Tennessee’s Unique Religious Protections in Employment: Do They Mean What They Say?

Tennessee has a long history of strongly held and diverse religious beliefs and practices. Equally firmly established is its “at-will” employment rule that allows businesses to create and control their workforces to maximize operations and profits to the benefit of employers and employees. When an employee’s religious beliefs conflict with his obligations to his employer, state and federal laws resolve the tension. Employees who experience this tension and feel they have been discriminated against based on their religion generally have the choice to bring their claims of discrimination under federal law, state law, or both. Because claims under federal law may be removed to federal court, and because state courts are generally perceived to be more favorable to employees, some employees strategically elect to pursue only selected state law claims. An employee might also be forced to bring a claim only under state law if she works for a small employer, since the federal law’s reach is limited to employers with at least fifteen employees. This Article examines whether a Tennessee employee who brings claims only under Tennessee’s statutory protection against religious discrimination in employment has the same protections as he would if he proceeded under federal law. Part I discusses employers’ obligations under the Tennessee Human Rights Act (“THRA”), the primary Tennessee religious anti-discrimination statute, and Title VII of the Civil Rights Act of 1964 (“Title VII”), the primary federal religious anti-discrimination law. Part II discusses the background of both the THRA and Title VII and how it informs the analysis. Part III proposes that the THRA not be interpreted to import the reasonable accommodation requirement from Title VII. This interpretation is consistent with the textual language of the statute, courts’ interpretation of the Tennessee Disability Act, existing case law, and Tennessee’s history of limiting exceptions to the at-will employment doctrine. The Article proposes that this different interpretation is more consistent with the THRA as it is currently written and invites discussion of whether this interpretation is ultimately better for employees and employers

Resolved Spectroscopy of the Narrow-Line Region in NGC 1068. I. The Nature of the Continuum Emission

We present the first long-slit spectra of the Seyfert 2 galaxy NGC 1068 obtained by the Space Telescope Imaging Spectrograph (STIS); the spectra cover the wavelength range 1150 - 10,270 Angstroms at a spatial resolution of 0.05 - 0.1 arcsec and a spectral resolving power of 1000. In this first paper, we concentrate on the far-UV to near-IR continuum emission from the continuum ``hot spot'' and surrounding regions extending out to +/- 6 arcsec (+/-432 pc) at a position angle of 202 degrees In addition to the broad emission lines detected by spectropolarimetry, the hot spot shows the ``little blue bump'' in the 2000 - 4000 Ang. range, which is due to Fe II and Balmer continuum emission. The continuum shape of the hot spot is indistinguishable from that of NGC 4151 and other Seyfert 1 galaxies. Thus, the hot spot is reflected emission from the hidden nucleus, due to electron scattering (as opposed to wavelength-dependent dust scattering). The hot spot is ~0.3 arcsec in extent and accounts for 20% of the scattered light in the inner 500 pc. We are able to deconvolve the extended continuum emission in this region into two components: electron-scattered light from the hidden nucleus (which dominates in the UV) and stellar light (which dominates in the optical and near-IR). The scattered light is heavily concentrated towards the hot spot, is stronger in the northeast, and is enhanced in regions of strong narrow-line emission. The stellar component is more extended, concentrated southwest of the hot spot, dominated by an old (> 2 x 10 Gyr) stellar population, and includes a nuclear stellar cluster which is ~200 pc in extent.Comment: 32 pages, Latex, includes 11 figures (postscript), to appear in the Astrophysical Journa

Significant X-ray Line Emission in the 5-6 keV band of NGC 4051

A Suzaku X-ray observation of NGC 4051 taken during 2005 Nov reveals line emission at 5.44 keV in the rest-frame of the galaxy which does not have an obvious origin in known rest-frame atomic transitions. The improvement to the fit statistic when this line is accounted for establishes its reality at >99.9% confidence: we have also verified that the line is detected in the three XIS units independently. Comparison between the data and Monte Carlo simulations shows that the probability of the line being a statistical fluctuation is p < 3.3 x 10^-4. Consideration of three independent line detections in Suzaku data taken at different epochs yields a probability p< 3 x 10^-11 and thus conclusively demonstrates that it cannot be a statistical fluctuation in the data. The new line and a strong component of Fe Ka emission from neutral material are prominent when the source flux is low, during 2005. Spectra from 2008 show evidence for a line consistent with having the same flux and energy as that observed during 2005, but inconsistent with having a constant equivalent width against the observed continuum. The stability of the line flux and energy suggests that it may not arise in transient hotspots, as has been suggested for similar lines in other sources, but could arise from a special location in the reprocessor, such as the inner edge of the accretion disk. Alternatively, the line energy may be explained by spallation of Fe into Cr, as discussed in a companion paper.Comment: 18 pages, accepted for publication by Ap

