Brown v. Delta Tau Delta: In a Premises Liability Claim, How Far Should the Law Court Go to Assign a Duty of Care?

In 2015, Maine’s premises liability law made an evolutionary leap. In Maine, the elements of a premises liability claim are the same as a negligence claim: duty of care, breach of that duty, causation, and harm to the plaintiff. Since the late nineteenth century, the duty element had remained consistent and predictable: a property owner, possessor, or proprietor owes a duty of reasonable care to individuals who are lawfully on the premises. As a result, premises liability defendants had always shared the common trait of owning, possessing, or managing the premises in question. In Brown v. Delta Tau Delta , the Supreme Judicial Court, sitting as the Law Court, expanded premises liability to cover a business entity that did not own, possess, or manage the premises in question, but nonetheless knew the tort would happen. The entity foresaw the tort, enjoyed a close relationship with the tortfeasor, and had sufficient control over the tortfeasor’s actions. Therefore, the entity had a duty of care. The court reached these conclusions after examining the series of events leading to the claim. This note begins with a discussion of those events. In 2015, Maine’s premises liability law made an evolutionary leap. In Maine, the elements of a premises liability claim are the same as a negligence claim: duty of care, breach of that duty, causation, and harm to the plaintiff. Since the late nineteenth century, the duty element had remained consistent and predictable: a property owner, possessor, or proprietor owes a duty of reasonable care to individuals who are lawfully on the premises. As a result, premises liability defendants had always shared the common trait of owning, possessing, or managing the premises in question. In Brown v. Delta Tau Delta , the Supreme Judicial Court, sitting as the Law Court, expanded premises liability to cover a business entity that did not own, possess, or manage the premises in question, but nonetheless knew the tort would happen. The entity foresaw the tort, enjoyed a close relationship with the tortfeasor, and had sufficient control over the tortfeasor’s actions. Therefore, the entity had a duty of care. The court reached these conclusions after examining the series of events leading to the claim. This note begins with a discussion of those events

Synapsis: Philadelphia Campus (1944)

This yearbook includes the Yearbook Staff, Neo Senior Honorary Society, Atlas Club, Iota Tau Sigma, ITS, (ΙΤΣ), Lambda Omicron Gamma, LOG, (ΛΟΓ), Phi Sigma Gamma, PSG, (ΦΣΓ), Junior Women\u27s Osteopathic Association, Dig-On Society, Student Wives Club, Students\u27 Wives Organization, Student Wives Organization, Newman Club, E.G. Drew Obstetrical and Gynecological Society, Edward G. Drew Obstetrical-Gynecological Society, Urological Society, Neurological Society, Cardio-Vascular Society, Pediatric Society, Pediatrics Society, Interfraternity Council, Inter-fraternity Council, Student Council, Class Officers.https://digitalcommons.pcom.edu/yearbooks/1067/thumbnail.jp

Myeloid Cell Mediated Immune Suppression in Pancreatic Cancer

Pancreatic ductal adenocarcinoma (PDA), the most common pancreatic cancer, is a nearly-universally lethal malignancy. PDA is characterized by extensive infiltration of immunosuppressive myeloid cells, including tumor-associated macrophages (TAMs) and myeloid-derived suppressor cells (MDSCs). Myeloid cells in the tumor microenvironment (TME) inhibit cytotoxic T cell responses promoting carcinogenesis. Immune checkpoint therapy has not been effective in PDA, most likely due to this robust immune suppression, making it critical to elucidate mechanisms behind this phenomenon. Here, we review myeloid cell infiltration and cellular crosstalk in PDA progression and highlight current therapeutic approaches to target myeloid cell-driven immune suppression

