A Further Note on Federal Causes of Action

In the article, I argue that federal causes of action ought to be treated as (1) distinct from substantive rights, (2) synonymous with the availability of a remedy (but not whether a remedy will in fact issue) and (3) distinct from subject matter jurisdiction (unless Congress instructs otherwise). This thesis is built principally on a historical recounting of the cause of action from eighteenth century England to twenty-first century America. In taking an historical approach, I did not mean to argue that federal courts are bound to adhere to centuries-old conceptions of the cause of action. I merely used history to show why the cause of action has taken on various identities and, further, why these identities have changed over time. By closely attending to these changes, we can better determine whether linguistic changes signal substantive changes in doctrine, or are simply loose language

The Fermi Bubble as a Source of Cosmic Rays in the Energy Range > 10E15 eV

The {\it Fermi} Large Area Telescope has recently discovered two giant gamma-ray bubbles which extend north and south of the Galactic center with diameters and heights of the order of $H\sim 10$ kpc. We suggest that the periodic star capture processes by the Galactic supermassive black hole Sgr A$^*$, with a capture rate of $\tau_{\rm cap}^{-1}\sim 3\times 10^{-5}$ yr$^{-1}$ and an energy release of $W\sim 3\times 10^{52}$ erg per capture, can result in hot plasma injecting into the Galactic halo at a wind velocity of $u\sim 10^8$ cm s$^{-1}$. The periodic injection of hot plasma can produce a series of shocks. Energetic protons in the bubble are re-accelerated when they interact with these shocks. We show that for energy larger than $E> 10^{15}$ eV, the acceleration process can be better described by the stochastic second-order Fermi acceleration. We propose that hadronic cosmic rays (CRs) within the ``knee'' of the observed CR spectrum are produced by Galactic supernova remnants distributed in the Galactic disk. Re-acceleration of these particles in the Fermi Bubble produces CRs beyond the knee. With a mean CR diffusion coefficient in this energy range in the bubble $D_B\sim 3\times 10^{30}$ cm$^2$ s$^{-1}$, we can reproduce the spectral index of the spectrum beyond the knee and within. The conversion efficiency from shock energy of the bubble into CR energy is about 10\%. This model provides a natural explanation of the observed CR flux, spectral indices, and matching of spectra at the knee.Comment: 43 pages, 8 figues, to be published in the Astrophysical Journal; version 2, 45 pages, 8 figures, added references and corrected typo

Chromospheric Variability in SDSS M Dwarfs. II. Short-Timescale H-alpha Variability

[Abridged] We present the first comprehensive study of short-timescale chromospheric H-alpha variability in M dwarfs using the individual 15 min spectroscopic exposures for 52,392 objects from the Sloan Digital Sky Survey. Our sample contains about 10^3-10^4 objects per spectral type bin in the range M0-M9, with a total of about 206,000 spectra and a typical number of 3 exposures per object (ranging up to a maximum of 30 exposures). Using this extensive data set we find that about 16% of the sources exhibit H-alpha emission in at least one exposure, and of those about 45% exhibit H-alpha emission in all of the available exposures. Within the sample of objects with H-alpha emission, only 26% are consistent with non-variable emission, independent of spectral type. The H-alpha variability, quantified in terms of the ratio of maximum to minimum H-alpha equivalent width (R_EW), and the ratio of the standard deviation to the mean (sigma_EW/), exhibits a rapid rise from M0 to M5, followed by a plateau and a possible decline in M9 objects. In particular, R_EW increases from a median value of about 1.8 for M0-M3 to about 2.5 for M7-M9, and variability with R_EW>10 is only observed in objects later than M5. For the combined sample we find that the R_EW values follow an exponential distribution with N(R_EW) exp[-(R_EW-1)/2]; for M5-M9 objects the characteristic scale is R_EW-1\approx 2.7, indicative of stronger variability. In addition, we find that objects with persistent H-alpha emission exhibit smaller values of R_EW than those with intermittent H-alpha emission. Based on these results we conclude that H-alpha variability in M dwarfs on timescales of 15 min to 1 hr increases with later spectral type, and that the variability is larger for intermittent sources.Comment: Submitted to ApJ; 20 pages, 15 figure

Tick species from cattle in the Adama Region of Ethiopia and pathogens detected

Ticks will diminish productivity among farm animals and transmit zoonotic diseases. We conducted a study to identify tick species infesting slaughter bulls from Adama City and to screen them for tick-borne pathogens. In 2016, 291 ticks were collected from 37 bulls in Adama, which were ready for slaughter. Ticks were identified morphologically. Total genomic DNA was extracted from ticks and used to test for Rickettsia spp. with real-time PCR. Species identification was done by phylogenetic analysis using sequencing that targeted the 23S-5S intergenic spacer region and ompA genes. Four tick species from two genera, Amblyomma and Rhipicephalus, were identified. Amblyomma cohaerens was the dominant species (n = 241, 82.8%), followed by Amblyomma variegatum (n = 22, 7.5%), Rhipicephalus pulchellus (n = 19, 6.5%), and Rhipicephalus decoloratus (n = 9, 3.0%). Among all ticks, 32 (11%) were positive for Rickettsia spp. and 15 (5.2%) of these were identified as R. africae comprising at least two genetic clades, occurring in A. variegatum (n = 10) and A. cohaerens (n = 5). The remainder of Rickettsia-positive samples could not be amplified due to low DNA yield. Furthermore, another 15 (5.2%) samples carried other pathogenic bacteria: Ehrlichia ruminantium (n = 9; 3.1%) in A. cohaerens, Ehrlichia sp. (n = 3; 1%) in Rh. pulchellus and A. cohaerens, Anaplasma sp. (n = 1; 0.5%) in A. cohaerens, and Neoehrlichia mikurensis (n = 2; 0.7%) in A. cohaerens. All ticks were negative for Bartonella spp., Babesia spp., Theileria spp., and Hepatozoon spp. We reported for the first time E. ruminatium, N. mikurensis, Ehrlichia sp., and Anaplasma sp. in A. cohaerens. Medically and veterinarily important pathogens were mostly detected from A. variegatum and A. cohaerens. These data are relevant for a One-health approach for monitoring and prevention of tick-borne disease transmission

Magnetic field generation in fully convective rotating spheres

Magnetohydrodynamic simulations of fully convective, rotating spheres with volume heating near the center and cooling at the surface are presented. The dynamo-generated magnetic field saturates at equipartition field strength near the surface. In the interior, the field is dominated by small-scale structures, but outside the sphere by the global scale. Azimuthal averages of the field reveal a large-scale field of smaller amplitude also inside the star. The internal angular velocity shows some tendency to be constant along cylinders and is ``anti-solar'' (fastest at the poles and slowest at the equator).Comment: 12 pages, 11 figures, 2 tables, to appear in the 10 Feb issue of Ap