National Juries for National Cases: Preserving Citizen Participation in Large-Scale Litigation

Procedural evolution in complex litigation seems to have left the civil jury behind. Reliance on aggregating devices, such as multidistrict litigation and class actions, as well as settlement pressure created by “bellwether” cases, has resulted in cases of national scope being tried by local juries. Local juries thus have the potential to impose their values on the rest of the country. This trend motivates parties to forum-shop, and some commentators suggest eliminating jury trials in complex cases altogether. Yet the jury is at the heart of our uniquely American understanding of civil justice, and the Seventh Amendment mandates its use in federal cases. This Article makes a bold proposal to align the jury assembly mechanism with the scope of the litigation: In cases of national scope, juries would be assembled from a national pool. This proposal would eliminate incentives for parties to forum-shop, and it would make the decisionmaking body representative of the population that will feel the effects of its decision. The Article argues that we would see greater legitimacy for decisions rendered by a national jury in national cases. Moreover, it argues that geographic diversification of the jury would enhance the quality of decisionmaking. Finally, national juries would preserve the functional and constitutional values of citizen participation in the civil justice system

A new species of Dialeurodes Cockerell (Hemiptera: Aleyrodidae) on Schefflera Forst and Forst in Florida

Descriptions of pupal cases of Dialeurodes schefflerae, new species, as well as distribution records are presented. This species is known to occur in Florida, Hawaii and Puerto Rico appearing to feed only on species of Schefflera Forst and Forst. This restriction to plant hosts in the Asian genus Schefflera, along with its affinities with Dialeurodes agalmae Takahashi, Dialeurodes citri (Ashmead) and Dialeurodes kirkaldyi (Kotinsky), suggests it is an invasive species, probably endemic to the Asian region

Time division access feasibility study modulation and synchronization considerations

Time division access system for satellite communications, and figure of merit for effects of bit and frequency synchronizatio

Fuzzy image segmentation of generic shaped clusters

The segmentation performance of any clustering algorithm is very sensitive to the features in an image, which ultimately restricts their generalisation capability. This limitation was the primary motivation in our investigation into using shape information to improve the generality of these algorithms. Fuzzy shape-based clustering techniques already consider ring and elliptical profiles in segmentation, though most real objects are neither ring nor elliptically shaped. This paper addresses this issue by introducing a new shape-based algorithm called fuzzy image segmentation of generic shaped clusters (FISG) that incorporates generic shape information into the framework of the fuzzy c-means (FCM) algorithm. Both qualitative and quantitative analyses confirm the superiority of FISG compared to other shape-based fuzzy clustering methods including, Gustafson-Kessel algorithm, ring-shaped, circular shell, c-ellipsoidal shells and elliptic ring-shaped clusters. The new algorithm has also been shown to be application independent so it can be applied in areas such as video object plane segmentation in MPEG-4 based coding

The Dilution Effect: Federalization, Fair Cross-Sections, and the Concept of Community

The question of the relevant community from which a fair cross-section of jurors should be drawn has received little theoretical attention. This article seeks to fill that gap by using communitarian and postmodern theory to give content to the idea of community in the fair cross-section context. This analysis is timely and has grave practical importance, given that the federal government is increasingly assuming the prosecution of crime previously dealt with at the state level. This federalization of criminal enforcement has the second-order effect of changing the community from which criminal juries will be drawn, particularly in urban areas surrounded by white suburban collar counties, in a way that dilutes minority participation in the jury system

Enhanced tidal stripping of satellites in the galactic halo from dark matter self-interactions