Simultaneous X-ray and Ultraviolet spectroscopy of the Seyfert galaxy NGC 5548. III. X-ray time variability

The Seyfert 1 galaxy NGC 5548 was observed for a week by Chandra using both the HETGS and LETGS spectrometers. In this paper we study the time variability of the continuum radiation. During our observation, the source showed a gradual increase in flux over four days, followed by a rapid decrease and flattening of the light curve afterwards. Superimposed upon these relatively slow variations several short duration bursts or quasi-periodic oscillations occured with a typical duration of several hours and separation between 0.6-0.9 days. The bursts show a delay of the hard X-rays with respect to the soft X-rays of a few hours. We interprete these bursts as due to a rotating, fluctuating hot spot at approximately 10 gravitational radii; the time delay of the hard X-rays from the bursts agree with the canonical picture of Inverse Compton scattering of the soft accretion disk photons on a hot medium that is relatively close to the central black hole.Comment: 6 pages, 7 figures, accepted for publication in Astronomy and Astrophysic

Outflows in the Narrow Line Region of Bright Seyfert Galaxies - I: GMOS-IFU Data

We present two-dimensional maps of emission-line fluxes and kinematics, as well as of the stellar kinematics of the central few kpc of five bright nearby Seyfert galaxies -- Mrk\,6, Mrk\,79, Mrk\,348, Mrk\,607 and Mrk\,1058 -- obtained from observations with the Gemini Multi-Object Spectrograph (GMOS) Integral Field Unit (IFU) on the Gemini North Telescope. The data cover the inner 3\farcs5$\times$5\farcs0 -- corresponding to physical scales in the range 0.6$\times$0.9 to 1.5$\times$2.2\,kpc$^2$ -- at a spatial resolution ranging from 110 to 280 pc with a spectral coverage of 4300 -- 7100\,\AA\ and velocity resolution of $\approx$ 90\,km\,s$^{-1}$. The gas excitation is Seyfert like everywhere but show excitation, but show excitation gradients that are correlated with the gas kinematics, reddening and/or the gas density. The gas kinematics show in all cases two components: a rotation one similar to that observed in the stellar velocity field, and an outflow component. In the case of Mrk607, the gas is counter-rotating relative to the stars. Enhanced gas velocity dispersion is observed in association to the outflows according to two patterns: at the locations of the highest outflow velocities along the ionization axis or perpendicularly to it in a strip centered at the nucleus that we attribute to an equatorial outflow. Bipolar outflows are observed in Mrk\,348 and Mrk\,79, while in Mrk\,1058 only the blueshifted part is clearly observed, while in the cases of Mrk\,6 and Mrk\,607 the geometry of the outflow needs further constraints from modeling to be presented in a forthcoming study, where the mass flow rate and powers will also be obtained.Comment: 20 pages, accepted by MNRA

High Velocity Line Emission in the NLR of NGC 4151

Narrow-band imaging of the nuclear region of NGC 4151 with the Hubble Space Telescope is presented. The filter bandpasses isolate line emission in various high velocity ranges in several ions. Slitless and long-slit spectra of the region with the Space Telescope Imaging Spectrograph also indicate the locations of high velocity gas. These emission regions are faint and are interspersed among the bright emission clouds seen in direct images. They have radial velocities up to 1400 km/s relative to the nucleus, and are found in both approach and recession on both sides of the nucleus. This contrasts strongly with the bright emission line clouds which have been discussed previously as showing bidirectional outflow with velocities within 400 km/s of the nucleus. We discuss the possible connections of the high velocity material with the radio jet and the nuclear radiation.Comment: 12 pages plus 6 figures, to be published in A

