Moore v. Harper and the Consequential Effects of the Independent State Legislature Theory

In December 2022, the United States Supreme Court heard oral arguments in Moore v. Harper. The case addresses whether the North Carolina Supreme Court possesses the authority to strike down a redistricting map drawn by the state legislature. Petitioners contend that the state legislature has no such authority under the United States Constitution, citing a novel interpretation of the Elections Clause known as the “independent state legislature” (“ISL”) theory. The ISL theory is not a unified theory, but rather a constellation of related doctrinal positions that revolve around a core precept: ordinary governing principles by which state courts review the legality of state laws under state constitutions do not apply to state legislatures regulating federal elections. Proponents of the theory argue that the state legislature can exercise authority to regulate federal elections immune to the checks and balances that typically apply to state legislative action. In deciding Moore, the Supreme Court could endorse some version of this theory, which would be profoundly disruptive to election administration at all levels and likely precipitate election chaos. This Article analyzes how validation of at least some version of the theory would upend election administration and impede local elections by effectively creating a two-tiered system for administering elections. If unchecked by state judicial or constitutional constraints, partisan state legislatures could erode state-based voting rights protections to the detriment of representative democracy. Though the exact effects on American democracy are difficult to fully predict, this Article concludes that a failure to emphatically rebuke Moore would likely prove destabilizing to the Nation’s election system

Comparative analysis of surface power system architectures for human Mars exploration

Thesis (S.M.)--Massachusetts Institute of Technology, Dept. of Aeronautics and Astronautics, 2009.Includes bibliographical references (p. 90-91).This thesis provides a comprehensive analysis of surface power generation and energy storage architectures for human Mars surface missions, including tracking and non-tracking photovoltaic power generation, nuclear fission power, dynamic radioisotope power generation, and battery and regenerative fuel cell energy storage. The quantitative analysis is carried out on the basis of equal energy provision to the power system user over one Martian day (including day and night periods); this means that the total amount of energy available to the user will be the same in all cases, but the power profile over the course of the day may be different from concept to concept. The analysis results indicate that solar power systems based on non-tracking, thin-film roll-out arrays with either batteries or regenerative fuel cells for energy storage achieve comparable levels of performance as systems based on nuclear fission power across the entire range of average power levels investigated (up to 200 kW). For solar power systems, deployment and dust mitigation methods were also considered. Possible areas of commonality between Mars surface power systems and more near term lunar surface power systems were investigated. Given the significant policy and sustainability advantages of solar power compared to nuclear fission power, as well as the significant development and performance increase for thin-film photovoltaic arrays and energy storage technologies that is anticipated over the coming decades, solar power as the primary source for human Mars surface power generation should be seriously considered as alternative to traditional nuclear fission based approaches.by Chase Allen Cooper.S.M

Exile Vol. VII No. 2

EDITORIAL 4 The Catcher (woodcut) by Wilford Baumes 6 The Littlest Orphan (story) by Clark Blaise 7-17 Dead Tree (poem) by Christine Cooper 17 Two Poems by Janet Tallman 18-19 Untitled (pen and ink drawing) by Virginia Piersol 20 The Monkey (story) by Nancy Schieber 21-24 To Kandinsky (poem) by Linda Chase 24 Athena (line etching) by Virginia Piersol 25 Visions of Peanut Chocolates (poem) by Linda Chase 26 The Second Day of Summer (story) by Neil J. Weintraub 27-39 Great Exploitations (poem) by Linda Chase 40 Awarded the semi-annual EXILE-Denison Bookstore Writing Prize: The Littlest Orphan by Clark Blaise 7-1

Reforming the New York Lieutenant Governor Replacement Process: A Policy Recommendation

New York\u27s governor has unilateral power to fill vacancies in the lieutenant governor\u27s office. This unchecked power is undemocratic and risks elevating unqualified officials. In this report, the Fordham Law School Rule of Law Clinic recommends reforming the lieutenant governor replacement process. Building on a recommendation advanced by the New York State Bar Association, the clinic recommends providing the Legislature an opportunity to confirm the governor\u27s nominees. If the Legislature rejects two nominations, the governor could choose a new lieutenant governor from among a group of elected and Senate-confirmed officials.https://ir.lawnet.fordham.edu/rule_of_law_clinic/1003/thumbnail.jp

Phage Hunting at the University of Mary Washington: Genome Annotation of Hari and JackRabbit

