Reconciling the Ministerial Exception and Title VII: Clarifying the Employer’s Burden for the Ministerial Exception

This note considers the consequences of the Supreme Court’s decision in Hosanna-Tabor Evangelical Lutheran Church and Sch. v. Equal Emp’t Opportunity Comm’n. In Hosanna-Tabor a unanimous Court declared the Constitution prevents federal non-discrimination law from being applied to “ministers.” However, the Court did not define the term minister. This note summarizes lower court decisions attempting to define this term. Building on these decisions the author proposes a three-prong test for determining whether a church employee should be classified as a minister

Aerodynamic Performance of a Biologically Inspired Hybrid Plasma-Mechanical Flow Control and Sensing Device

The continued high global demand for passenger and freight air traffic along with increased use of unmanned aerial vehicles operating in broader Reynolds number regimes has resulted in researchers examining alternative technologies, which would result in safer, more reliable, and superior performing aircraft. Aerodynamic flow control may be one of the most promising approaches to solving this problem, having already proven its ability to enable higher flow efficiency while simultaneously improving overall control of flow behavior such as laminar-to-turbulent transition. Recent research in aerodynamic flow control has seen a pronounced growth in the areas of biomimicry and plasma flow control actuators. Plasma actuators offer an inexpensive and energy efficient method of flow control. In addition, plasma actuator technology has the potential to be applied to a host of other aircraft performance parameters including applications in radar cross section mitigation and in situ wing deicing. Biomimetic researchers have studied large scale mechanics and phenomena such as flapping mechanics, and wing morphology, as well as small scale factors such as feather fluttering and microscale feather geometry. The proliferation of interest in these fields laid the foundation and inspiration for the development of a novel aerodynamic flow control and sensing device known as the compliant electrode discharge device, commonly referred to by the inventors as “plasma feathers”. This study consists of an investigation into the behavior of the compliant electrode device and its aerodynamic characteristics and performance during its flapping mode operation. Three models of varying aspect ratio were constructed, characterized through a modal analysis, and then subsequently tested for behavioral characteristic and aerodynamic performance. The behavioral testing shows that there is clearly defined range of pulsing ratios and duty cycle combinations that will likely result in desired behavior. The aerodynamic performance was investigated via two-dimensional two-component particle image velocimetry. It’s shown in tunnel-on testing that the device can favorably affect a low Reynolds number flow and potentially be used as an active airbrake in higher Reynolds number flows. Testing in quiescent air demonstrated that flows with velocities on the order of the speed of the tip of the compliant electrode can be induced in two momentum jets that are similar to the superposition of a traditional dielectric barrier discharges induced jet (horizontally oriented jet) and a synthetic jet’s induced jet (vertically oriented jet) overlayed upon one another allowing for a broad range of low Reynolds number applications

The Types and Usage of Twentieth Century Saxophone Techniques.

The areas of modern compositional and performance techniques for the saxophone are ones that have not been organized. Composers and players are using these compositional techniques at the present time in serious literature. These techniques are termed contemporary or twentieth century, but have been in use since the instrument was invented. There is authenticated use of the altissimo register by saxophonists E. I A. Lefebre who played with Gilmore and Sousa, and H. Benne Henton who played with Sousa and then formed his own ban

Study of Periodic Forcing with a Dielectric Barrier Discharge Device for the Control of Flow Separation on a NACA 0012

The continued high global demand for passenger and freight air traffic as well as increased use of unmanned aerial vehicles (UAVs), in spite of rising fuel costs and several tragic cases involving loss-of-control events, has resulted in researchers examining alternative technologies, which would result in safer, more reliable, and superior performing aircraft. Aerodynamic flow control may be the most promising approach to this problem having already proven its ability to enable higher flow efficiency while also simultaneously improving overall flow control. Recent research in the area of aerodynamic control is transitioning from traditional mechanical flow control devices such as slats and flaps to plasma actuators. Plasma actuators offer an inexpensive and energy efficient method of flow control. In addition, plasma actuator technology has the potential of application to a host of other aircraft performance parameters including applications in radar mitigation and in situ wing deicing.;Dielectric Barrier Discharge (DBD), one of the most widely studied forms of plasma actuation, employs an electrohydrodynamic (EHD) device, which uses dominant electric fields and the respective electrically related body forces for actuation. Unlike momentum jets or other traditional flow control methods used on wings and tail surfaces, a DBD device operates without moving components or injecting any mass into the flow stream.;Work performed focuses on qualitatively investigating experimentally the use of DBD devices for flow separation control on a NACA 0012-based 2D wing model. Flow visualization techniques illuminated flow seed particles around the model to determine the state of the flow (i.e., attached or separated) for various actuator cases. The DBD was operated in a steady-on mode as well as for three different pulsing frequencies (only for low power testing) based on the Strouhal frequency for each flight condition and compared to the clean (i.e., plasma off) case. Some of the flow control results were compared to another active flow control scheme known as dynamic roughness (DR) which consists of surface mounted time dependent deforming elements that operate as a periodic forcing device that energizes the boundary layer. The potential use of DBDs for application to existing UAVs and aircraft was also evaluated based on applicability, power consumption, and other relevant factors.;Results of this work indicate that low power gapless DBD actuators are an effective form of separation control at low Reynolds numbers Ohorn (10 4) near the angle of attack where separation begins to occur. However, testing seems to indicate that gapless low power DBDs are underpowered to have any substantial flow control authority at higher Reynolds numbers and angles of attack. With improved materials for DBD construction and more testing, DBDs could potentially be an effective form of flow control on UAVs and manned aircraft in the future

Implementation of a patient satisfaction survey in the Pacific University Family Vision Center

Patient satisfaction surveys are a key outcome indicator of quality healthcare delivery. One of the goals in optometric educational systems is to teach interns to provide quality healthcare. The purpose of this study was to design, implement and evaluate a patient satisfaction survey in the Pacific University Family Vision Center. The survey would specifically benefit the intern by measuring and providing valuable feedback in regards to the individual intern\u27s efficiency, professionalism, courtesy and communication skills. The card was also designed to be short, straightforward, and easy to fill out. The results showed a 46% return rate, with a majority of the responses indicating a high level of patient satisfaction. Future implementation of the patient satisfaction survey is recommended in the clinics