Revisiting ERISA Preemption in Gobeille v. Liberty Mutual

Under the U.S. Constitution’s Supremacy Clause, federal law preempts state law. In 1974 Congress passed the Employee Retirement Income Security Act (ERISA) governing benefits offered by employers to their employees. The purpose of this statute was ensuring the uniformity of the law applicable to employee benefts. The Supreme Court case of Gobeille v. Liberty Mutual concerns the limits of ERISA’s preemption of state law, specifically whether a state law governing employee benefits is merely peripheral to the core ERISA functions. This Commentary argues that ERISA does not preempt a state law which does not interfere with the administration of ERISA plans and which facilitates better, more affordable heath care options to the public

A Comparison of the Effectiveness of Pitfall Traps and Winkler Litter Samples for Characterization of Terrestrial Ant (Formicidae) Communities in Temperate Savannas

Relatively few studies in temperate environments have compared pitfall traps and Winkler litter samples, two of the most commonly used ant (Formicidae) sampling protocols. Most of the comparative work has been performed in tropical and subtropical environments. Temperate studies have primarily taken place in forested environments. Our study focuses on the relative efficiency of these two methods in temperate oak savannas, the major ecotone connecting grasslands and deciduous forest in the Midwest. These environments are often maintained by fire and mechanical brush removal, which tends to decrease the amount of available leaf litter. We sampled 21 sites, varying in age since restoration from un-restored to 22 years of restoration activities in McHenry Co. Illinois. Each site was sampled with 30 pitfall traps and five Winkler litter samples. A total of 38 species in 17 genera in 5 subfamilies were captured and identified. Pitfall traps accounted for 37 of the species, while Winkler litter samples only captured 23 species, and only one species specific to that method. We conclude that in northern temperate savannas, pitfall traps were more effective and more efficient at characterizing the epigeic ant community than Winkler litter samples

Analyzing female labor supply: Evidence from a Dutch tax reform

This paper uses the exogenous variation caused by the Dutch tax reform of 2001 to investigate how married women react to financial incentives. Among OECD countries, the Netherlands has average female labor force participation, but by far the highest rate of part-time work. Our main conclusion is that the positive significant effect of the 2001 tax reform on labor force participation dominates the negative insignificant effect on working hours. Our preferred explanation is that women respond more to changes in tax allowances than to changes in marginal tax rates.

Envisioning Futures of Design Education: An Exploratory Workshop with Design Educator

The demand for innovation in the creative economy has seen the adoption and adaptation of design thinking and design methods into domains outside design, such as business management, education, healthcare, and engineering. Design thinking and methodologies are now considered useful for identifying, framing and solving complex, often wicked social, technological, economic and public policy problems. As the practice of design undergoes change, design education is also expected to adjust to prepare future designers to have dramatically different demands made upon their general abilities and bases of knowledge than have design career paths from years past. Future designers will have to develop skills and be able to construct and utilize knowledge that allows them to make meaningful contributions to collaborative efforts involving experts from disciplines outside design. Exactly how future designers should be prepared to do this has sparked a good deal of conjecture and debate in the professional and academic design communities. This report proposes that the process of creating future scenarios that more broadly explore and expand the role, or roles, for design and designers in the world’s increasingly interwoven and interdependent societies can help uncover core needs and envision framework(s) for design education. This approach informed the creation of a workshop held at the Design Research Society conference in Brighton, UK in June of 2016, where six design educators shared four future scenarios that served as catalysts for conversations about the future of design education. Each scenario presented a specific future design education context. One scenario described the progression of design education as a core component of K-12 curricula; another scenario situated design at the core of a network of globally-linked local Universities; the third scenario highlighted the expanding role of designers over time; and the final scenario described a distance design education context that made learning relevant and “close” to an individual learner’s areas of interest. Forty participants in teams of up to six were asked to collaboratively visualize a possible future vision of design education based on one of these four scenarios and supported by a toolkit consisting of a set of trigger cards (with images and text), along with markers, glue and flipcharts. The collaborative visions that were jointly created as posters using the toolkit and then presented by the teams to all the workshop participants and facilitators are offered here as a case study. Although inspired by different scenarios, their collectively envisioned futures of what design education should facilitate displayed some key similarities. Some of those were: Future design education curricula will focus on developing collaborative approaches within which faculty and students are co-learners; These curricula will bring together ways of learning and knowing that stem from multiple disciplines; and Learning in and about the natural environment will be a key goal (the specifics of how that would be accomplished were not elaborated upon.) In addition, the need for transdisciplinarity was expressed across the collaborative visions created by each of the teams, but the manner that participants chose to express their ideas about this varied. Some envisioned that design would evolve by drawing on other disciplinary knowledge, and others envisioned that design would gradually integrate with other disciplines

