The Politics of Selecting Chevron Deference

In this article, we examine an important threshold question in judicial behavior and administrative law: When do federal circuit courts decide to use the Chevron deference framework and when do they select a framework that is less deferential to the administrative agency\u27s statutory interpretation? The question is important because the purpose of Chevron deference is to give agencies-not judges-policy-making space within statutory interpretation. We expect, nonetheless, that whether to invoke the Chevron framework is largely driven by political dynamics, with judges adopting a less deferential standard when their political preferences do not align with the agency\u27s decision. To provide insight, we analyze circuit court decisions from 2003 until 2013 that review agency statutory interpretations. Our results-from the largest and most comprehensive database of its kind-- provide partial confirmation of our expectations. When courts reviewed liberal agency interpretations, all panels-liberal, moderate, and conservative-were equally likely to apply Chevron. However, when reviewing conservative agency interpretations, liberal panels selected the Chevron deference framework significantly less frequently than conservative panels. Contrary to limited prior studies, we find no evidence of whistleblower or disciplining effects when judges of different judicial ideologies comprised the panel. Viewed together, our results provide important implications for the current debate on whether to eliminate, narrow, or clarify Chevron\u27s domain

Judge Kavanaugh, Chevron Deference, and the Supreme Court

How might a new U.S. Supreme Court Justice Brett Kavanaugh review federal agency statutory interpretations that come before him on the Court? To find at least a preliminary answer, we can look to his judicial behavior while serving on the U.S. Court of Appeals for the D.C. Circuit—and there is plenty of relevant Kavanaugh judicial behavior to observe. Since starting his service on the D.C. Circuit in 2006, Judge Kavanaugh has participated in the disposition of around 2,700 cases and has authored more than 300 opinions. Over a third of those authored opinions involved administrative law

A Disk Shadow Around the Young Star ASR 41 in NGC 1333

We present images of the young stellar object ASR 41 in the NGC 1333 star forming region at the wavelengths of H_alpha and [SII] and in the I, J, H, and K-bands. ASR 41 has the near-infrared morphology of an edge-on disk object, but appears an order of magnitude larger than typical systems of this kind. We also present detailed models of the scattering and radiative transfer in systems consisting of a young star surrounded by a proto-planetary disk, and the whole system being embedded in either an infalling envelope or a uniform molecular cloud. The best fit to the observed morphology can be achieved with a disk of approx. 200 AU diameter, immersed in a low density cloud. The low cloud density is necessary to stay below the sub-mm flux upper limits and to preserve the shadow cast by the disk via single scattering. The results demonstrate that ASR 41 is probably not inherently different from typical edge-on disk objects, and that its large apparent size is due to the shadow of a much smaller disk being projected into the surrounding dusty molecular material

Post-glacial sea-level change along the Pacific coast of North America

Sea-level history since the Last Glacial Maximum on the Pacific margin of North America is complex and heterogeneous owing to regional differences in crustal deformation (neotectonics), changes in global ocean volumes (eustasy) and the depression and rebound of the Earth\u27s crust in response to ice sheets on land (isostasy). At the Last Glacial Maximum, the Cordilleran Ice Sheet depressed the crust over which it formed and created a raised forebulge along peripheral areas offshore. This, combined with different tectonic settings along the coast, resulted in divergent relative sea-level responses during the Holocene. For example, sea level was up to 200 m higher than present in the lower Fraser Valley region of southwest British Columbia, due largely to isostatic depression. At the same time, sea level was 150 m lower than present in Haida Gwaii, on the northern coast of British Columbia, due to the combined effects of the forebulge raising the land and lower eustatic sea level. A forebulge also developed in parts of southeast Alaska resulting in post-glacial sea levels at least 122 m lower than present and possibly as low as 165 m. On the coasts of Washington and Oregon, as well as south-central Alaska, neotectonics and eustasy seem to have played larger roles than isostatic adjustments in controlling relative sea-level changes

Optimisation of grolishing freeform surfaces with rigid and semi-rigid tools

After the formal acceptance of our fabrication of E-ELT segments, we aim to further accelerate the mass production by introducing an intermediate grolishing procedure using industrial robots, reducing the total process time by this much faster and parallel link. In this paper, we have presented research outputs on tool design, tool path generation, study of mismatch between rigid, semi-rigid tool and aspheric surface. It is indicated that the generation of mid-spatial frequency is proportional to the grit size and misfit between work piece and tool surfaces. Using a Non-Newtonian material tool with a spindle speed of 30 rpm has successfully reduce the mid-spatial error. The optimization of process parameters involve the study the combination effects of the above factors. These optimized parameters will result in a lookup table for reference of given input surface quality. Future work may include the higher spindle speed for grolishing with non- Newtonian tool looking for potential applications regarding to form correction, higher removal rate and edge contro

A post-glacial sea level hinge on the central Pacific coast of Canada

Post-glacial sea level dynamics during the last 15,000 calendar years are highly variable along the Pacific coast of Canada. During the Last Glacial Maximum, the Earth\u27s crust was depressed by ice loading along the mainland inner coast and relative sea levels were as much as 200 m higher than today. In contrast, some outer coastal areas experienced a glacial forebulge (uplift) effect that caused relative sea levels to drop to as much as 150 m below present levels. Between these inner and outer coasts, we hypothesize that there would have been an area where sea level remained relatively stable, despite regional and global trends in sea level change. To address this hypothesis, we use pond basin coring, diatom analysis, archaeological site testing, sedimentary exposure sampling, and radiocarbon dating to construct sea level histories for the Hakai Passage region. Our data include 106 newly reported radiocarbon ages from key coastal sites that together support the thesis that this area has experienced a relatively stable sea level over the last 15,000 calendar years. These findings are significant in that they indicate a relatively stable coastal environment amenable to long-term human occupation and settlement of the area. Our results will help inform future archaeological investigations in the region

