A Unifying Theory for the Religion Clauses of the First Amendment

According to Justice Powell, the first amendment religion clauses are the source of some of the most perplexing questions that the Supreme Court confronts. In a long and rapidly expanding line of religion clause cases the Court has struggled, with a conspicuous lack of success, to articulate principles of broad applicability. The Court\u27s efforts to date have resulted in a jumble of tests, standards, and theoretical approaches from which predicting the outcome in future cases is very difficult. The conceptual problems that have frustrated the Court\u27s attempts at doctrinal development center in two broad areas: first,the meaning and effect of the establishment clause and second, the relationship between the establishment clause and the free exercise clause. In a third area, the meaning and effect of the free exercise clause, the Court has had somewhat less trouble articulating a doctrinal approach, but even here the Court has not applied the doctrine consistently and has not reached entirely predictable results. Perhaps the most telling measure of the Court\u27s doctrinal frustration in the religion clause area is the extent to which it recently has attempted to elevate its conspicuous lack of doctrinal consistency into an accepted methodology for decision making. Chief Justice Burger summarized current thinking on the relationship between the two religion clauses by noting that there is internal tension in the First Amendment between the Establishment Clause and the Free Exercise Clause. Finding a clearer acknowledgement of the Court\u27s failure to articulate a unifying theory underlying the two clauses would be difficult. Concerning the meaning and effect of the establishment clause, Chief Justice Burger has observed with apparent approval (or at least resignation) that the Court has been unwilling to tie establishment clause analysis to a single test. With the same apparent approval, Justice White has noted that our decisions have tended to avoid categorical imperatives and absolutist approaches .... This course sacrifices clarity and predictability for flexibility .. .., Describing the same phenomenon in another case, Justice O\u27Connor concluded that [e]very government practice must be judged in its unique circumstances to determine whether it constitutes an endorsement or disapproval of religion. In effect, the Court seems to have accepted the inevitability of an ad hoc approach with a final result in any case possible only after Supreme Court review... The thesis of this Article is that such a single overriding objective can be identified and articulated. This objective reflects the basic purpose of those who authored and adopted the religion clauses and, to a remarkable degree, harmonizes the Court\u27s apparently disparate results in religion clause cases. The Court\u27s conscious acceptance of the unifying theory proposed in this Article would provide a satisfying explanation for a large number of results arrived at by intuition in the past and would provide a theoretical basis from which to predict results in future cases

Crystallization of the Zagami Shergottite: An Experimental Study

Spherulites are usually rounded or spherical objects found in rhyolitic obsidian. They usually comprise acicular crystals of alkali feldspar that radiate from a single point. The radiating array of crystalline fibers typically have a similar crystallographic orientation such that a branch fiber departs slightly but appreciably from that of its parent fiber. Individual fibers range from 1 to several micrometers in diameter. The spherulites most likely form by heterogeneous nucleation on microscopic seed crystals, bubbles, or some other surface at high degrees of supercooling. They grow very rapidly stabilizing their fibrous habit and typically range in size from microscopic to a few cm in diameter

Exploring Mars Glass Tube Anomalies

This practical article provides information regarding the use of Edward de Bono CoRT thinking skills to broaden and enhance critical and creative thinking skills in twice exceptional students using the Mars Glass Tube Mystery as a vehicle to explore possibilities and spark creative thinking. The exceptionalities addressed in this lesson plan are gifted learners who have one or more additional exceptionalities of slow processing speed and / or poor fine motor skills. Throughout the lesson, the Mars Mystery photos leveraged both prior knowledge and student curiosity to create an engaging activity for the participants. CoRT thinking skills provided a robust structure for guiding meaningful discussions, a means of encouraging deeper thought, and facilitating productive group discourse. The mystery-focused lesson encouraged imagination, allowing students to not only stretch independent thought but to actively participate in sharing and validating each other’s ideas and to explore creativity as a way to express ideas and generate conclusions

