuronal processes. MTs have also been implicated in higher neuronal functions, including memory, and the emergence of "consciousness". How MTs handle and process electrical information, however, is heretofore unknown. Here we show new electrodynamic properties of MTs. Isolated, taxol-stabilized microtubules behave as bio-molecular transistors capable of amplifying electrical information. Electrical amplification by MTs can lead to the enhancement of dynamic information, and processivity in neurons can be conceptualized as an "ionic-based" transistor, which may impact among other known functions, neuronal computational capabilities.Comment: This is the final submitted version. The published version should be downloaded from Biophysical Journa