Commerce Clause, Enforcement Clause, or Neither? The Constitutionality of the Violence Against Women Act in Brzonkala v. Morrison

On September 21, 1994, two men raped Christy Brzonkala in her dormitory room at Virginia Polytechnic Institute and State Univer- sity( VirginiaTech ). Unfortunately,this kind of event is not a rare occurrence in the United States. According to the U.S. Department of Justice Bureau of Justice Statistics ( BJS ), women are the victims of more than 4.5 million violent crimes each year. This alarming figure includes approximately 500,000 rapes or other sexual assaults. In light of these statistics, and after four years of hearings, Congress enacted [the Violence Against Women Act of 1994 ( VAWA or the Act )], a comprehensive federal statute designed to address \u27the escalating problem of violent crime against women. Title III of the VAWA establishes a federal substantive right that all persons within the United States shall have the right to be free from crimes o fgender-motivated violence. To enforce this right, the Act creates a private cause of action against any person committing a gender-motivated crime and allows compensatory damages, punitive damages, injunctive, declaratory, or any other appropriate relief

The lithium depletion boundary and the age of NGC 2547

We present the results of a photometric and spectroscopic survey of cool M dwarf candidates in the young open cluster NGC 2547. Using the 2dF fiber spectrograph, we have searched for the luminosity at which lithium remains unburned in an attempt to constrain the cluster age. The lack of a population of individual lithium-rich objects towards the faint end of our sample places a very strong lower limit to the cluster age of 35 Myr. However, the detection of lithium in the averaged spectra of our faintest targets suggests that the lithium depletion boundary lies at 9.5 < M(I) < 10.0 and that the cluster age is < 54 Myr. The age of NGC 2547 judged from fitting isochrones to low-mass pre-main-sequence stars in colour-magnitude diagrams is 20-35 Myr using the same evolutionary models. The sense and size of the discrepancy in age determined by these two techniques is similar to that found in another young cluster, IC 2391, and in the low-mass pre main-sequence binary system, GJ 871.1AB. We suggest that the inclusion of rotation or dynamo-generated magnetic fields in the evolutionary models could reconcile the two age determinations, but only at the expense of increasing the cluster ages beyond that currently indicated by the lithium depletion. Alternatively, some mechanism is required that increases the rate of lithium depletion in young, very low-mass fully convective stars.Comment: 14 pages, 7 figures, 3 tables, accepted by MNRA

13 million years of seafloor spreading throughout the Red Sea Basin

The crustal and tectonic structure of the Red Sea and especially the maximum northward extent of the (ultra)slow Red Sea spreading centre has been debated—mainly due to a lack of detailed data. Here, we use a compilation of earthquake and vertical gravity gradient data together with high-resolution bathymetry to show that ocean spreading is occurring throughout the entire basin and is similar in style to that at other (ultra)slow spreading mid-ocean ridges globally, with only one first-order offset along the axis. Off-axis traces of axial volcanic highs, typical features of (ultra)slow-spreading ridges, are clearly visible in gravity data although buried under thick salt and sediments. This allows us to define a minimum off-axis extent of oceanic crust of <55 km off the coast along the complete basin. Hence, the Red Sea is a mature ocean basin in which spreading began along its entire length 13 Ma ago

Geochemistry of lavas from Mohns Ridge, Norwegian-Greenland Sea: implications for melting conditions and magma sources near Jan Mayen

Mohns Ridge lavas between 71 and 72°30′N (∼360 km) have heterogeneous compositions varying between alkali basalts and incompatible-element-depleted tholeiites. On a large scale there is a continuity of incompatible element and isotopic compositions between the alkali basalts from the island Jan Mayen and Mohns Ridge tholeiites. The variation in isotopes suggests a heterogeneous mantle which appears to be tapped preferentially by low degree melts (∼5%) close to Jan Mayen but also shows its signature much further north on Mohns Ridge. Three lava types with different incompatible element compositions [e.g. chondrite-normalized (La/Sm)N2] occur in the area at 72°N and were generated from this heterogeneous mantle. The relatively depleted tholeiitic melts were mixed with a small degree melt from an enriched source. The elements Ba, Rb and K of the enriched melt were probably buffered in the mantle by residual amphibole or phlogopite. That such a residual phase is stable in this region of oceanic mantle suggests both high water contents and low mantle temperatures, at odds with a hotspot origin for Jan Mayen. Instead we suggest that the melting may be induced by the lowered solidus temperature of a “wet” mantle. Mohns MORB (mid ocean ridge basalt) and Jan Mayen area alkali basalts have high contents of Ba and Rb compared to other incompatible elements (e.g. Ba/La >10). These ratios reflect the signature of the mantle source. Ratios of Ce/Pb and Rb/Cs are normal MORB mantle ratios of 25 and 80, respectively, thus the enrichments of Ba and Rb are not indicative of a sedimentary component added to the mantle source but were probably generated by the influence of a metasomatizing fluid, as supported by the presence of hydrous phases during the petrogenesis of the alkali basalts. Geophysical and petrological models suggest that Jan Mayen is not the product of hotspot activity above a mantle plume, and suggest instead that it owes its existence to the unique juxtaposition of a continental fragment, a fracture zone and a spreading axis in this part of the North Atlantic

