Salvaging General Jurisdiction: Satisfying Daimler And Proposing A New Framework

General jurisdiction is slowly being eroded. What was once a well-trodden path used to hale corporate defendants into the courthouse is now increasingly barred or shut. In its most recent general jurisdiction opinion, Daimler AG v. Bauman, the U.S. Supreme Court continued its trend towards divesting general jurisdiction of its utility. This is a mistake. The 21st century’s economy is increasingly complex, and general jurisdiction must evolve with this complexity. Failing to do so allows intricate corporate structures to insulate corporate defendants from the jurisdiction of U.S courts. Although the theory of personal jurisdiction has come a long way since the landmark decisions in Pennoyer v. Neff and International Shoe v. Washington, it must continue to evolve. Arguably, another catalytic opinion is needed to belatedly nudge general jurisdiction into modernity. This note explores the history of general jurisdiction, provides a means to satisfy the currently rigorous general jurisdiction standard, and proposes a new standard that is more cogent in the modern age. In doing so, Part I of this note explains the theory behind general jurisdiction and how it differs from specific jurisdiction, and Part II describes the history of the Supreme Court’s general jurisdiction jurisprudence since Pennoyer. After examining the theory of general jurisdiction and Supreme Court precedent on the issue, Part III traces the steps of the Daimler case, from the Northern District of California to the Supreme Court, with each courts’ nuances highlighted. Part IV then explains the necessary steps plaintiffs must take to satisfy the new rigors of general jurisdiction. Finally, Part V provides a new definition and standard of general jurisdiction, one that will hopefully be more consistent with the original theory of general jurisdiction that was first outlined in Pennoyer and International Shoe

Numerical Determination of Temperature Profiles in Flowing Systems From Conversions of Chemically Reacting Tracers

This study presents the mathematical bases of the measurement of internal temperatures within flowing systems using chemically reacting tracers. It considers plug-flow (or piston-flow) systems. The differential equation for reactant conversion can be reformulated into a Fredholm integral equation of the first kind. In the Fredholm integral equation the unknown is the temperature distribution function, which characterizes the internal temperature profile of the flowing system. Due to nonlinearity of the kernel, the usual technique of regularization has been modified into an iterative approach. This new approach is employed to solve this Fredholm integral equation. The iterative approach successfully overcomes the usual difficulty of determining the optimal value of the regularization smoothing parameter. Advantages and disadvantages of this method are discussed, and the results are compared with those obtained by optimization of undetermined parameters in a postulated temperature distribution function. The insight acquired from this study can be used to determine temperature profiles for many existing systems, and can form a basis for analysis of the more complicated dispersed-flow systems. The iterative Fredholm integral equation method is tested to see what is required to discriminate between two models of the temperature behavior of Hot Dry Rock geothermal reservoirs. It is found that using as few as two reacting tracers can distinguish between the models and provide a reasonable approximation of the temperature profile within a reservoir. 10 refs., 6 figs., 2 tabs

Young people today: news media, policy and youth justice

The new sociology of childhood sees children as competent social agents with important contributions to make. And yet the phase of childhood is fraught with tensions and contradictions. Public policies are required, not only to protect children, but also to control them and regulate their behaviour. For children and young people in the UK, youth justice has become increasingly punitive. At the same time, social policies have focused more on children's inclusion and participation. In this interplay of conflict and contradictions, the role the media play is critical in contributing to the moral panic about childhood and youth. In this article, we consider media representations of “antisocial” children and young people and how this belies a moral response to the nature of contemporary childhood. We conclude by considering how a rights-based approach might help redress the moralised politics of childhood representations in the media

Physician decision making in selection of second-line treatments in immune thrombocytopenia in children.

