The FTAIA in Its Proper Place: Merits, Jurisdiction, and Statutory Interpretation in \u3cem\u3eMinn-Chem, Inc. v. Agrium Inc.\u3c/em\u3e

The Foreign Trade Antitrust Improvements Act (FTAIA) excludes anticompetitive conduct occurring in purely foreign commerce from the reach of U.S. antitrust laws. However, the act permits the application of U.S. antitrust laws to both import commerce and foreign commerce that has a “direct, substantial, and reasonably foreseeable” effect on U.S. commerce. Controversy over the act centers on whether the act proscribes a federal court\u27s subject-matter jurisdiction. In his 1993 dissent in Hartford v. California, Justice Scalia argued that the act does not affect a court\u27s adjudicative authority. However, ten years later the Seventh Circuit Court of Appeals held the opposite in United Phosphorus, Ltd. v. Angus Chemical Company. In 2012, in Minn-Chem, Inc. v. Agrium Inc., the Seventh Circuit reversed its prior opinion, holding that the FTAIA does not confer subject-matter jurisdiction. This Case Note chronicles the arc between Justice Scalia\u27s dissent in Hartford to the Seventh Circuit\u27s 2012 unanimous en banc decision in Minn-Chem. The accumulation of decisions leading to Minn-Chem has far-reaching consequences for civil procedure, statutory interpretation, and the extraterritorial application of U.S. laws. This Note argues that the Seventh Circuit made the right call in Minn-Chem. It also argues, in light of recent Supreme Court decisions in Morrison v. National Australia Bank and Kiobel v. Royal Dutch Petroleum, that the canon of statutory interpretation establishing the presumption that acts of Congress do not apply extraterritorially should not apply to U.S. antitrust laws

Organizational stress and individual strain: A social-psychological study of risk factors in coronary heart disease among administrators, engineers, and scientists

It is hypothesized that organizational stresses, such as high quantitative work load, responsibility for persons, poor relations with role senders, and contact with alien organizational territories, may be associated with high levels of psychological and physiological strain which are risk factors in coronary heart disease. It is further hypothesized that persons with coronary-prone Type A personality characteristics are most likely to exhibit strain under conditions of organizational stress. Measures of these stresses, personality traits, and strains were obtained from 205 male NASA administrators, engineers, and scientists. Type A personality measures included sense of time urgency, persistence, involved striving, leadership, and preference for competitive and environmentally overburdening situations