What’s HUD Got to Do With It?: How HUD’s Disparate Impact Rule May Save the Fair Housing Act’s Disparate Impact Standard

Since 2011, the U.S. Supreme Court has granted certiorari three times on the question of whether disparate impact liability is cognizable under the Fair Housing Act (FHA). The first two times, the parties settled. The question is before the Court once again in Texas Department of Housing & Community Affairs v. Inclusive Communities Project, Inc., and this time the parties seem unlikely to settle. Disparate impact liability in the civil rights context entails liability for actions that have a discriminatory effect, regardless of an actor’s motive. Under the FHA, this can translate into liability for actions that make housing disproportionately unavailable for persons of a protected class or actions that tend to increase or maintain segregated housing patterns. All eleven federal circuit courts that have addressed the question agree that disparate impact claims are cognizable under the FHA. In addition, in the spring of 2013, the U.S. Department of Housing and Urban Development (HUD) promulgated a rule that standardizes the burdens of proof for disparate impact claims under the FHA and specifically states for the first time in a formal administrative rule that disparate impact claims are cognizable under the FHA. The promulgation of HUD’s disparate impact rule means that this time around the Supreme Court must give heightened deference to an interpretation of the FHA that authorizes disparate impact claims. This Note argues that despite the near-unanimity of the circuit courts’ interpretation of the FHA, the fate of disparate impact claims under the FHA was anything but certain prior to the promulgation of the HUD rule. The HUD rule makes it much more likely that the FHA disparate impact standard will survive, and this Note argues that it should

Theology, News and Notes - Vol. 47, No. 03

Theology News & Notes was a theological journal published by Fuller Theological Seminary from 1954 through 2014.https://digitalcommons.fuller.edu/tnn/1141/thumbnail.jp

Cell–Cell Adhesion Prevents Mutant Cells Lacking Myosin II from Penetrating Aggregation Streams ofDictyostelium

AbstractWhen a small number of fluorescently labeled myosin II mutant cells (mhcA−) are mixed with wild-type cells and development of the chimeras is observed by confocal microscopy, the mutant cells are localized to the edges of aggregation streams and mounds. Moreover, the mutant cells stick to wild-type cells and become distorted (Shelden and Knecht, 1995). Two independent adhesion mechanisms, Contact Sites A and Contact Sites B, function during the aggregation stage and either one or both might be responsible for excluding the myosin II null cells. We have mixedmhcA−cells with cells in which the appearance of Contact Sites B is delayed (strain TL72) as well as cells which lack Contact Sites A (strain GT10) and double mutants in which both adhesion mechanisms are affected (strain TL73). In all chimeras, themhcA−cells were distorted by interactions with the adhesion mutant cells, indicating that it does not require significant adhesive interaction to distort the flaccid cortex ofmhcA−cells.mhcA−cells were excluded from streams composed of cells lacking either Contact Sites A or Contact Sites B but mixed randomly with cells lacking both adhesion systems. By 10 hr of development, cells of strain TL73 acquire Contact Sites B adhesion. If cells of this strain were mixed with labeledmhcA−cells, allowed to develop for 9 hr, and then dissociated before replating, the myosin II null cells were seen to be distorted and excluded from the reaggregates. Thus the exclusion ofmhcA−cells from streams can be accomplished by either Contact Sites A or B. When chimeras of labeled TL73 and wild-type cells were made, the TL73 cells were found to be randomly mixed into aggregation streams. This result indicates that adhesive sorting does not function during aggregation and so cannot account for the exclusion ofmhcA−cells from streams. We hypothesize that the flaccid cortex ofmhcA−cells cannot generate sufficient protrusive force to break the contacts between adhered cells in aggregation streams but can enter streams where the cells are weakly adherent

A Background Noise Reduction Technique Using Adaptive Noise Cancellation for Microphone Arrays

Background noise in wind tunnel environments poses a challenge to acoustic measurements due to possible low or negative Signal to Noise Ratios (SNRs) present in the testing environment. This paper overviews the application of time domain Adaptive Noise Cancellation (ANC) to microphone array signals with an intended application of background noise reduction in wind tunnels. An experiment was conducted to simulate background noise from a wind tunnel circuit measured by an out-of-flow microphone array in the tunnel test section. A reference microphone was used to acquire a background noise signal which interfered with the desired primary noise source signal at the array. The technique s efficacy was investigated using frequency spectra from the array microphones, array beamforming of the point source region, and subsequent deconvolution using the Deconvolution Approach for the Mapping of Acoustic Sources (DAMAS) algorithm. Comparisons were made with the conventional techniques for improving SNR of spectral and Cross-Spectral Matrix subtraction. The method was seen to recover the primary signal level in SNRs as low as -29 dB and outperform the conventional methods. A second processing approach using the center array microphone as the noise reference was investigated for more general applicability of the ANC technique. It outperformed the conventional methods at the -29 dB SNR but yielded less accurate results when coherence over the array dropped. This approach could possibly improve conventional testing methodology but must be investigated further under more realistic testing conditions