Interpretation of UV Absorption Lines in SN1006

We present a theoretical interpretation of the broad silicon and iron UV absorption features observed with the Hubble Space Telescope in the spectrum of the Schweizer-Middleditch star behind the remnant of Supernova 1006. These features are caused by supernova ejecta in SN1006. We propose that the redshifted SiII2 1260 A feature consists of both unshocked and shocked SiII. The sharp red edge of the line at 7070 km/s indicates the position of the reverse shock, while its Gaussian blue edge reveals shocked Si with a mean velocity of 5050 km/s and a dispersion of 1240 km/s, implying a reverse shock velocity of 2860 km/s. The measured velocities satisfy the energy jump condition for a strong shock, provided that all the shock energy goes into ions, with little or no collisionless heating of electrons. The line profiles of the SiIII and SiIV absorption features indicate that they arise mostly from shocked Si. The total mass of shocked and unshocked Si inferred from the SiII, SiIII and SiIV profiles is M_Si = 0.25 \pm 0.01 Msun on the assumption of spherical symmetry. Unshocked Si extends upwards from 5600 km/s. Although there appears to be some Fe mixed with the Si at lower velocities < 7070 km/s, the absence of FeII absorption with the same profile as the shocked SiII suggests little Fe mixed with Si at higher (before being shocked) velocities. The column density of shocked SiII is close to that expected for SiII undergoing steady state collisional ionization behind the reverse shock, provided that the electron to SiII ratio is low, from which we infer that most of the shocked Si is likely to be of a fairly high degree of purity, unmixed with other elements. We propose that the ambient interstellar density on the far side of SN1006 is anomalously low compared to the density around the rest of the remnant. ThisComment: 24 pages, with 8 figures included. Accepted for publication in the Astrophysical Journa

STIS Longslit Spectroscopy Of The Narrow Line Region Of NGC 4151. I. Kinematics and Emission Line Ratios

Longslit spectra of the Seyfert galaxy NGC 4151 from the UV to near infrared have been obtained with STIS to study the kinematics and physical conditions in the NLR. The kinematics show evidence for three components, a low velocity system in normal disk rotation, a high velocity system in radial outflow at a few hundred km/s relative to the systemic velocity and an additional high velocity system also in outflow with velocities up to 1400 km/s, in agreement with results from STIS slitless spectroscopy (Hutchings et al., 1998, Kaiser et al., 1999, Hutchings et al., 1999) We have explored two simple kinematic models and suggest that radial outflow in the form of a wind is the most likely explanation. We also present evidence indicating that the wind may be decelerating with distance from the nucleus. We find that the emission line ratios along our slits are all entirely consistent with photoionization from the nuclear continuum source. A decrease in the [OIII]5007/H-beta and [OIII]5007/[OII]3727 ratios suggests that the density decreases with distance from the nucleus. This trend is borne out by the [SII] ratios as well. We find no strong evidence for interaction between the radio jet and the NLR gas in either the kinematics or the emission line ratios in agreement with the results of Kaiser et al. (1999) who find no spatial coincidence of NLR clouds and knots in the radio jet. These results are in contrast to other recent studies of nearby AGN which find evidence for significant interaction between the radio source and the NLR gas.Comment: 32 pages, 13 figures, accepted for publication in The Astrophysical Journa

On the Effects of Dissipative Turbulence on the Narrow Emission-Line Ratios in Seyfert Galaxies

We present a photoionization model study of the effects of micro-turbulence and dissipative heating on emission lines for number and column densities, elemental abundances, and ionizations typical for the narrow emission line regions (NLRs) of Seyfert galaxies. Earlier studies of NLR spectra generally found good agreement between the observations and the model predictions for most strong emission lines, such as [O III] $\lambda$5007, [O II] $\lambda$3727, [N II] $\lambda$6583, [Ne III] $\lambda$3869, and the H and He recombination lines. Nevertheless, the strengths of lines from species with ionization potentials greater than that of He$^{+}$(54.4 eV), e.g. N$^{+4}$ and Ne$^{+4}$, were often under-predicted. Among the explanations suggested for these discrepancies were (selectively) enhanced elemental abundances and contributions from shock heated gas. Interestingly, the NLR lines have widths of several 100 km s$^{-1}$, well in excess of the thermal broadening. If this is due to micro-turbulence, and the turbulence dissipates within the emission-line gas, the gas can be heated in excess of that due to photoionization. We show that the combined effects of turbulence and dissipative heating can strongly enhance N V $\lambda$1240 (relative to He II $\lambda$1640), while the heating alone can boost the strength of [Ne V] $\lambda$3426. We suggest that this effect is present in the NLR, particularly within $\sim$ 100 pc of the central engine. Finally, since micro-turbulence would make clouds robust against instabilities generated during acceleration, it is not likely to be a coincidence that the radially outflowing emission-line gas is turbulent.Comment: 29 oages, including 10 figures. Accepted for publication in the Astrophysical Journa