Neutralizing the Stratagem of “Snap Removal”: A Proposed Amendment to the Judicial Code

The “Removal Jurisdiction Clarification Act” is a narrowly tailored legislative proposal designed to resolve a widespread conflict in the federal district courts over the proper interpretation of the statutory “forum-defendant” rule. The forum-defendant rule prohibits removal of a diversity case “if any of the parties in interest properly joined and served as defendants is a citizen of the [forum state].” 28 U.S.C. § 1441(b)(2) (emphasis added). Some courts, following the “plain language” of the statute, hold that defendants can avoid the constraints of the rule by removing diversity cases to federal court when a citizen of the forum state has been joined as a defendant but has not yet been served. This stratagem has been referred to as “snap removal.” Other courts reject the stratagem. They take a “purposive” approach, typically reasoning that following the plain language “produces a result that is at clear odds with congressional intent.” Resolution of the conflict can come only from Congress. The preferable resolution is to neutralize the stratagem of snap removal by requiring district courts to remand cases to the appropriate state court if, after removal, the plaintiff timely serves one or more forum defendants and a timely motion to remand follows. That is the approach taken by the proposed legislation. The legislation also would confirm that the forum-defendant rule is not jurisdictional, endorsing the position taken by all but one of the circuits that have considered the question

Ferromagnetic Film on a Superconducting Substrate

We study the equilibrium domain structure and magnetic flux around a ferromagnetic (FM) film with perpendicular magnetization M_0 on a superconducting (SC) substrate. At 4{\pi}M_0<H_{c1} the SC is in the Meissner state and the equilibrium domain width in the film, l, scales as (l/4{\pi}{\lambda}_{L}) = (l_{N}/4{\pi}{\lambda}_{L})^{2/3} with the domain width on a normal (non-superconducting) substrate, l_{N}/4\pi\lambda_L >> 1. Here \lambda_L is the London penetration length. For 4{\pi}M_0 > H_{c1} and l_{N} in excess of about 35 {\lambda}_{L}, the domains are connected by SC vortices. We argue that pinning of vortices by magnetic domains in FM/SC multilayers can provide high critical currents.Comment: 4 pages, 2 figures, submitted to PR

Two-Level Systems in Evaporated Amorphous Silicon

In $e$-beam evaporated amorphous silicon ($a$-Si), the densities of two-level systems (TLS), $n_{0}$ and $\overline{P}$, determined from specific heat $C$ and internal friction $Q^{-1}$ measurements, respectively, have been shown to vary by over three orders of magnitude. Here we show that $n_{0}$ and $\overline{P}$ are proportional to each other with a constant of proportionality that is consistent with the measurement time dependence proposed by Black and Halperin and does not require the introduction of additional anomalous TLS. However, $n_{0}$ and $\overline{P}$ depend strongly on the atomic density of the film ($n_{\rm Si}$) which depends on both film thickness and growth temperature suggesting that the $a$-Si structure is heterogeneous with nanovoids or other lower density regions forming in a dense amorphous network. A review of literature data shows that this atomic density dependence is not unique to $a$-Si. These findings suggest that TLS are not intrinsic to an amorphous network but require a heterogeneous structure to form

Phonon quarticity induced by changes in phonon-tracked hybridization during lattice expansion and its stabilization of rutile TiO2_2

Although the rutile structure of TiO$_2$ is stable at high temperatures, the conventional quasiharmonic approximation predicts that several acoustic phonons decrease anomalously to zero frequency with thermal expansion, incorrectly predicting a structural collapse at temperatures well below 1000\,K. Inelastic neutron scattering was used to measure the temperature dependence of the phonon density of states (DOS) of rutile TiO$_2$ from 300 to 1373\,K. Surprisingly, these anomalous acoustic phonons were found to increase in frequency with temperature. First-principles calculations showed that with lattice expansion, the potentials for the anomalous acoustic phonons transform from quadratic to quartic, stabilizing the rutile phase at high temperatures. In these modes, the vibrational displacements of adjacent Ti and O atoms cause variations in hybridization of $3d$ electrons of Ti and $2p$ electrons of O atoms. With thermal expansion, the energy variation in this "phonon-tracked hybridization" flattens the bottom of the interatomic potential well between Ti and O atoms, and induces a quarticity in the phonon potential.Comment: 7 pages, 6 figures, supplemental material (3 figures

Lattice dynamics of anharmonic solids from first principles

An accurate and easily extendable method to deal with lattice dynamics of solids is offered. It is based on first-principles molecular dynamics simulations and provides a consistent way to extract the best possible harmonic - or higher order - potential energy surface at finite temperatures. It is designed to work even for strongly anharmonic systems where the traditional quasiharmonic approximation fails. The accuracy and convergence of the method are controlled in a straightforward way. Excellent agreement of the calculated phonon dispersion relations at finite temperature with experimental results for bcc Li and bcc Zr is demonstrated

Phonon self-energy and origin of anomalous neutron scattering spectra in SnTe and PbTe thermoelectrics

The anharmonic lattice dynamics of rock-salt thermoelectric compounds SnTe and PbTe are investigated with inelastic neutron scattering (INS) and first-principles calculations. The experiments show that, surprisingly, although SnTe is closer to the ferroelectric instability, phonon spectra in PbTe exhibit a more anharmonic character. This behavior is reproduced in first-principles calculations of the temperature-dependent phonon self-energy. Our simulations reveal how the nesting of phonon dispersions induces prominent features in the self-energy, which account for the measured INS spectra and their temperature dependence. We establish that the phase-space for three-phonon scattering processes, rather than just the proximity to the lattice instability, is the mechanism determining the complex spectrum of the transverse-optical ferroelectric mode

A vocabulary-independent generation framework for DBpedia and beyond

The dbpedia Extraction Framework, the generation framework behind one of the Linked Open Data cloud’s central hubs, has limitations which lead to quality issues with the dbpedia dataset. Therefore, we provide a new take on its Extraction Framework that allows for a sustainable and general-purpose Linked Data generation framework by adapting a semantic-driven approach. The proposed approach decouples, in a declarative manner, the extraction, transformation, and mapping rules execution. This way, among others, interchanging different schema annotations is supported, instead of being coupled to a certain ontology as it is now, because the dbpedia Extraction Framework allows only generating a certain dataset with a single semantic representation. In this paper, we shed more light to the added value that this aspect brings. We provide an extracted dbpedia dataset using a different vocabulary, and give users the opportunity to generate a new dbpedia dataset using a custom combination of vocabularies

Mechanism for Limiting Thickness of Thin Oxide Films on Aluminum

A first-principles account of the observed limiting thickness of oxide films formed on aluminum during oxidizing conditions is presented. The results uncover enhanced bonding of oxygen to thin alumina films in contact with metallic aluminum that stems from charge transfer between a reconstructed oxide-metal interface and the adsorbed molecules. The first-principles results are compared with the traditional Cabrera-Mott (CM) model, which is a classical continuum model. Within the CM model, charged surface oxygen species and metal ions generate a (Mott) potential that drives oxidation. An apparent limiting thickness is observed as the oxidation rate decreases rapidly with film growth. The present results support experimental estimates of the Mott potential and film thicknesses. In contrast to the CM model, however, the calculations reveal a real limiting thickness that originates from a diminishing oxygen adsorption energy beyond a certain oxide film thickness