Antimicrobial Interventions and Application Time Effects on Ground Beef Quality

Small business meat processors can use organic acid antimicrobial interventions to control Shiga toxin-producing E. coli (STEC) when producing ground beef; however, many small producers are concerned about the impact on ground beef quality. The effects of two commonly used organic acids, lactic acid and peroxyacetic acid, were evaluated at short (15 seconds) or extended (3 minutes) raw material dip times on ground beef quality parameters. Beef trim dipped in lactic acid for 3 minutes had a reduction in total aerobic bacteria plate count, but also increased ground beef discoloration and lipid oxidation during retail display. Use of a shorter dip time showed minimal differences in ground beef quality compared to untreated controls. In addition, dipping lean trim in peroxyacetic acid for 3 minutes slowed ground beef discoloration during display. Therefore, processors should consider either type of organic acid, and the length of lean trim exposure to organic acid during dipping, to optimize shelf life quality attributes

Antimicrobial Interventions and Application Time Effects on Ground Beef Quality

Small business meat processors can use organic acid antimicrobial interventions to control Shiga toxin-producing E. coli (STEC) when producing ground beef; however, many small producers are concerned about the impact on ground beef quality. The effects of two commonly used organic acids, lactic acid and peroxyacetic acid, were evaluated at short (15 seconds) or extended (3 minutes) raw material dip times on ground beef quality parameters. Beef trim dipped in lactic acid for 3 minutes had a reduction in total aerobic bacteria plate count, but also increased ground beef discoloration and lipid oxidation during retail display. Use of a shorter dip time showed minimal differences in ground beef quality compared to untreated controls. In addition, dipping lean trim in peroxyacetic acid for 3 minutes slowed ground beef discoloration during display. Therefore, processors should consider either type of organic acid, and the length of lean trim exposure to organic acid during dipping, to optimize shelf life quality attributes

Media Effects on Lettuce Growth in "Pillows" Designed for the VEGGIE Spaceflight Growth Chamber

VEGGIE is a prototype vegetable production unit for space designed by Orbital Technologies Corporation that is being developed to fly on the International Space Station. A modular plant rooting system "pillow" is being designed to support plant growth in VEGGIE under microgravity conditions. VEGGIE pillows are small self-contained packets of media with time-release fertilizer that can wick water passively from a root mat reservoir. Seeds are planted in pillows and the entire root system of a plant is contained as the crop develops, preventing loss into the spacecraft cabin. This study compared five media types and three lettuce cultivars in pillows growing in a VEGGIE analog environment.. Media consisted of a peat-based potting mix (Fafard #2,Conrad Fafard Inc., Agawam, MA), and a calcined clay, (arcillite, 1-2 mm sifted, Turface Proleague, Profile LLC, Buffalo Grove IL) as well as three different blends of the two, 70:30, 50:50, and 30:70. Lettuce cultivars tested were 'Sierra', a bi-colored French crisp Batavia lettuce, 'Outredgeous', a red romaine lettuce and 'Flandria', a green butter head variety. Plants were grown for 28 days, harvested, biometric data was obtained, and tissue mineral analysis was performed. For all cultivars, lettuce plants grown in the media blends were more productive than those in the individual media types. All cultivars showed bell-shaped curves in response to increases in arcillite / decreases in Fafard #2 for leaf area, fresh, and dry mass. Plants in 100% Fafard #2 and in 100% arcillite were stunted, but only those in higher levels of Fafard #2 (70% and 100%) had reduced shoot percent moisture, possibly indicating that mechanisms causing stunting differed. Variation in tissue nutrient content are consistent with this, with Mg and Mn highest in plants grown in 100% Fafard and decreasing as the concentration of arcillite increased. Color also varied with media, especially in the 'Sierra' lettuce, with plants grown in increasing levels of Fafard #2 being much more red and those in 100% arcillite almost completely green. The red-leaf cultivar 'Outredgeous' showed increasing chlorophyll (SPAD values) with increasing percentage of arcillite. In all cultivars tested it appears that a mixture of media types, usually 50:50 or 30:70 Fafard #2: arcillite, sustained healthier, more productive plants. Smaller, less productive plants in either of the individual media may indicate stress issues, however more work is needed to understand the reasons for this sub-optimal growth. This work was supported by NAS

The effect of bisphosphonate treatment on the biochemical and cellular events during bone remodelling in response to microinjury stimulation.

