The Insurability of Punitive Damages in Washington: Should Insureds Who Engage in Intentional Misconduct Reap the Benefit of Their Bargains?

This Note examines the issue of the insurability of punitive damages, concluding that insurance coverage should not be allowed for punitive damages arising from intentional misconduct because such coverage contravenes public policy in the state of Washington. Part I defines and provides background for punitive damages and malicious prosecution. Part II outlines and synthesizes the treatment of the insurability of punitive damages in various states. The facts of the Fluke case, including the Court of Appeals\u27s rationale that insurance coverage for punitive damages is not against public policy in Washington, are detailed in Part III. The next section reveals the Court of Appeals\u27s faulty reasoning, illuminating several reasons why Washington should prohibit insurance coverage for punitive damages arising out of intentional misconduct. Part V summarizes the Washington Supreme Court\u27s decision affirming the appellate court on the issue of whether insuring punitive damages is against public policy in Washington. This Note concludes in Part VI that punitive damages assessed for intentional misconduct should not be insurable in Washington as a mat- ter of public policy and that the Washington Supreme Court should have reversed the appellate court on this issue

The Insurability of Punitive Damages in Washington: Should Insureds Who Engage in Intentional Misconduct Reap the Benefit of Their Bargains?

This Note examines the issue of the insurability of punitive damages, concluding that insurance coverage should not be allowed for punitive damages arising from intentional misconduct because such coverage contravenes public policy in the state of Washington. Part I defines and provides background for punitive damages and malicious prosecution. Part II outlines and synthesizes the treatment of the insurability of punitive damages in various states. The facts of the Fluke case, including the Court of Appeals\u27s rationale that insurance coverage for punitive damages is not against public policy in Washington, are detailed in Part III. The next section reveals the Court of Appeals\u27s faulty reasoning, illuminating several reasons why Washington should prohibit insurance coverage for punitive damages arising out of intentional misconduct. Part V summarizes the Washington Supreme Court\u27s decision affirming the appellate court on the issue of whether insuring punitive damages is against public policy in Washington. This Note concludes in Part VI that punitive damages assessed for intentional misconduct should not be insurable in Washington as a mat- ter of public policy and that the Washington Supreme Court should have reversed the appellate court on this issue

Haemoglobin polymorphism in the eels of Hispaniola

One hundred and eighty-three eels of Hispaniola were examined for the number of vertebrae and all of them were found to belong to the species Anguilla rostrata (Le Sueur 1817), as was expected. The haemoglobins of 52 individuals were examined with electrophoresis, and a polymorphism was observed. According to the explanation of SICK et al. (1967), 7.7% of the eels of Hispaniola bear the heterozygous pattern already observed in American eels, while the others bear the most common phenotype, which is identical to the only haemoglobin phenotype of the European species

Orthodontic management of a mandibular double-tooth incisor: A case report

The presence of a double-tooth requires specific complex management due to the need for differential diagnosis and following treatment choices. The aim of this report was to present a rare case of a geminated mandibular lateral incisor, treated with an orthodontic approach. A Caucasian 10.9-year-old girl presented a lower right double-tooth incisor, with a class 1 molar and a class 2 cuspid tendency on both sides. The upper arch was constricted as shown by bilaterally tendencies to cross-bite, a slightly lower midline deviation was reported and a lack of space for all four permanent cuspids was confirmed also by the panoramic X-ray. In the lower arch, there was a severe crowding of about 14 mm and a buccally ectopic left canine. Overbite was normal and Overjet minimally increased. The double-tooth was identified like a geminated tooth, for the presence of one root and one pulp canal of increased size, as shown by the radiographic examinations. The anomalous tooth was managed with an orthodontic approach associated with a progressive stripping to reshape the crown. A two-phase treatment plan was performed, based on first maxillary expansion and lip bumper and then fixed appliances, in order to achieve a proper occlusion and a better aesthetic

