Sword or Shield? Setting Limits on SLUSA’s Ever-Growing Reach

Concerned by the overwhelming presence of vexatious federal securities-fraud class actions, Congress passed the Private Securities Litigation Reform Act of 1995 to increase the procedural burden plaintiffs would face in filing these nonmeritorious suits. Instead of being deterred, plaintiffs simply brought their suits in state court. Congress responded with the Securities Litigation Uniform Standards Act of 1998 (SLUSA), making federal court the exclusive venue for securities-fraud class actions. However, Congress expressly saved from SLUSA\u27s reach claims that were traditionally brought in state court under corporate law through the Delaware carve-out. Though this exemption was meant to protect the historic dual federal-state securities-regulation regime, recent appellate court opinions have stretched SLUSA\u27s reach too far, leaving plaintiffs incapable of bringing many traditional state-law claims essential to the proper policing of corporate law regardless of the forum. This Note addresses the implications of such a broad reading of SLUSA and advocates a two-pronged approach that will simultaneously effectuate SLUSA\u27s purpose while still preserving these important state-law claims. By looking to the heart of a complaint, courts can best effectuate congressional intent both to limit problematic litigation practices and to preserve the important role federalism plays in the securities-law context

Barnes Hospital Record

https://digitalcommons.wustl.edu/bjc_barnes_record/1138/thumbnail.jp

Adoption of Transgenic Crops by Smallholder Farmers in Entre Rios, Argentina

This is a study of the adoption of transgenic crops by 120 smallholder farmers interviewed in July 2005 in the communities of San Jose de Feliciano and La Paz in the Entre Rios Province of Argentina. Logistic regression results indicate that access to a planter is essential for smallholders to adopt Bt corn, while adopters of Roundup Ready soybeans have larger farms, access to credit, availability of all essential machinery, more years of schooling, and are primarily located in the La Paz community.transgenic crops, technology adoption, Bt corn, Roundup Ready soybeans, biotechnology, Argentina, smallholders, Farm Management, Research and Development/Tech Change/Emerging Technologies,

Intraoperative bronchial stump air leak control by Progel® application after pulmonary lobectomy

Diffuse tracheobronchial calcification is a physiological condition associated with advanced age, especially in women. A calcified bronchus can be fractured during major lung resections (lobectomy, bilobectomy, and pneumonectomy), exposing patients to intraoperative air leakage and broncho-pleural fistula (BPF) occurrence. We retrospectively evaluated the use of Progel® application on the suture line of bronchial stump after pulmonary lobectomy analysing the intraoperative air leak and BPF occurrence. Between January 2014 and December 2014, Progel® was applied in 11 patients who presented intraoperative bronchial fractures after suture resection by mechanical staplers and air leak from bronchial stump, in order to treat air leakage. Patients were 7 men and 4 women, aged between 56 and 81 years (mean age 71.2 ± 12.1 years). Surgical procedures included 6 upper lobectomies (4 right, 2 left), 1 bilobectomy and 4 lower lobectomies (3 right, 1 left). Mean hospital stay was 4.5 ± 2.6 days (2-8 days). None of the patients had postoperative air leakage. No Progel® application-related complications occurred. No other major complications occurred. No mortality occurred. Progel® proved to be useful in treating intraoperative air leakage during major lung resections, particularly those occurring as a result of fracture of the bronchus from a mechanical stapler

Learning-Related Values in Young Children’s Storybooks: An Investigation in the United States, China, and Mexico

This research examined the prevalence of learning-related values in children’s storybooks in the United States, China, and Mexico. Storybooks ( N = 157) were randomly selected from government-recommended booklists in each country. Trained coders assessed the prevalence of learning-related beliefs (e.g., malleability of ability), motivated cognitions (e.g., achievement orientation), and behaviors (e.g., effort) in the storybooks. A set of MANOVAs revealed that Chinese (vs. American and Mexican) storybooks contained more instances of learning-related beliefs and behaviors. For example, Chinese storybooks included more instances of achievement-related goals and behaviors, relative to storybooks in the United States and Mexico. With the exception of achievement goals and helplessness, the prevalence of learning-related qualities was largely similar in the United States and Mexico