Bacillus thuringiensis subspecies Kurstaki (BTK) is often used as a microbial insecticide for pest control and as a simulant for Bacillus anthracis in biowarfare and bioterrorism studies. Students in 2021 Phage Hunters class at University of Mary Washington isolated nine bacteriophages using the host Bacillus thuringiensis subspecies Kurstaki. Two phages, Hari and Jackrabbit, were sent to SEAPHAGES for sequencing are currently being annotated in the lab during the Spring semester. Hari was found in a soil sample obtained from King George, VA while JackRabbit was isolated from Linton, VA. Both samples were isolated from enriched cultures. Hari has a genome length of 161,978 bp, which auto-annotated with 286 features, and a direct terminal repeat of 2,633 bp. Hari is most similar to DIGNKC, SBP8a and PPIsBest by BLAST. JackRabbit has a genome length of 161,552 bp, which auto-annotated with 288 features, and a direct terminal repeat of 2,821 bp

Nutritional supplementation for nonalcohol-related fatty liver disease: a network meta-analysis.

BACKGROUND: The prevalence of non-alcohol-related fatty liver disease (NAFLD) varies between 19% and 33% in different populations. NAFLD decreases life expectancy and increases risks of liver cirrhosis, hepatocellular carcinoma, and the requirement for liver transplantation. Uncertainty surrounds relative benefits and harms of various nutritional supplements in NAFLD. Currently no nutritional supplement is recommended for people with NAFLD. OBJECTIVES: • To assess the benefits and harms of different nutritional supplements for treatment of NAFLD through a network meta-analysis • To generate rankings of different nutritional supplements according to their safety and efficacy SEARCH METHODS: We searched the Cochrane Central Register of Controlled Trials, MEDLINE, Embase, Science Citation Index Expanded, Conference Proceedings Citation Index-Science, the World Health Organization International Clinical Trials Registry Platform, and trials registers until February 2021 to identify randomised clinical trials in people with NAFLD. SELECTION CRITERIA: We included only randomised clinical trials (irrespective of language, blinding, or status) for people with NAFLD, irrespective of method of diagnosis, age and diabetic status of participants, or presence of non-alcoholic steatohepatitis (NASH). We excluded randomised clinical trials in which participants had previously undergone liver transplantation. DATA COLLECTION AND ANALYSIS: We performed a network meta-analysis with OpenBUGS using Bayesian methods whenever possible and calculated differences in treatments using hazard ratios (HRs), odds ratios (ORs), and rate ratios with 95% credible intervals (CrIs) based on an available-case analysis, according to National Institute of Health and Care Excellence Decision Support Unit guidance. MAIN RESULTS: We included in the review a total of 202 randomised clinical trials (14,200 participants). Nineteen trials were at low risk of bias. A total of 32 different interventions were compared in these trials. A total of 115 trials (7732 participants) were included in one or more comparisons. The remaining trials did not report any of the outcomes of interest for this review. Follow-up ranged from 1 month to 28 months. The follow-up period in trials that reported clinical outcomes was 2 months to 28 months. During this follow-up period, clinical events related to NAFLD such as mortality, liver cirrhosis, liver decompensation, liver transplantation, hepatocellular carcinoma, and liver-related mortality were sparse. We did not calculate effect estimates for mortality because of sparse data (zero events for at least one of the groups in the trial). None of the trials reported that they measured overall health-related quality of life using a validated scale. The evidence is very uncertain about effects of interventions on serious adverse events (number of people or number of events). We are very uncertain about effects on adverse events of most of the supplements that we investigated, as the evidence is of very low certainty. However, people taking PUFA (polyunsaturated fatty acid) may be more likely to experience an adverse event than those not receiving an active intervention (network meta-analysis results: OR 4.44, 95% CrI 2.40 to 8.48; low-certainty evidence; 4 trials, 203 participants; direct evidence: OR 4.43, 95% CrI 2.43 to 8.42). People who take other supplements (a category that includes nutritional supplements other than vitamins, fatty acids, phospholipids, and antioxidants) had higher numbers of adverse events than those not receiving an active intervention (network meta-analysis: rate ratio 1.73, 95% CrI 1.26 to 2.41; 6 trials, 291 participants; direct evidence: rate ratio 1.72, 95% CrI 1.25 to 2.40; low-certainty evidence). Data were sparse (zero events in all groups in the trial) for liver transplantation, liver decompensation, and hepatocellular carcinoma. So, we did not perform formal analysis for these outcomes. The evidence is very uncertain about effects of other antioxidants (antioxidants other than vitamins) compared to no active intervention on liver cirrhosis (HR 1.68, 95% CrI 0.23 to 15.10; 1 trial, 99 participants; very low-certainty evidence). The evidence is very uncertain about effects of interventions in any of the remaining comparisons, or data were sparse (with zero events in at least one of the groups), precluding formal calculations of effect estimates. Data were probably because of the very short follow-up period (2 months to 28 months). It takes follow-up of 8 to 28 years to detect differences in mortality between people with NAFLD and the general population. Therefore, it is unlikely that differences in clinical outcomes are noted in trials providing less than 5 to 10 years of follow-up. AUTHORS' CONCLUSIONS: The evidence indicates considerable uncertainty about effects of nutritional supplementation compared to no additional intervention on all clinical outcomes for people with non-alcohol-related fatty liver disease. Accordingly, high-quality randomised comparative clinical trials with adequate follow-up are needed. We propose registry-based randomised clinical trials or cohort multiple randomised clinical trials (study design in which multiple interventions are trialed within large longitudinal cohorts of patients to gain efficiencies and align trials more closely to standard clinical practice) comparing interventions such as vitamin E, prebiotics/probiotics/synbiotics, PUFAs, and no nutritional supplementation. The reason for the choice of interventions is the impact of these interventions on indirect outcomes, which may translate to clinical benefit. Outcomes in such trials should be mortality, health-related quality of life, decompensated liver cirrhosis, liver transplantation, and resource utilisation measures including costs of intervention and decreased healthcare utilisation after minimum follow-up of 8 years (to find meaningful differences in clinically important outcomes)