We investigate the effects of self-interacting dark matter (SIDM) on the tidal stripping and evaporation of satellite galaxies in a Milky Way-like host. We use a suite of five zoom-in, dark-matter-only simulations, two with velocity-independent SIDM cross sections, two with velocity-dependent SIDM cross sections, and one cold dark matter simulation for comparison. After carefully assigning stellar mass to satellites at infall, we find that stars are stripped at a higher rate in SIDM than in CDM. In contrast, the total bound dark matter mass loss rate is minimally affected, with subhalo evaporation having negligible effects on satellites for viable SIDM models. Centrally located stars in SIDM haloes disperse out to larger radii as cores grow. Consequently, the half-light radius of satellites increases, stars become more vulnerable to tidal stripping, and the stellar mass function is suppressed. We find that the ratio of core radius to tidal radius accurately predicts the relative strength of enhanced SIDM stellar stripping. Velocity-independent SIDM models show a modest increase in the stellar stripping effect with satellite mass, whereas velocity-dependent SIDM models show a large increase in this effect towards lower masses, making observations of ultra-faint dwarfs prime targets for distinguishing between and constraining SIDM models. Due to small cores in the largest satellites of velocity-dependent SIDM, no identifiable imprint is left on the all-sky properties of the stellar halo. While our results focus on SIDM, the main physical mechanism of enhanced tidal stripping of stars apply similarly to satellites with cores formed via other means.Comment: 19 pages, 18 figures, Accepted by MNRA

Magnetostriction of single crystal and polycrystalline Tb0.60Dy0.40 at cryogenic temperatures

At cryogenic temperatures, single crystals of TbDy alloys exhibit giant magnetostrictions of nearly 9000 ppm, making these materials promising for engineering service in cryogenic actuators, valves, and positioners. The preparation of single crystals is difficult and costly. Preliminary results on the magnetostriction of textured polycrystalline materials are presented here. For instance, polycrystalline Tb0.60Dy0.40, plane-rolled (one direction of applied stress) to induce crystallographic texture, has shown magnetostrictions at 77 K of 3000 ppm for an applied field of 4.5 kOe and an applied load of 23 MPa, or 48% that of a single crystal under similar conditions. Comparisons are presented between the magnetostrictive response of plane- and form-rolled (two orthogonal directions of applied stress) polycrystalline Tb0.60Dy0.40 at 10 and 77 K. It is reported that at 10 K plane-rolled Tb0.60Dy0.40 exhibits 1600 ppm magnetostriction at an applied field of 4.4 kOe with a minimal applied load of 0.28 MPa. An observed restoration of the initial unstrained state may be a useful feature of polycrystalline materials for engineering service. Finally it is reported that thermal expansion measurements provide a measure of crystallographic texture for comparison with the magnetostriction

Extended fuzzy rules for image segmentation

The generic fuzzy rule-based image segmentation (GFRIS) technique does not produce good results for non-homogeneous regions that possess abrupt changes in pixel intensity, because it fails to consider two important properties of perceptual grouping, namely surroundedness and connectedness. A new technique called extended fuzzy rules for image segmentation (EFRIS) is proposed, which includes a second rule to that defined already in GFRIS, that incorporates both the surroundedness and connectedness properties of a region's pixels. This additional rule is based on a split-and-merge algorithm and refines the output from the GFRIS technique. Two different classes of image, namely light intensity and medical X-rays are empirically used to assess the performance of the new technique. Quantitative evaluation of the performance of EFRIS is discussed and contrasted with GFRIS using one of the standard segmentation evaluation methods. Overall, EFRIS exhibits significantly improved results compared with the GFRIS approac

A generic fuzzy rule based technique for image segmentation

Many fuzzy clustering based techniques do not incorporate the spatial relationships of the pixels, while all fuzzy rule based image segmentation techniques tend to be very much application dependent. In most techniques, the structure of the membership functions are predefined and their parameters are either automatically or manually determined. This paper addresses the aforementioned problems by introducing a general fuzzy rule based image segmentation technique, which is application independent and can also incorporate the spatial relationships of the pixels. It also proposes the automatic defining of the structure of the membership functions. A qualitative comparison is made between the segmentation results using this method and the popular fuzzy c-means (FCM) applied to two types of images: light intensity (LI) and an X-ray of the human vocal tract. The results clearly show that this method exhibits significant improvements over FCM for both types of image