What Is a “Substantial Burden” on Religion Under RFRA and the First Amendment?

What is the meaning of a “substantial burden” on religion under the federal Religious Freedom Restoration Act (and its state-level equivalents)? This question is timelier than ever, as several pending cert petitions before the Supreme Court ask it to overturn the landmark decision that spurred RFRA’s enactment: Employment Division v. Smith, which held that exemptions for burdens on religion are not required from neutral and generally applicable laws. Whether or not the Court grants any of these cert petitions, judges will continue to need a clear and reliable method for identifying substantial burdens on religion. This Article considers several existing tests and proposes a new framework designed to remedy their shortcomings. Put simply, a court’s analysis of a substantial burden requires it to ask two questions: (1) What type of religious exercise does the law burden? And (2) what type of impact does the law have on that exercise? The Article develops answers to both questions, by specifying the kind of religious exercise that can be substantially burdened in the first place (what I’ll call obligation and substantial religious autonomy), and by sketching several types of substantial impact laws might have on religion (what I’ll call simply punitive, indirectly punitive, non-punitive, or preventive burdens). Only burdens that meet these two criteria together can properly be considered substantial. Taken together, these two prongs of the framework help us generate a taxonomy of at least eight different kinds of substantial burdens on religion. But a challenge remains: Would judicial application of this framework—particularly, would asking what type of religious exercise the law burdens— violate the Establishment Clause? In response, the Article clarifies the kinds of Establishment Clause concerns one might have about any judicial effort to interpret the substantiality of a burden on religion. Ultimately, it finds, the proposed framework can withstand all those concerns. Finally, the Article shows more precisely how the framework would help the Supreme Court decide a number of recent and potentially forthcoming cases involving substantial-burden claims

Charge-Transfer Interactions of Nicotine with Chloranil: Solvent Effects UV-Visible Spectrophotometric Study

UV-visible spectrophotometric studies on the interaction of nicotine with chloranil in cyclohexane, dioxane, benzene, chloroform and dichloromethane solutions at 25 °C demonstrate the formation of charge-transfer (CT) complexes. A new broad band begins to grow in time on the longer wavelength side of the characteristic absorption bands of the constituents. At equilibrium, the new band position depends on the polarity of the solvent used. In EtOH, MeOH and DMSO solutions, a new absorption spectra are immediately formed after mixing. The position of the new spectra is not affected by the solvent polarity. The solvation of the CT-complex immediately causes complete ionization of the neutral complex. It has been found that acetone acts as intermediate between the non-ionizing and ionizing solvents in which absorptions corresponding to the ions are observed simultaneously with the intermolecular CT-absorption. The stability constants and the molar absorptivities of the complexes formed have been calculated assuming the formation of 1 :1 complexes. Experimental results indicate that the stability constant of the complex formed and its type (neutral or ionic) depends greatly on the dielectric constant of the solvent used

Pancreatic beta-cell failure in the pathogenesis of type 2 diabetes

Contains fulltext : 142146.pdf (publisher's version ) (Open Access)2 p

CA19-9 as a Potential Target for Radiolabeled Antibody-Based Positron Emission Tomography of Pancreas Cancer.

Introduction. Sensitive and specific imaging of pancreas cancer are necessary for accurate diagnosis, staging, and treatment. The vast majority of pancreas cancers express the carbohydrate tumor antigen CA19-9. The goal of this study was to determine the potential to target CA19-9 with a radiolabeled anti-CA19-9 antibody for imaging pancreas cancer. Methods. CA19-9 was quantified using flow cytometry on human pancreas cancer cell lines. An intact murine anti-CA19-9 monoclonal antibody was labeled with a positron emitting radionuclide (Iodine-124) and injected into mice harboring antigen positive and negative xenografts. MicroPET/CT were performed at successive time intervals (72 hours, 96 hours, 120 hours) after injection. Radioactivity was measured in blood and tumor to provide objective confirmation of the images. Results. Antigen expression by flow cytometry revealed approximately 1.3 × 10(6) CA19-9 antigens for the positive cell line and no expression in the negative cell line. Pancreas xenograft imaging with Iodine-124-labeled anti-CA19-9 mAb demonstrated an average tumor to blood ratio of 5 and positive to negative tumor ratio of 20. Conclusion. We show in vivo targeting of our antigen positive xenograft with a radiolabeled anti-CA19-9 antibody. These data demonstrate the potential to achieve anti-CA19-9 antibody based positron emission tomography of pancreas cancer

Kinetics and Mechanism of Reduction of 4(p-Dimethylamino)-Benzylidene-3-Methyl-1-Phenyl-2-Pyrazolin-5-one by Bisulphite Ions in Aqueous Ethanolic Media

The kinetics of the title reduction studied in aqueous ethanolic media spectrophotometrically. The effect of hydrogen ion concentration on the reduction rate was investigated in buffer solutions at constant ionic strength of 1.0. The reaction was found to be of the first order in both reactants and inverse first order with respect to the hydrogen ion. The rate of the reaction decreased with increasing ethanol as well as hydrogen ion concentrations. Pseudo-first-order rate constant, kob was obtained by monitoring the disappearance of the [dye]. Activation parameters have been evaluated and a tentative reaction mechanism was discussed