Spectrum of Illness in International Migrants Seen at GeoSentinel Clinics in 1997-2009, Part 2: Migrants Resettled Internationally and Evaluated for Specific Health Concerns

Of 7629 migrants, one third were infected with tuberculosis (22% active, 10% latent), one quarter with a variety of parasites (malaria 7%, schistosomes 6%, Strongyloides 5%, miscellaneous 5%), and 17% with chronic viral hepatitis (12% hepatitis B, 5% hepatitis C

Dose-Dependent Effects of Multiple Acute Cocaine Injections on Maternal Behavior and Aggression in Sprague-Dawley Rats

Rat dams, which had no prior drug treatment, were either nontreated controls or were injected subcutaneously 4 times during a 10-day period with a single dose of 30, 15 or 7.5 mg/kg of cocaine hydrochloride HCl, or normal saline. Injections were given immediately postpartum following delivery of their final pup (PPD 1), and again on postpartum day 3 (PPD 3), postpartum day 6 (PPD 6) and postpartum day 10 (PPD 10). Dams were observed 30 min following injections for maternal behavior (MB) towards 8 surrogate male pups on PPD 1 and PPD 3 and for aggression towards a male or female intruder in the presence of their litter on PPD 6 and PPD 10. Compared to saline and untreated controls, cocaine-treated dams exhibited more disruptions in MB on both PPD 1 and PPD 3 and were less aggressive towards an intruder, regardless of intruder sex, on PPD 6 and PPD 10. In most cases MB was altered in a dose-dependent manner with the higher doses of cocaine resulting in a greater disruption of behavior

On the accuracy of PLIF measurements in slender plumes

The purpose of this article was to assess the measurement uncertainty of the planar laser-induced fluorescence (PLIF) method and, as much as possible, to devise corrections for predictable biases. More specifically, we considered the measurement of concentration maps in cross sections parallel to and normal to the axis of a slender plume containing Rhodamine 6G as a passive scalar tracer and transported by a turbulent shear flow. In addition to previously examined sources of error related to PLIF, we also investigated several unexplored ones. First, we demonstrated that errors would arise if the laser sheet thickness was comparable to or larger than the thickness of the instantaneous plume. We then investigated the effect of secondary fluorescence, which was attributed to absorption and re-emission of primary fluorescence by dye both within and outside the laser sheet. We found that, if uncorrected, this effect would contaminate the calibration as well as the instantaneous concentration measurements of the plume, and proposed methods for the correction of these errors and for identifying the instantaneous boundaries of the in-sheet dye regions

Clinical and Pathological Characteristics and Outcomes Among Patients With Subcutaneous Panniculitis-like T-Cell Lymphoma and Related Adipotropic Lymphoproliferative Disorders

IMPORTANCE: There is a knowledge gap about subcutaneous panniculitis-like T-cell lymphoma (SPTCL) owing to its rarity and diagnostic difficulty, resulting in an absence of well-documented large case series published to date. OBJECTIVE: To generate consensus knowledge by a joint multi-institutional review of SPTCL and related conditions. DESIGN, SETTING, AND PARTICIPANTS: This retrospective clinical and pathological review included cases initially diagnosed as SPTCL at 6 large US academic centers. All cases were reviewed by a group of pathologists, dermatologists, and oncologists with expertise in cutaneous lymphomas. Through a process of group consensus applying defined clinical and pathological diagnostic criteria, the cohort was classified as (1) SPTCL or (2) adipotropic lymphoproliferative disorder (ALPD) for similar cases with incomplete histopathological criteria for SPTCL designation. EXPOSURES: Cases of SPTCL diagnosed between 1998 and 2018. MAIN OUTCOMES AND MEASURES: The main outcome was disease presentation and evolution, including response to therapy, disease progression, and development of hemophagocytic lymphohistiocytosis. RESULTS: The cohort of 95 patients (median [range] age, 38 [2-81] years; female-to-male ratio, 2.7) included 75 cases of SPTCL and 20 cases of ALPD. The clinical presentation was similar for both groups with multiple (61 of 72 [85%]) or single (11 of 72 [15%]) tender nodules mostly involving extremities, occasionally resulting in lipoatrophy. Hemophagocytic lymphohistiocytosis (HLH) was only observed in SPTCL cases. With a mean follow-up of 56 months, 60 of 90 patients (67%) achieved complete remission with a median (range) of 3 (1-7) cumulative therapies. Relapse was common. None of the patients died of disease progression or HLH. Two patients with ALPD eventually progressed to SPTCL without associated systemic symptoms or HLH. CONCLUSIONS AND RELEVANCE: In this case series of patients initially diagnosed as having SPTCL, results showed no evidence of systemic tumoral progression beyond the adipose tissue. The SPTCL experience in this study confirmed an indolent course and favorable response to a variety of treatments ranging from immune modulation to chemotherapy followed by hematopoietic stem cell transplantation. Morbidity was primarily associated with HLH