Immune thrombocytopenia (ITP) is an acquired autoimmune bleeding disorder which presents with isolated thrombocytopenia and risk of hemorrhage. While most children with ITP promptly recover with or without drug therapy, ITP is persistent or chronic in others. When needed, how to select second-line therapies is not clear. ICON1, conducted within the Pediatric ITP Consortium of North America (ICON), is a prospective, observational, longitudinal cohort study of 120 children from 21 centers starting second-line treatments for ITP which examined treatment decisions. Treating physicians reported reasons for selecting therapies, ranking the top three. In a propensity weighted model, the most important factors were patient/parental preference (53%) and treatment-related factors: side effect profile (58%), long-term toxicity (54%), ease of administration (46%), possibility of remission (45%), and perceived efficacy (30%). Physician, health system, and clinical factors rarely influenced decision-making. Patient/parent preferences were selected as reasons more often in chronic ITP (85.7%) than in newly diagnosed (0%) or persistent ITP (14.3%, P = .003). Splenectomy and rituximab were chosen for the possibility of inducing long-term remission (P < .001). Oral agents, such as eltrombopag and immunosuppressants, were chosen for ease of administration and expected adherence (P < .001). Physicians chose rituximab in patients with lower expected adherence (P = .017). Treatment choice showed some physician and treatment center bias. This study illustrates the complexity and many factors involved in decision-making in selecting second-line ITP treatments, given the absence of comparative trials. It highlights shared decision-making and the need for well-conducted, comparative effectiveness studies to allow for informed discussion between patients and clinicians

Accommodating 'others'?: housing dispersed, forced migrants in the UK

Utilising insights from a qualitative study in the city of Leeds (UK), this paper considers issues related to the housing of dispersed forced migrants. The term 'dispersed forced migrants' is used here as a general label to include four groups of international migrants (i.e. refugees, asylum seekers, those with humanitarian protection status and failed asylum seekers) who have previously been dispersed, on a no choice basis, to a variety of locations across the UK under the requirements of the Immigration and Asylum Act (1999). The tiering of housing entitlement that exists within the generic population of dispersed forced migrants (a consequence of the particular socio-legal status assigned to individuals), and its role in rendering migrants susceptible to homelessness is outlined. The adequacy/standard of accommodation made available to forced migrants is also discussed. It is concluded that current arrangements fail to meet the basic housing needs of many forced migrants. Any future improvement in this situation will require a significant shift in government policy

The impacts of environmental warming on Odonata: a review

Climate change brings with it unprecedented rates of increase in environmental temperature, which will have major consequences for the earth's flora and fauna. The Odonata represent a taxon that has many strong links to this abiotic factor due to its tropical evolutionary history and adaptations to temperate climates. Temperature is known to affect odonate physiology including life-history traits such as developmental rate, phenology and seasonal regulation as well as immune function and the production of pigment for thermoregulation. A range of behaviours are likely to be affected which will, in turn, influence other parts of the aquatic ecosystem, primarily through trophic interactions. Temperature may influence changes in geographical distributions, through a shifting of species' fundamental niches, changes in the distribution of suitable habitat and variation in the dispersal ability of species. Finally, such a rapid change in the environment results in a strong selective pressure towards adaptation to cope and the inevitable loss of some populations and, potentially, species. Where data are lacking for odonates, studies on other invertebrate groups will be considered. Finally, directions for research are suggested, particularly laboratory studies that investigate underlying causes of climate-driven macroecological patterns

Ethics, politics and migration: Public debates on the free movement of Romanians and Bulgarians in the UK, 2006–2013

Public debates on immigration have become the subject of much concern, particularly in the UK. This article applies an ethical lens to assess changes in public debates over intra-EU migration in six UK national newspapers during 2006 and 2013. It finds an almost complete dominance of communitarian justifications, mainly based on welfare chauvinism, but a notable increase in security-related arguments and a decrease in economic nationalist ideas. Alternative cosmopolitan arguments about immigration go from rare to virtually absent. The discussion links these shifts to a failure of the UK centre-left to overcome historic difficulties in presenting a coherent narrative on immigration policy

Kepler-21b: A 1.6REarth Planet Transiting the Bright Oscillating F Subgiant Star HD 179070