Discursive leadership in technological change

Phd ThesisThis thesis is contributing to a greater understanding of discursive leadership by exploring as it happens in situ and by looking more closely at the daily interactional work of leadership actors in the process of technological change. In this thesis, I argue that many of the existing accounts of leadership in organisational studies have contributed to a widely accepted ‘grandiose’ image of leadership conceptualising the phenomenon as a pre-existing entity and a taken-for-granted privilege of people on the top of organisational hierarchy who are responsible for making the executive decisions. My view on leadership is different. It is less grandiose, more mundane, and fundamentally a reality-defining activity. Being intrigued by daily discursive practices of doing leadership - as moments of providing an ‘intelligible formulation’ of reality - I contribute to the discursive leadership agenda by following a social constructionist path. The ‘linguistic turn’ in social sciences is my point of departure towards embracing the social and linguistic aspects of leadership. My thesis contributes to the field of management and organisation studies by developing an analytical framework to study discursive leadership as an interactional accomplishment by elaborating and synthesising theoretical insights from organisational sensemaking, discursive leadership and the social studies of technology. The value of this framework informed by the principles of ethnomethodology is that it has the potential for providing a better understanding of how technological change is constructed, negotiated and accomplished through the daily discursive practices of leadership actors who make sense of and give sense to processes of technological change in organisations. Responding to the empirical challenge of tracing the everyday interactional constitution of discursive leadership, my study is based on an extensive dataset, including meeting observations, interviews, and documents obtained during a twelve-month fieldwork. Drawing on this data, I use a range of interpretive approaches; namely, ethnomethodologically-informed discourse analysis (EDA), conversation analysis (CA), membership categorisation analysis (MCA) and organisational ethnography that iv enabled me to undertake a painstaking exploration of discursive micro-granularity of members’ sensemaking accounts which I used as units of my analysis. My study advances the existing research on organisational sensemaking by analysing reasoning procedures through which leadership actors construct a meaningful sense of the technological change through accounts. By setting a micro-discursive lens on leadership as a situated discursive practice and giving priority to participants’ own sensemaking, I identified a repertoire of discursive devices used by leadership actors to make sense and to give sense to the technological change in an organisation. Through examining the interactional accomplishment of the leadership phenomenon, my research advances the existing work on organisational sensemaking by an empirical demonstration of the organising properties of leadership as ‘sensemaking in action’. My thesis contributes to the discursive leadership field by offering insights into category predication work of leadership actors which enable sensemaking and sensegiving about technological change through the processes of framing and reframing. Three vignettes (each comprising of a set of episodes) demonstrate the membership categorisation work in leadership interaction which includes the following processes: reconstituting a category, characterising a category and generating category constraints thus revealing how technological change is accomplished through discursive practice of leadership actors

The B-G News December 16, 1952

The BGSU campus student newspaper December 16, 1952. Volume 37 - Issue 23https://scholarworks.bgsu.edu/bg-news/2098/thumbnail.jp

Lattice Green functions in all dimensions

We give a systematic treatment of lattice Green functions (LGF) on the $d$-dimensional diamond, simple cubic, body-centred cubic and face-centred cubic lattices for arbitrary dimensionality $d \ge 2$ for the first three lattices, and for $2 \le d \le 5$ for the hyper-fcc lattice. We show that there is a close connection between the LGF of the $d$-dimensional hypercubic lattice and that of the $(d-1)$-dimensional diamond lattice. We give constant-term formulations of LGFs for all lattices and dimensions. Through a still under-developed connection with Mahler measures, we point out an unexpected connection between the coefficients of the s.c., b.c.c. and diamond LGFs and some Ramanujan-type formulae for $1/\pi.$Comment: 30 page

Hillsdale Magazine

https://digitalcommons.hillsdale.edu/hillsdalemagazine/1002/thumbnail.jp

Child trauma: surviving structural violence in America

The definitions of trauma and trauma behavior are expansive and have continued to grow in the past century. While biomedicine continues to expand the Diagnostic and Statistical Manual for cultural competency and subjective experience, the concept of trauma is still limited to certain behavior and events determined by hegemonic views. This becomes detrimental to families and children exposed to everyday instances of structural violence. Looking at major child care sectors— the education system, biomedical care, and the family unit—to understand the influences of biopower and the consequences of structural violence, data collected from the greater Boston area reveals the consequences of structural violence on both child behavior and the manifestation of trauma. This thesis reexamines the social construct of trauma and trauma behavior, and uses its own term, structural trauma, to account for the social frameworks that create a legitimacy deficit for the trauma-related behaviors children embody. Examination of these three main child care sectors and the barriers that contribute to, or try to deconstruct, structural trauma reveals that these institutions have organized themselves into a pastoral apparatus that can prove to be more harmful than helpful for addressing child trauma and family well-being. Through structural trauma, researchers and society can gain further insight on how policies and practices create additional, unintentional vulnerabilities in underserved populations, consequently inhibiting healing and understanding amongst families and institutions