Lifestyle modifications for nonalcohol-related fatty liver disease: a network meta-analysis

BACKGROUND: The prevalence of nonalcohol-related fatty liver disease (NAFLD) varies between 19% and 33% in different populations. NAFLD decreases life expectancy and increases the risks of liver cirrhosis, hepatocellular carcinoma, and requirement for liver transplantation. There is uncertainty surrounding the relative benefits and harms of various lifestyle interventions for people with NAFLD. OBJECTIVES: To assess the comparative benefits and harms of different lifestyle interventions in the treatment of NAFLD through a network meta-analysis, and to generate rankings of the different lifestyle interventions according to their safety and efficacy. SEARCH METHODS: We searched CENTRAL, MEDLINE, Embase, Science Citation Index Expanded, Conference Proceedings Citation Index - Science, World Health Organization International Clinical Trials Registry Platform, and trials registers until February 2021 to identify randomised clinical trials in people with NAFLD. SELECTION CRITERIA: We included only randomised clinical trials (irrespective of language, blinding, or status) in people with NAFLD, whatever the method of diagnosis, age, and diabetic status of participants, or presence of non-alcoholic steatohepatitis (NASH). We excluded randomised clinical trials in which participants had previously undergone liver transplantation. DATA COLLECTION AND ANALYSIS: We planned to perform a network meta-analysis with OpenBUGS using Bayesian methods and to calculate the differences in treatments using hazard ratios (HRs), odds ratios (ORs), and rate ratios (RaRs) with 95% credible intervals (CrIs) based on an available-participant analysis, according to National Institute of Health and Care Excellence Decision Support Unit guidance. However, the data were too sparse for the clinical outcomes. We therefore performed only direct comparisons (head-to-head comparisons) with OpenBUGS using Bayesian methods. MAIN RESULTS: We included a total of 59 randomised clinical trials (3631 participants) in the review. All but two trials were at high risk of bias. A total of 33 different interventions, ranging from advice to supervised exercise and special diets, or a combination of these and no additional intervention were compared in these trials. The reference treatment was no active intervention. Twenty-eight trials (1942 participants) were included in one or more comparisons. The follow-up ranged from 1 month to 24 months. The remaining trials did not report any of the outcomes of interest for this review. The follow-up period in the trials that reported clinical outcomes was 2 months to 24 months. During this short follow-up period, clinical events related to NAFLD such as mortality, liver cirrhosis, liver decompensation, liver transplantation, hepatocellular carcinoma, and liver-related mortality were sparse. This is probably because of the very short follow-up periods. It takes a follow-up of 8 years to 28 years to detect differences in mortality between people with NAFLD and the general population. It is therefore unlikely that differences by clinical outcomes will be noted in trials with less than 5 years to 10 years of follow-up. In one trial, one participant developed an adverse event. There were no adverse events in any of the remaining participants in this trial, or in any of the remaining trials, which seemed to be directly related to the intervention. AUTHORS' CONCLUSIONS: The evidence indicates considerable uncertainty about the effects of the lifestyle interventions compared with no additional intervention (to general public health advice) on any of the clinical outcomes after a short follow-up period of 2 months to 24 months in people with nonalcohol-related fatty liver disease. Accordingly, high-quality randomised clinical trials with adequate follow-up are needed. We propose registry-based randomised clinical trials or cohort multiple randomised clinical trials (a study design in which multiple interventions are trialed within large longitudinal cohorts of participants to gain efficiencies and align trials more closely to standard clinical practice), comparing aerobic exercise and dietary advice versus standard of care (exercise and dietary advice received as part of national health promotion). The reason for the choice of aerobic exercise and dietary advice is the impact of these interventions on indirect outcomes which may translate to clinical benefit. The outcomes in such trials should be mortality, health-related quality of life, decompensated liver cirrhosis, liver transplantation, and resource use measures including costs of intervention and decreased healthcare use after a minimum follow-up of eight years, to find meaningful differences in the clinically important outcomes