We present Kepler observations of the bright (V=8.3), oscillating star HD 179070. The observations show transit-like events which reveal that the star is orbited every 2.8 days by a small, 1.6 R_Earth object. Seismic studies of HD 179070 using short cadence Kepler observations show that HD 179070 has a frequencypower spectrum consistent with solar-like oscillations that are acoustic p-modes. Asteroseismic analysis provides robust values for the mass and radius of HD 179070, 1.34{\pm}0.06 M{\circ} and 1.86{\pm}0.04 R{\circ} respectively, as well as yielding an age of 2.84{\pm}0.34 Gyr for this F5 subgiant. Together with ground-based follow-up observations, analysis of the Kepler light curves and image data, and blend scenario models, we conservatively show at the >99.7% confidence level (3{\sigma}) that the transit event is caused by a 1.64{\pm}0.04 R_Earth exoplanet in a 2.785755{\pm}0.000032 day orbit. The exoplanet is only 0.04 AU away from the star and our spectroscopic observations provide an upper limit to its mass of ~10 M_Earth (2-{\sigma}). HD 179070 is the brightest exoplanet host star yet discovered by Kepler.Comment: Accepted to Ap

Idiopathic interstitial pneumonia: Do community and academic physicians agree on diagnosis?

Rationale: Treatment and prognoses of diffuse parenchymal lung diseases (DPLDs) varies by diagnosis. Obtaining a uniform diagnosis among observers is difficult. Objectives: Evaluate diagnostic agreement between academic and community-based physicians for patients with DPLDs, and determine if an interactive approach between clinicians, radiologists, and pathologists improved diagnostic agreement in community and academic centers. Methods: Retrospective review of 39 patients with DPLD. A total of 19 participants reviewed cases at 2 community locations and 1 academic location. Information from the history, physical examination, pulmonary function testing, high-resolution computed tomography, and surgical lung biopsy was collected. Data were presented in the same sequential fashion to three groups of physicians on separate days. Measurements and Main Results: Each observer’s diagnosis was coded into one of eight categories. A statistic allowing formultiple raters was used to assess agreement in diagnosis. Interactions between clinicians, radiologists, and pathologists improved interobserver agreement at both community and academic sites; however, final agreement was better within academic centers (Kappa= 0.55–0.71) than within community centers (Kappa=0.32–0.44). Clinically significant disagreement was present between academic and communitybased physicians (Kappa=0.11–0.56). Community physicians were more likely to assign a final diagnosis of idiopathic pulmonary fibrosis compared with academic physicians. Conclusions: Significant disagreement exists in the diagnosis of DPLD between physicians based in communities compared with those in academic centers. Wherever possible, patients should be referred to centers with expertise in diffuse parenchymal lung disorders to help clarify the diagnosis and provide suggestions regarding treatment options.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/91941/1/2007 AJRCCM Idiopathic interstitial pneumonia - Do community and academic physicians agree on diagnosis.pd

A molten salt test loop for component and instrumentation testing

Molten salt is an effective coolant for a wide range of applications, including nuclear reactors, concentrated solar power, and other high temperature industrial heat transfer processes. The technical readiness level of components and instrumentation for high-temperature molten salt applications needs improvement for molten salt to be more widely adopted. A molten salt test loop was designed, built, and commissioned as a test bed to address these issues. The molten salt test loop at Abilene Christian University was built out of 316 stainless steel with a forced flow centrifugal-type pump, and was instrumented for remote operation. A low-temperature molten nitrate salt was used in this system, which was designed to operate at temperatures up to 300 ◦C and flow rates up to 90 liters per minute. This paper describes the loop design, computational fluid dynamics modeling, construction, and commissioning details. An outline of the data acquisition and control systems is presented. Salt samples were taken before and after introduction into the loop, and melting points were measured both before and after salt circulation. Performance of the system is discussed as well as improvements required for higher temperature loops envisioned for the future