Osteoporosis is one of the most prevalent bone diseases worldwide and is characterised by high levels of bone turnover, a marked loss in bone mass and accumulation of microdamage, which leads to an increased fracture incidence that places a huge burden on global health care systems. Bisphosphonates have been used to treat osteoporosis and have shown great success in conserving bone mass and reducing fracture incidence. In spite of the existing knowledge of the in vivo responses of bone to bisphosphonates, the cellular responses to these drugs have yet to be fully elucidated. In vitro model systems that allow the decoupling of complex highly integrated events, such as bone remodelling, provide a tool whereby these biological processes may be studied in a more simplified context. This study firstly utilised an in vitro model system of bone remodelling and comprising all three major cell types of the bone (osteocytes, osteoclasts and osteoblasts), which was representative of the bone\u27s capacity to sense microdamage and subsequently initiate a basic multicellular unit response. Secondly, this system was used to study the effect of two commonly utilised aminobisphosphonate treatments for osteoporosis, alendronate and zoledronate. We demonstrated that microinjury to osteocyte networks being treated with bisphosphonates modulates receptor activator of nuclear factor kappa-B ligand and osteoprotegerin activity, and subsequently osteoclastogenesis. Furthermore, bisphosphonates increased the osteogenic potential following microinjury. Thus, we have shown for the first time that bisphosphonates act at all three stages of bone remodelling, from microinjury to osteoclastogenesis and ultimately osteogenesis

Pulmonary Inflammation Induced by Incomplete or Inactivated Adenoviral Particles

Overview summary The amount of pulmonary inflammation induced in mice by intratracheal administration of high doses of adenoviral vectors was compared to that induced by viral particles that lack the ability to express the genes that they contain. The number of inflammatory cells infiltrating the lung 6 days after particle administration was similar between animals receiving normal versus defective adenoviral particles.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/63169/1/hum.1995.6.12-1553.pd

Acute Stroke, Hematocrit, and Blood Pressure.

A population-based study of the relation between hematocrit and stroke subtype was carried out among 2,077 individuals using the Lehigh Valley Stroke Register. This register identifies all stroke patients admitted to the 8 acute care hospitals serving the Lehigh Valley area of eastern Pennsylvania-western New Jersey. The mean hematocrit was higher in patients with lacunes than with thrombotic or embolic strokes (p = 0.02). However, when blood pressure was also considered the increase in hematocrit in patients with lacunar stroke was significant only when systolic hypertension (greater than or equal to 150 mm Hg) was also present (p = 0.029); no significant difference in hematocrit was found between stroke subtypes in normotensive individuals. Therefore, we cannot exclude the possibility that hypertension interacts with hematocrit in accounting for the observed association with lacunar infarcts. There was no trend for increased in-hospital mortality for stroke patients in either the low (less than or equal to 30, 30-36%) or high (greater than or equal to 47%) hematocrit groups

Stability in Cosmology, from Einstein to Inflation

I investigate the role of stability in cosmology through two episodes from the recent history of cosmology: (1) Einstein’s static universe and Eddington’s demonstration of its instability, and (2) the flatness problem of the hot big bang model and its claimed solution by inflationary theory. These episodes illustrate differing reactions to instability in cosmological models, both positive ones and negative ones. To provide some context to these reactions, I also situate them in relation to perspectives on stability from dynamical systems theory and its epistemology. This reveals, for example, an insistence on stability as an extreme position in relation to the spectrum of physical systems which exhibit degrees of stability and fragility, one which has a pragmatic rationale, but not any deeper one