Theology, News and Notes - Vol. 05, No. 02

Theology News & Notes was a theological journal published by Fuller Theological Seminary from 1954 through 2014.https://digitalcommons.fuller.edu/tnn/1010/thumbnail.jp

Leaps and lulls in the developmental transcriptome of Dictyostelium discoideum

Development of the soil amoeba Dictyostelium discoideum is triggered by starvation. When placed on a solid substrate, the starving solitary amoebae cease growth, communicate via extracellular cAMP, aggregate by tens of thousands and develop into multicellular organisms. Early phases of the developmental program are often studied in cells starved in suspension while cAMP is provided exogenously. Previous studies revealed massive shifts in the transcriptome under both developmental conditions and a close relationship between gene expression and morphogenesis, but were limited by the sampling frequency and the resolution of the methods. Here, we combine the superior depth and specificity of RNA-seq-based analysis of mRNA abundance with high frequency sampling during filter development and cAMP pulsing in suspension. We found that the developmental transcriptome exhibits mostly gradual changes interspersed by a few instances of large shifts. For each time point we treated the entire transcriptome as single phenotype, and were able to characterize development as groups of similar time points separated by gaps. The grouped time points represented gradual changes in mRNA abundance, or molecular phenotype, and the gaps represented times during which many genes are differentially expressed rapidly, and thus the phenotype changes dramatically. Comparing developmental experiments revealed that gene expression in filter developed cells lagged behind those treated with exogenous cAMP in suspension. The high sampling frequency revealed many genes whose regulation is reproducibly more complex than indicated by previous studies. Gene Ontology enrichment analysis suggested that the transition to multicellularity coincided with rapid accumulation of transcripts associated with DNA processes and mitosis. Later development included the up-regulation of organic signaling molecules and co-factor biosynthesis. Our analysis also demonstrated a high level of synchrony among the developing structures throughout development. Our data describe D. discoideum development as a series of coordinated cellular and multicellular activities. Coordination occurred within fields of aggregating cells and among multicellular bodies, such as mounds or migratory slugs that experience both cell-cell contact and various soluble signaling regimes. These time courses, sampled at the highest temporal resolution to date in this system, provide a comprehensive resource for studies of developmental gene expression

Bostonia. Volume 11

Founded in 1900, Bostonia magazine is Boston University's main alumni publication, which covers alumni and student life, as well as university activities, events, and programs

Evaluation of protection induced by a dengue virus serotype 2 envelope domain III protein scaffold/DNA vaccine in non-human primates

AbstractWe describe the preclinical development of a dengue virus vaccine targeting the dengue virus serotype 2 (DENV2) envelope domain III (EDIII). This study provides proof-of-principle that a dengue EDIII protein scaffold/DNA vaccine can protect against dengue challenge. The dengue vaccine (EDIII-E2) is composed of both a protein particle and a DNA expression plasmid delivered simultaneously via intramuscular injection (protein) and gene gun (DNA) into rhesus macaques. The protein component can contain a maximum of 60 copies of EDIII presented on a multimeric scaffold of Geobacillus stearothermophilus E2 proteins. The DNA component is composed of the EDIII portion of the envelope gene cloned into an expression plasmid. The EDIII-E2 vaccine elicited robust antibody responses to DENV2, with neutralizing antibody responses detectable following the first boost and reaching titers of greater than 1:100,000 following the second and final boost. Vaccinated and naïve groups of macaques were challenged with DENV2. All vaccinated macaques were protected from detectable viremia by infectious assay, while naïve animals had detectable viremia for 2–7 days post-challenge. All naïve macaques had detectable viral RNA from day 2–10 post-challenge. In the EDIII-E2 group, three macaques were negative for viral RNA and three were found to have detectable viral RNA post challenge. Viremia onset was delayed and the duration was shortened relative to naïve controls. The presence of viral RNA post-challenge corresponded to a 10–30-fold boost in neutralization titers 28 days post challenge, whereas no boost was observed in the fully protected animals. Based on these results, we determine that pre-challenge 50% neutralization titers of >1:6000 correlated with sterilizing protection against DENV2 challenge in EDIII-E2 vaccinated macaques. Identification of the critical correlate of protection for the EDIII-E2 platform in the robust non-human primate model lays the groundwork for further development of a tetravalent EDIII-E2 dengue vaccine