The Proper Standard of Review for Required Party Determinations Under Federal Rule of Civil Procedure 19

Rule 19 of the Federal Rules of Civil Procedure, concerning the required joinder of parties, ensures that all parties with an interest in an action are joined in the litigation. At any time during the suit, a court may determine that an absent party has a specific interest that requires its presence in the dispute. When the court cannot join the absent party, however, the court must use Rule 19(b) to determine whether to continue the litigation without the absentee or dismiss the suit entirely. Despite the potentially drastic consequence of dismissal, federal courts of appeals cannot agree on the proper standard of review for Rule 19(b) decisions. Should the court review the decision de novo as if it were examining the issue for the first time? Or should it review for abuse of discretion with deference to the district court’s analysis? This Note explores the history and application of Rule 19 before examining the two standards of review and the factors set out by the Supreme Court in Pierce v. Underwood to help appellate courts determine which of the two standards should apply. This Note argues that an analysis of those factors demonstrates that both Rule 19(a) and 19(b) decisions should be reviewed for abuse of discretion. It proposes that reviewing courts should use the single standard, but that the amount of deference given to the district court opinion depends on the specific determination within the larger Rule 19 inquiry

UNBOUND

Featured here, are the extraordinary works of our graduating Fashion Design class. This accomplishment is truly a celebration of the tree years of passion, hard work, and dedication of our students. It\u27s our hope that the fashion industry will partake in the creative endeavors of the emerging designers from the Fashion Design program at Fanshawe College in London, Ontario.https://first.fanshawec.ca/famd_design_fashiondesign_unbound/1002/thumbnail.jp

Balanced translocation linked to psychiatric disorder, glutamate and cortical structure/function

Rare genetic variants of large effect can help elucidate the pathophysiology of brain disorders. Here we expand the clinical and genetic analyses of a family with a (1;11)(q42;q14.3) translocation multiply affected by major psychiatric illness and test the effect of the translocation on the structure and function of prefrontal, and temporal brain regions. The translocation showed significant linkage (LOD score 6.1) with a clinical phenotype that included schizophrenia, schizoaffective disorder, bipolar disorder, and recurrent major depressive disorder. Translocation carriers showed reduced cortical thickness in the left temporal lobe, which correlated with general psychopathology and positive psychotic symptom severity. They showed reduced gyrification in prefrontal cortex, which correlated with general psychopathology severity. Translocation carriers also showed significantly increased activation in the caudate nucleus on increasing verbal working memory load, as well as statistically significant reductions in the right dorsolateral prefrontal cortex glutamate concentrations. These findings confirm that the t(1;11) translocation is associated with a significantly increased risk of major psychiatric disorder and suggest a general vulnerability to psychopathology through altered cortical structure and function, and decreased glutamate levels

Verbal working memory and functional large-scale networks in schizophrenia

The aim of this study was to test whether bilinear and nonlinear effective connectivity (EC) measures of working memory fMRI data can differentiate between patients with schizophrenia (SZ) and healthy controls (HC). We applied bilinear and nonlinear Dynamic Causal Modeling (DCM) for the analysis of verbal working memory in 16 SZ and 21 HC. The connection strengths with nonlinear modulation between the dorsolateral prefrontal cortex (DLPFC) and the ventral tegmental area/substantia nigra (VTA/SN) were evaluated. We used Bayesian Model Selection at the group and family levels to compare the optimal bilinear and nonlinear models. Bayesian Model Averaging was used to assess the connection strengths with nonlinear modulation. The DCM analyses revealed that SZ and HC used different bilinear networks despite comparable behavioral performance. In addition, the connection strengths with nonlinear modulation between the DLPFC and the VTA/SN area showed differences between SZ and HC. The adoption of different functional networks in SZ and HC indicated neurobiological alterations underlying working memory performance, including different connection strengths with nonlinear modulation between the DLPFC and the VTA/SN area. These novel findings may increase our understanding of connectivity in working memory in schizophrenia

The Impact of Sprint Exercise Training on Vascular Functions in 50-70 y Olds

PURPOSE: Aging is a major risk factor for the development of cardiovascular disease due in part to increased oxidative stress and arterial stiffening. Lifestyle modifications, such as exercise, are among the first-line of approach for preventing vascular dysfunction. Exercise training has been shown to foster antioxidant states and improve vascular health. Therefore, the purpose of this study was to determine the effect of 8-weeks of sprint exercise training using inertial loading on vascular health in 50-70 y old. METHODS: Thirty-one apparently healthy middle-aged and older adults (59 ± 5 years, 17 females) participated in the study. The participants performed 15 sprints per training session week 1, 20 sprints per session weeks 2-4 and 30 sprints per session weeks 5-8 with 56s, 41s, and 26s of rest, respectively, between sprints. Training sessions occurred three times per week for 8 weeks. Each sprint consisted of 4s of all-out cycling where the participants accelerated a heavy flywheel from a stationary position to maximal angular velocity. They were instructed to keep pedaling throughout the duration of the 4s to achieve maximal power and cadence. Baseline and post intervention measurements of flow-mediated dilation (FMD; index of endothelium-dependent vasodilation), cardio-ankle vascular index (CAVI; indicator of arterial stiffness), and arterial blood pressure were made. RESULTS: CAVI decreased significantly following the 8-weeks of inertial load exercise training (2.38%; p=0.048). Additionally, grouping the participants by age or sex did not influence the reduction observed with CAVI. However, FMD and blood pressure did not change significantly (p≥0.05). CONCLUSIONS: The 8-weeks of exercise training using an inertial load ergometer decreased arterial stiffness in men and women 50-70 y. Future studies are needed to determine the efficacy of this type of exercise intervention in clinical populations to improve vascular function