Characterisation, modification and mathematical modelling of sudsing

A programme of research is outlined which considers the foaming performance and foam behaviour of surfactant systems commonly encountered in hand-wash laundry detergent applications. An experimental study of the physical chemistry of foam generation indicates that precipitation of a typical anionic surfactant with calcium forms mesophase particles and causes a marked reduction in the rate of transport of surfactant to air–water surfaces and a concomitant reduction in foaming. Oily soil antifoam effects are however insensitive to the presence of calcium, being equally effective regardless of pH and calcium content. They may be reproduced by a simple particle–oil mixture of a saturated and an unsaturated triglyceride (e.g. tristearin and triolein respectively). A detailed foam rheometry study is performed using foam flowing through a constriction. Bubble shapes are used to deduce the normal and shear stresses across the foam flow field. Broad agreement between the experimental stress field and that obtained from quasistatic simulations is demonstrated. As foam flow-rate increases, a different model, which takes explicit account of viscous dissipative forces within the foam flow field is required. The dissipative foam flow model predicts differential shrinkage and stretch rates of foam films. Coupled to a model for surfactant transport, this shows the extent to which surfactant concentration accumulates in shrinking films and is depleted in stretching films. In addition to film stretching, it is also important to know about film bursting or failure rates. Here failure rates are estimated using capillary suction pressures exerted on the films by Plateau border channels around film edges. The failure rates can then be employed to predict the evolution of bubble size at various spatial locations in a foam: reasonable agreement with experimental bubble size distributions is obtained

Sella turcica and craniofacial morphology in patients with palatally displaced canines: a retrospective study

Background: The aim of the study was to evaluate the sella and craniofacial morphological features in growing patients with palatally displaced canines compared to controls. Materials and methods: Twenty-two subjects with palatally displaced canines were retrospectively selected and compared to 22 controls matched for age and gender. Lateral cephalograms were collected and sagittal and vertical cephalometric variables were measured, together with sella interclinoid distance, sella depth, and sella diameter. The independent samples T-test or Mann-Whitney U-test were used to compare all the variables between the two groups. A Pearson correlation was computed for the craniofacial and sella variables that differed significantly (p < 0.05) between the groups. Results: Patients with palatally displaced canines showed a smaller interclinoid distance and a greater SNA angle than control subjects. The interclinoid distance and the SNA angle were negatively correlated (–0.52, p = 0.017) in the experimental group. Conclusions: Growing patients with palatally displaced canines had smaller sella interclinoid distances and a greater SNA angle than control subjects

Enamel Erosion Reduction through Coupled Sodium Fluoride and Laser Treatments before Exposition in an Acid Environment: An In Vitro Randomized Control SEM Morphometric Analysis

(1) Background: Erosive lesions of dental enamel are steadily increasing owing to both the availability of exogenous acid and the production of endogenous acid. The aim of this study was to investigate the erosion-inhibiting potential of a diode laser irradiation and topical application of fluoride used alone or in combination on the enamel surface of extracted teeth before exposure to an acidic solution. (2) Methods: The four axial enamel surfaces of 40 healthy molars were used for four study groups: (A) no treatment; (B) application of fluoride gel for 120 s; (O) a diode laser application for 120 s; and (X) a combined laser/fluoride for 120 s. Each enamel surface was examined by SEM (scanning electron microscopy). (3) Results: At 700× magnification, it was possible to detect the enamel prisms of the test area of groups A, B, and O, while no structures such as enamel prisms were highlighted for group X because they were covered by an amorphous layer. The mean number of prisms ×1000 µm2 was 7.2 units with an SD of 0.72 for group A, 8 units with an SD of 0.96 for group B, and 4.8 units with a SD of 0.4 for group O. Student’s t-test showed no significant difference between group A and B with a p = 0.054. Group O showed a significant reduction of prims ×1000 µm2 compared with group A (p = 0.0027) and group B (p = 0.0009). Student’s t-test showed no significant difference between groups A and B with a p = 0.054. Group O showed a significant reduction of prims density with respect to group A (p = 0.0027) and group B (p = 0.0009). (4) Conclusions: This amorphous layer might be correlated with the effect of laser on enamel, which reduces both water and carbonate ion; increases the crystallinity of hydroxyapatite, and improves the mechanical properties of enamel; which is responsible for greater protection expressed by the enamel of group X against acid attacks