Back to the Drawing Board: Revisiting the Supreme Court\u27s Stance on Partisan Gerrymandering

In the United States, state legislatures have drawn voting districts to achieve desired election results for hundreds of years. Dating back to the James Madison presidency, various legislatures and iterations of the U.S. Supreme Court have wrestled with the legal and constitutional issues that stem from the practice known as “gerrymandering.” While courts and legislatures have, at times, been successful in eliminating some of the more sinister uses of the tactic, such as racially motivated district-line drawing, gerrymandering inspired by partisan motives remains. Continual improvements in technology coupled with an increasingly divided political culture mean that partisan gerrymandering is at risk of becoming more effective than ever. As a result, the voices of individuals with political ideologies opposing those of the sitting state legislatures risk being quieted to barely audible whispers. Until this year, however, the Supreme Court had contented itself to stand idly by, firmly refusing to wade into the legal and constitutional muck that is partisan gerrymandering. This Note explores the uses and effects of partisan gerrymandering by modern state legislatures. It then delves into the contentious history of the partisan gerrymandering question at the Supreme Court level, with special focus on a concurring opinion by Justice Kennedy in which he proposed a solution for how to handle future partisan gerrymandering issues. This Note analyzes the validity of Justice Kennedy’s solution and ultimately concludes that his proposal has sound legal and practical support and would allow courts to hold unconstitutional efforts to gerrymander along political lines

Existentialism: Its Evolution and How It Applies Today

Daniel Vieth explores the meaning of existentialism, accomplished through discussion of philosophy and modern examples, such as The Matrix

Answering the Political Question: Demonstrating an Intent-Based Framework for Partisan Gerrymandering

Partisan gerrymandering is widely recognized as a threat to the foundations of our democracy. Political parties with control over their state legislatures routinely leverage the redistricting process to entrench themselves in power—suppressing political adversaries, chilling public participation, and polarizing the electorate. Nevertheless, despite a persistent recognition that partisan gerrymandering is incompatible with basic democratic principles, the Supreme Court struggled to develop a stable and consistent doctrinal approach to this issue, even as reliable standards emerged to adjudicate malapportionment and racial gerrymandering claims. Recently, in Rucho v. Common Cause, the Court abandoned the search entirely, holding that partisan gerrymandering is a nonjusticiable political question, grounded in impossible quantifications of fairness that leave it too amorphous for the federal courts to review. This Article challenges the Supreme Court’s political question holding, diagnoses the breakdown of federal partisan gerrymandering doctrine, and argues in favor of an intent-based framework. Part I invokes Professor John Hart Ely’s theory of representation-reinforcing review to argue that the political question doctrine is an exploration of political discretion, and that courts have authority to overturn laws that restrict the democratic process. Part II asserts that the Supreme Court’s decision to frame partisan gerrymandering doctrine around a map’s impact on future elections, rather than the predominant intent of the mapmakers, was the source of its inability to develop manageable standards and the genesis of the doctrine’s collapse. Part III provides a unique, comprehensive synthesis of leading state and federal gerrymandering cases under the rubric of predominant legislative intent. The result is a manageable, proof-of-concept standard for partisan gerrymandering that guards against the worst distortions of the democratic process, while preserving the separation of powers and addressing the prudential concerns that hindered the evolution of this doctrine

Activated Carbon Prepared From Pomegranate Peel Microwave Assisted Koh Activation For Dyes Adsorption

Penghasilan karbon teraktif berasaskan kulit buah delima (KTKBD) melalui pengaktifan KOH berbantukan gelombang mikro telah berjaya dikaji. KTKBD yang terhasil telah digunakan untuk penyingkiran pewarna malacit hijau (MH) dan remazol brilliant biru reaktif (RBBR) daripada larutan akuas. KTKBD mempunyai luas permukaan yang tinggi 941.02 m2/g dan menunjukkan struktur liang meso tidak seragam serta terdapat pelbagai kumpulan berfungsi pada permukaan KTKBD. Kesan kepekatan awal pewarna (50-500 mg/L), masa sentuh (0-24 h), suhu larutan (30-60°C) dan pH larutan (2-12) telah dinilai melalui kajian penjerapan berkelompok. Jumlah penjerapan pewarna meningkat dengan peningkatan suhu, kepekatan awal pewarna dan masa sentuh. Penjerapan pewarna MH dan pewarna RBBR ke atas KTKBD adalah terbaik dipadankan oleh model Freundlich. Penjerapan kinetik MH dan RBBR ke atas KTKBD terbaik dipadankan oleh model kinetik pseudo-tertib kedua. Melalui kajian termodinamik, penjerapan pewarna MH dan RBBR ke atas KTKBD adalah berlaku secara jerapan fizikal, spontan dan endotermik. Melalui kajian mekanisma, kadar penjerapan dikawal oleh mekanisma serapan-filem. _______________________________________________________________________________________________________ The production of pomegranate peel based activated carbon (PPAC) through microwave assisted KOH activation has been successfully investigated. PPAC produced was used for removal of malachite green (MG) and remazol brilliant blue reactive (RBBR) dyes from aqueous solution. The PPAC has high surface area of 941.02 m2/g and demonstrated heterogeneous mesoporous type of pore structure with a presence of various functional groups on the PPAC’s surface. The effects of adsorbate initial concentration (50-500 mg/L), contact time (0-24 h), solution temperature (30-60oC) and solution pH (2-12) were evaluated through batch adsorption test. All dyes adsorption uptakes increased with increasing temperature, initial dyes concentration and contact time. Adsorption of MG and RBBR dyes onto PPAC were best fitted by Freundlich model. Adsorption kinetic of MG and RBBR dyes onto PPAC were best fitted by pseudo-second-order kinetic model. From the thermodynamic study, the MG and RBBR adsorption onto PPAC were physically controlled type, spontaneous and endothermic in nature. From the mechanism study, the adsorption rate was governed by film diffusion mechanism

Vieth v. Comm of PA

United States District Court for the Middle District of Pennsylvani