A comparison of chemistry and dust cloud formation in ultracool dwarf model atmospheres

The atmospheres of substellar objects contain clouds of oxides, iron, silicates, and other refractory condensates. Water clouds are expected in the coolest objects. The opacity of these `dust' clouds strongly affects both the atmospheric temperature-pressure profile and the emergent flux. Thus any attempt to model the spectra of these atmospheres must incorporate a cloud model. However the diversity of cloud models in atmospheric simulations is large and it is not always clear how the underlying physics of the various models compare. Likewise the observational consequences of different modeling approaches can be masked by other model differences, making objective comparisons challenging. In order to clarify the current state of the modeling approaches, this paper compares five different cloud models in two sets of tests. Test case 1 tests the dust cloud models for a prescribed L, L--T, and T-dwarf atmospheric (temperature T, pressure p, convective velocity vconv)-structures. Test case 2 compares complete model atmosphere results for given (effective temperature Teff, surface gravity log g). All models agree on the global cloud structure but differ in opacity-relevant details like grain size, amount of dust, dust and gas-phase composition. Comparisons of synthetic photometric fluxes translate into an modelling uncertainty in apparent magnitudes for our L-dwarf (T-dwarf) test case of 0.25 < \Delta m < 0.875 (0.1 < \Delta m M 1.375) taking into account the 2MASS, the UKIRT WFCAM, the Spitzer IRAC, and VLT VISIR filters with UKIRT WFCAM being the most challenging for the models. (abr.)Comment: 22 pages, 17 figures, MNRAS 2008, accepted, (minor grammar/typo corrections

Transradial Approach as a Default Route in Coronary Artery Interventions

Advances in percutaneous coronary intervention (PCI) and peri-procedural potent antithrombotic treatments during the past decade have dramatically improved the outcomes of ischemic heart disease. The femoral artery is the vascular route used in PCI in most catheterization labs. However, when the femoral artery is used as the approaching vessel, local hemorrhagic complication is not rare in the era of potent antithrombotics. Recent studies have suggested that peri-procedural bleeding complications after PCI are associated with increased short- and long-term morbidity and mortality. On the other hand, there has been growing interest in transradial PCI due to rare complications at the puncture site, patient conveniences, early discharge and shortened hospitalization periods. Furthermore, the indications of transradial PCI are expanding to the complex lesion subsets due to the miniaturization of devices used, improvement of devices and techniques, and accumulated experience with the use of transradial PCI. In this review, we discuss the data of transradial PCI as a potential default route in coronary artery interventions, as well as other issues that may raise concerns with transradial PCI

Endless Pressure: Life on a Low Income in Austere Times

© 2016 The Authors Social Policy & Administration Published by John Wiley & Sons Ltd Much has been written that details the decline in living standards following the ‘credit crunch’ in the UK. It remains that we understand to a lesser degree the lived reality of poverty through the Great Recession and into the era of austerity. This article draws on testimonies of 62 participants from low income households conducted in three different areas of the UK during 2012–13 to document the pressures that this period brought to bear on these households. According to these testimonies, the experience of poverty intensified in key respects: first, participants reported feeling, more than ever before, that they were ‘existing, rather than living’ due to the meagre budgets they were forced to live on; second, the precarious nature of work and social security contributed to a sense of insecurity that was all pervasive in our participants' lives; third, due to the pejorative political rhetoric and media coverage of poverty, our participants felt that their lives were placed under increased scrutiny which deleteriously impacted their wider relationships and sense of belonging. Our analysis demonstrates the profound consequences for those living on low incomes of the continued shift to residual forms of state welfare and the increased reliance on the ‘Big Society’ as a means to deal with the pressures identified in this article