Lethal impairment of cholinergic neurotransmission in hemicholinium-3-sensitive choline transporter knockout mice

Presynaptic acetylcholine (ACh) synthesis and release is thought to be sustained by a hemicholinium-3-sensitive choline transporter (CHT). We disrupted the murine CHT gene and examined CHT–/– and +/– animals for evidence of impaired cholinergic neurotransmission. Although morphologically normal at birth, CHT–/– mice become immobile, breathe irregularly, appear cyanotic, and die within an hour. Hemicholinium-3-sensitive choline uptake and subsequent ACh synthesis are specifically lost in CHT–/– mouse brains. Moreover, we observe a time-dependent loss of spontaneous and evoked responses at CHT–/– neuromuscular junctions. Consistent with deficits in synaptic ACh availability, we also observe developmental alterations in neuromuscular junction morphology reminiscent of changes in mutants lacking ACh synthesis. Adult CHT+/– mice overcome reductions in CHT protein levels and sustain choline uptake activity at wild-type levels through posttranslational mechanisms. Our results demonstrate that CHT is an essential and regulated presynaptic component of cholinergic signaling and indicate that CHT warrants consideration as a candidate gene for disorders characterized by cholinergic hypofunction

Thermochronological history of an orogen-passive margin system : an example from northern Mozambique

In this paper, we present a conceptual model to describe the post!Pan!African (<!500 Ma) basement cooling pattern for NE Mozambique. The cooling history is derived from combined low!temperature thermochronological dating methods comprising titanite, zircon and apatite fission track data. After Pan!African orogenesis (!620–530 Ma) the Precambrian basement was subject to extensional tectonics and a relatively slow Lower Ordovician to Recent cooling with rates of !2.2°C to 0.1°C Myr−1. Basement rock cooling was mainly a response to Late Paleozoic to Mesozoic rifting between northern Mozambique and East Gondwana during the opening of the Rovuma and Mozambique sedimentary basins. Meanwhile, different dynamic margin and basin types evolved along the eastern and southern continental margins of NE Mozambique. During the Late Carboniferous–Triassic an intracontinental rift opened between NE Mozambique and East Antarctica, and the fastest denudation was focused along the present southern continental margin. Since the Middle Jurassic, tectonic denudation along the Rovuma margin was localized in a narrow zone, some 30 km wide, associated with erosion along strike!slip faults. In contrast, the Jurassic! Cretaceous opening and ocean crust formation in the Mozambique Basin were accompanied with an unusually uniform Late Cretaceous cooling pattern over a large area (!150,000 km2) of the basin hinterland. This pattern can be explained by isostatic and erosional response to magmatic underplating or differential stretching, whereby the old Pan!African lithospheric structure appears to have important controls on later events

Individualised funding interventions to improve health and social care outcomes for people with a disability: a mixed-methods systematic review

The World Health Organisation estimates that 15% of the world’s population live with a disability and that this number will continue to grow into the future, but with the attendant challenge of increasing unmet need due to poor access to health and social care (WHO, 2013). Historically, the types of supports available to people with a disability were based on medical needs only. More recently, however, the importance of social care needs, such as keeping active and socialising, has been recognised (Malley et al., 2012). There is now an international policy imperative for people with a disability to live autonomous, self-determined lives whereby they are empowered and as independent as possible, choosing their supports and self-directing their lives (Perreault & Vallerand, 2007; Saebu, Sørensen, & Halvari, 2013). One way to achieve self-determination is by means of a personal budget (United Nations, 2006). Personal budgets are just one example of many terms used to describe individualised funding – a mechanism to provide personalised and self-directed supports for people with a disability, which places them at the centre of decision-making around how and when they are supported (Carr, 2010). Individualised funding – which is rooted in the Independent Living Movement (Jon Glasby & Littlechild, 2009) - has evolved to take many forms. These include, for example, directpayments, whereby funds are given directly to the person with a disability who then self-manages this money to meet their individual needs, capabilities, life circumstances and aspirations (Áiseanna Tacaíochta, 2014a). Alternatively, a microboard, brokerage model, or ‘managed’ personal budget provide a similar amount of freedom for the person with a disability, but an intermediary service assumes responsibility for administrative tasks, while sometimes also providing support, guidance and information to enable the person to successfully plan, arrange and manage their supports or care plans (Carr, 2010). Other types of models also exist, largely guided by country-specific contexts, such as social benefits systems