Mineralogical, geochemical and isotopic characteristics of hydrothermal alteration processes in the active, submarine, felsic-hosted PACMANUS field, Manus Basin, Papua New Guinea

During ODP Leg 193, 4 sites were drilled in the active PACMANUS hydrothermal field on the crest of the felsic Pual Ridge to examine the vertical and lateral variations in mineralization and alteration patterns. We present new data on clay mineral assemblages, clay and whole rock chemistry and clay mineral strontium and oxygen isotopic compositions of altered rocks from a site of diffuse low-temperature venting (Snowcap, Site 1188) and a site of high-temperature venting (Roman Ruins, Site 1189) in order to investigate the water-rock reactions and associated elemental exchanges. The volcanic succession at Snowcap has been hydrothermally altered, producing five alteration zones: (1) chlorite +/- illite-cristobalite-plagioclase alteration apparently overprinted locally by pyrophyllite bleaching at temperatures of 260-310degreesC; (2) chlorite +/- mixed-layer clay alteration at temperatures of 230degreesC; (3) chlorite and illite alteration; (4) illite and chlorite +/- illite mixed-layer alteration at temperatures of 250-260degreesC; and (5) illite +/- chlorite alteration at 290-300degreesC. Felsic rocks recovered from two holes (1189A and 1189B) at Roman Ruins, although very close together, show differing alteration features. Hole 1189A is characterized by a uniform chlorite-illite alteration formed at similar to250degreesC, overprinted by quartz veining at 350degreesC. In contrast, four alteration zones occur in Hole 1189B: (1) illite chlorite alteration formed at similar to300degreesC; (2) chlorite +/- illite alteration at 235degreesC; (3) chlorite illite and. mixed layer clay alteration; and (4) chlorite illite alteration at 220degreesC. Mass balance calculations indicate that the chloritization, illitization and bleaching (silica-pyrophyllite assemblages) alteration stages are accompanied by different chemical changes relative to a calculated pristine precursor lava. The element Cr appears to have a general enrichment in the altered samples from PACMANUS. The clay concentrate data show that Cr and Cu are predominantly present in the pyrophyllites. Illite shows a significant enrichment for Cs and Cu relative to the bulk altered samples. Considerations of mineral stability allow us to place some constraints on fluid chemistry. Hydrothermal fluid pH for the chloritization and illitization was neutral to slightly acidic and relatively acidic for the pyrophyllite alteration. In general the fluids, especially from Roman Ruins and at intermediate depths below Snowcap, show only a small proportion of seawater mixing (<10%). Fluids in shallow and deep parts of the Snowcap holes, in contrast, show stronger seawater influence. Copyright (C) 2004 Elsevier Ltd

Seawater cycled throughout Earth's mantle in partially serpentinized lithosphere

The extent to which water and halogens have primordial origins in the Earth's mantle, or are dominated by seawater-derived components introduced by subduction, remains a matter of debate. About 90% of non-radiogenic xenon in the Earth's mantle has a subducted atmospheric origin, but the degree to which atmospheric gases and other seawater components are coupled during subduction is unclear. Here we present the concentrations of water and halogens in samples of magmatic glasses collected from global mid-ocean ridges and ocean islands. We show that water and halogen enrichment is unexpectedly associated with trace element signatures characteristic of dehydrated oceanic crust, and that the most incompatible halogens have relatively uniform abundance ratios that are different from primitive mantle values. Taken together, these results imply that Earth's mantle is highly processed and that most of its water and halogens were introduced by the subduction of serpentinised lithospheric mantle associated with dehydrated oceanic crust.Australian Research Council (FT130100141

Ischemic preconditioning in the liver is independent of regulatory T cell activity

Ischemic preconditioning (IPC) protects organs from ischemia reperfusion injury (IRI) through unknown mechanisms. Effector T cell populations have been implicated in the pathogenesis of IRI, and T regulatory cells (Treg) have become a putative therapeutic target, with suggested involvement in IPC. We explored the role of Treg in hepatic IRI and IPC in detail. IPC significantly reduced injury following ischemia reperfusion insults. Treg were mobilized rapidly to the circulation and liver after IRI, but IPC did not further increase Treg numbers, nor was it associated with modulation of circulating pro-inflammatory chemokine or cytokine profiles. We used two techniques to deplete Treg from mice prior to IRI. Neither Treg depleted FoxP3.LuciDTR mice, nor wildtyoe mice depleted of Tregs with PC61, were more susceptible to IRI compared with controls. Despite successful enrichment of Treg in the liver, by adoptive transfer of both iTreg and nTreg or by in vivo expansion of Treg with IL-2/anti-IL-2 complexes, no protection against IRI was observed.We have explored the role of Treg in IRI and IPC using a variety of techniques to deplete and enrich them within both the liver and systemically. This work represents an important negative finding that Treg are not implicated in IPC and are unlikely to have translational potential in hepatic IRI