Removal Reform: A Solution for Federal Question Jurisdiction, Forum Shopping, and Duplicative State-Federal Litigation

Federal court procedural, especially jurisdictional ones, need to be governed by clear, effective, and fair rules. Yet twentieth century doctrines and reforms, even when made in the name of pragmatism, have produced decidedly unpragmatic results: a vague and disputed doctrine of federal question jurisdiction that excludes from federal court many cases where federal law controls the outcome, rules that facilitate forum shopping by plaintiffs and make it impossible to predict in advance what law will apply to decide one’s case, and the stunning waste of a system in which the exact same issues are simultaneously litigated in state and federal courts as part of a “race to judgment.” The status quo is, quite simply, broken. This Article contends that we can ameliorate these concerns by permitting removal to federal court whenever the parties are diverse and whenever the defendant’s answer or plaintiff’s reply shows that a case arises under federal law— rather than artificially limiting our vision to the plaintiff’s well-pleaded complaint. Though modest, these reforms could serve as a tonic to many of the status quo’s most striking irrationalities: the criteria for federal question jurisdiction would be expanded to cover many currently excluded cases that turn on federal law, plaintiffs would lose opportunities to forum shop by pinning unwilling defendants in state courts, and the systemic waste of duplicative and concurrent state-federal litigation could be largely eliminated. By broadly addressing these deeply-rooted problems, this Article aims at improving the clarity, rationality, and essential fairness of the rules that govern our federal courts

Phase 2 trial of montelukast for prevention of pain in sickle cell disease.

Cysteinyl leukotrienes (CysLTs) are lipid mediators of inflammation. In patients with sickle cell disease (SCD), levels of CysLTs are increased compared with controls and associated with a higher rate of hospitalization for pain. We tested the hypothesis that administration of the CysLT receptor antagonist montelukast would improve SCD-related comorbidities, including pain, in adolescents and adults with SCD. In a phase 2 randomized trial, we administered montelukast or placebo for 8 weeks. The primary outcome measure was a >30% reduction in soluble vascular cell adhesion molecule 1 (sVCAM), a marker of vascular injury. Secondary outcome measures were reduction in daily pain, improvement in pulmonary function, and improvement in microvascular blood flow, as measured by laser Doppler velocimetry. Forty-two participants with SCD were randomized to receive montelukast or placebo for 8 weeks. We found no difference between the montelukast and placebo groups with regard to the levels of sVCAM, reported pain, pulmonary function, or microvascular blood flow. Although montelukast is an effective treatment for asthma, we did not find benefit for SCD-related outcomes. This clinical trial was registered at www.clinicaltrials.gov as #NCT01960413

An extensive endoplasmic reticulum-localised glycoprotein family in trypanosomatids

Peer reviewedPublisher PD

Students' Perception of the Psycho-Social Clinical Learning Environment: An Evaluation of Placement Models

Nursing is a practice based discipline. A supportive environment has been identified as important for the transfer of learning in the clinical context. The aim of the paper was to assess undergraduate nurses' perceptions of the psychosocial characteristics of clinical learning environments within three different clinical placement models. Three hundred and eight-nine undergraduate nursing students rated their perceptions of the psycho-social learning environment using a Clinical Learning Environment Inventory. There were 16 respondents in the Preceptor model category, 269 respondents in the Facilitation model category and 114 respondents in the clinical education unit model across 25 different clinical areas in one tertiary facility. The most positive social climate was associated with the preceptor model. On all subscales the median score was rated higher than the two other models. When clinical education units were compared with the standard facilitation model the median score was rated higher in all of the subscales in the Clinical Learning Environment Inventory. These results suggest that while preceptoring is an effective clinical placement strategy that provides psycho-social support for students, clinical education units that are more sustainable through their placement of greater numbers of students, can provide greater psycho-social support for students than traditional models

Work engagement and voluntary absence: The moderating role of job resources

The present study examined the moderating role of job resources, namely, organisational trust, the quality of employees’ relationship with their manager, and the motivating potential of jobs, on the negative relationship between work engagement and voluntary absence. Employee survey results and absence records collected from the Human Resources Department of a construction and consultancy organisation in the United Kingdom (n=325) showed that work engagement was negatively related to voluntary absence, as measured by the Bradford Factor. Further, the results showed that organisational trust and the quality of employees’ relationships with their line managers ameliorated the negative effect of relatively low levels of engagement on voluntary absence. Theoretical and practical implications of the findings are discussed

Effects of alcohol preload on attentional bias towards cocaine-related cues

Background Drug and alcohol users have an ‘attentional bias’ for substance-related cues, which is likely to reflect the incentive-motivational properties of those cues. Furthermore, administration of an alcohol preload increases attentional bias for alcohol and tobacco-related cues in heavy drinkers and tobacco smokers, respectively. The present study investigated attentional bias for cocaine cues in cocaine users and non-users following administration of either alcohol or placebo. Method Thirty-two regular cocaine users and 40 non-users took part. Participants were administered alcohol or placebo, and administration was double blind. After drink administration, a Visual Probe task and Modified Stroop task were used to assess attentional bias. Subjective craving and alcohol outcome expectancies were also measured. Results There was a significant interaction between group and drink type on the visual probe task indicating that cocaine users who had received alcohol had increased attentional bias for cocaine pictures compared to non-users and cocaine users who received placebo. The cocaine Stroop revealed no differences between cocaine users and non-users, and no effects of alcohol in either group. Conclusions Alcohol preload in regular cocaine users increases attentional bias for cocaine cues. However, cocaine users who received placebo did not show attentional bias for cocaine stimuli. Future research should investigate the effects of alcohol preload on attentional bias in cocaine-dependent individuals