DNA Typing Compatibility with a One Step Saliva Screening Test

Screening a substrate for bodily fluids is an extremely important step for locating areas that may contain DNA. Several different methods have been developed for saliva (1). The Phadebas® Forensic Press (PFP) test is a presumptive saliva test that utilizes a preloaded paper that will react with the enzyme amylase, a component of saliva (2-5). Because of its ability to screen for amylase while simultaneously locating stains, the PFP may prove to be an effective, rapid method for screening. However it is important to assess whether the PFP introduces any inhibitors (7) to downstream processing such as PCR amplification. Based on previous studies, we hypothesize that the PFP will provide a rapid and sensitive method for locating multiple saliva stains simultaneously, without introducing inhibitors to DNA profiling. To test the limitations of PFP as well as evaluated its effects on DNA profiling we first created a dilution series of saliva ranging from neat to 1:5000. After this we preformed sensitivity tests on an indirect method, UV degraded samples and washed samples as well as with bodily fluid mixtures. Once all sensitivity tests were done, cuttings were taken from the substrate and PFP paper and analyzed for DNA. Tests found that the sensitivity ranges of the PFP were between 1:10 and 1:1000, indirect tests were less sensitive than direct, all bodily fluid mixtures were detected, and UV degraded samples took more time to react. In addition our DNA results confirmed our hypothesis that PFP does not inhibit DNA and is a useful method for locating stains. This project was funded by NSFREU Grant DBI 1262832

The Price Premium for Organic Babyfood: A Hedonic Analysis

The price premium associated with organic babyfood is estimated by applying a hedonic model to price and characteristic data for babyfood products collected in two cities: Raleigh, North Carolina, and San Jose, California. The price per ounce of babyfood is modeled as a function of a number of babyfood and store characteristics. The estimated organic price premium is generally equal to 3 cents to 4 cents per ounce. To the extent this premium reflects consumer willingness to pay to reduce pesticide exposures, it could be used to infer values for reduced dietary exposures to pesticide residues for babies.babyfood, hedonic analysis, organic foods, Demand and Price Analysis,

Earned income tax credit recipients: income, marginal tax rates, wealth, and credit constraints

The Earned Income Tax Credit (EITC) has evolved into the largest anti-poverty program in the United States by providing tax credits for low and moderate income working families. In this paper, we describe the characteristics of EITC recipients at various ages using Current Population Survey data. In addition, we discuss the relevance of the EITC in affecting marginal income tax rates in the United States and discuss the effects of the EITC on household labor supply decisions. Lastly, using data from the Survey of Consumer Finances, we estimate wealth distributions for EITC recipients and analyze the extent to which EITC recipients are credit constrained.Credit ; Taxation

Cytoskeletal turnover and Myosin contractility drive cell autonomous oscillations in a model of Drosophila Dorsal Closure

Oscillatory behaviour in force-generating systems is a pervasive phenomenon in cell biology. In this work, we investigate how oscillations in the actomyosin cytoskeleton drive cell shape changes during the process of Dorsal Closure, a morphogenetic event in Drosophila embryo development whereby epidermal continuity is generated through the pulsatile apical area reduction of cells constituting the amnioserosa (AS) tissue. We present a theoretical model of AS cell dynamics by which the oscillatory behaviour arises due to a coupling between active Myosin-driven forces, actin turnover and cell deformation. Oscillations in our model are cell-autonomous and are modulated by neighbour coupling, and our model accurately reproduces the oscillatory dynamics of AS cells and their amplitude and frequency evolution. A key prediction arising from our model is that the rate of actin turnover and Myosin contractile force must increase during DC in order to reproduce the decrease in amplitude and period of cell area oscillations observed in vivo. This prediction opens up new ways to think about the molecular underpinnings of AS cell oscillations and their link to net tissue contraction and suggests the form of future experimental measurements.Comment: 17 pages, 6 figures; added references, modified and corrected Figs. 1 and 3, corrected typos, expanded discussio