Plant-Microbial Interactions Change Along a Prairie Restoration Chronosequence

Soil microbial communities are critical in determining the performance and density of species in plant communities. However, their role in regulating the success of restorations is much less clear. This study assessed the ability of soil microbial communities to regulate the growth and performance of two potentially dominant grasses and two common forbs in prairie restorations. Specifically, I examined the effects of soil microbial communities along a restoration chronosequence from agricultural fields to remnant prairies using experimentally inoculated soils. The two grass species, Andropogon gerardii and Sorghastrum nutans, produced larger biomass with the agricultural inoculates and experienced a decline in performance in later stages of the chronosequence, indicating that the microbial community shifted from being beneficial to grasses in the early stages to inhibiting grasses in the later stages of restoration. The forb, Silphium terebinthinaceum was largely unaltered by the inoculation or position along the restoration chronosquence. Baptisia leucantha growth appeared limited by nodule formation in agricultural soils, peaked in young restoration soils along with module formation, but decreased in older soils as the microbial community became more antagonistic. Overall, this experiment showed strong site variability, representing patchiness in microbial interactions, though older soils consistently had the strongest inhibitory effect on growth. Negative feedbacks tended to be less important in the beginning stages of succession in these restorations but appear important in remnant and restored prairies. My results provide evidence that it maybe advantageous for management practices to take negative feedbacks into consideration when trying to recreate the diversity of prairies

Gonzalo Navajas: La modernidad como crisis. Los clásicos modernos ante el siglo XXI

Review of: Gonzalo Navajas. La modernidad como crisis. Los clásicos modernos ante el siglo XXI. Madrid: Bibilioteca Nueva, 2004. 184 pp

Numa and the Nature of the Fantastic in the Fiction of Juan Benet

Perhaps the most rewarding critical approach to the novels of Juan Benet is one that encompasses the irrational and seeks to reveal the mysterious— one that can be closely identified with the notion of the fantastic. The view of the fantastic developed in the present study is based on a synthetic modification of the precepts of Todorov and Rabkin, and places emphasis on the hesitation of the reader when confronted with a diametric reversal of the laws of the text. Both the literary theory and prose fiction of Benet can be closely linked to the fantastic: the former through Benet\u27s focus on narrative uncertainty and ambiguity; the latter in a variety of important ways, but most pervasively through the character Numa. Numa recurs throughout Benet\u27s fiction as an enigmatic and superhuman figure. He at once conforms to and transgresses the norms of the text, and inspires reader hesitation in the face of the marvelous. Through him Benet reifies many of his theoretical tenets, and also shapes the specific nature of his fantastic world

The Gig Economy’s Short Reach: An Analysis of the Scope of the Federal Arbitration Act’s “Transportation Worker” Exemption

The Federal Arbitration Act (FAA) governs arbitration agreements in the United States. Section 1 of the FAA provides an exemption from arbitration for “contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” In a 2001 decision, Circuit City Stores, Inc. v. Adams, the U.S. Supreme Court held that the residual phrase “any other class of workers engaged in foreign or interstate commerce” includes transportation workers. But, such language is ambiguous, and the Supreme Court did not expound upon what it means to be a transportation worker or to be engaged in interstate commerce for purposes of the exemption. Since the FAA’s enactment in 1925, modes of employment have evolved drastically and now include the recent platform or mobile-based gig economy—one subsect of which includes delivery drivers working for companies like Amazon Flex, Grubhub, Lyft, and Uber. Mandatory arbitration agreements in their employment contracts compel these drivers to arbitrate, rather than litigate, disputes against these companies. A circuit split has emerged regarding whether modern gig economy drivers fall within the “transportation worker” exemption, with courts divided primarily on whether these drivers are “engaged in interstate commerce.” Without a blueprint to follow, lower courts have created their own tests and applied their own standards to these drivers, leading to inconsistent results. Some courts have held that the driver does not need to cross state lines to be exempt from arbitration; instead, these courts look to the companies that these drivers work for to determine if the company is engaged in interstate commerce. If so, they find that the company’s workers are engaged in interstate commerce. Other courts emphasize that the driver must be a member of a “class of workers” that is engaged in interstate commerce, thereby requiring the driver to actually cross state lines to obtain the exemption. This circuit split highlights the difficulty of applying a near century-old statute to a modern worker context. This Note argues that, in the absence of a Supreme Court ruling or congressional amendment on the matter, lower courts should not exempt gig economy delivery drivers from arbitrating employment disputes against their platform companies because the drivers are not transportation workers engaged in interstate commerce

Circuit Split Deepened by Second Circuit\u27s \u27Functional\u27 Test Application in Recent Section 1782 Ruling

Federal law authorizes district courts to order discovery for use in a proceeding before a foreign or international tribunal. While that law, 28 U.S.C. § 1782, permits interested persons to request such discovery, neither the statutory language nor Supreme Court jurisprudence definitively resolves whether private arbitral tribunals fall within its scope. Unsurprisingly, the lack of clear guidance on this matter has triggered a circuit split, with the Second and Fifth Circuits generally declining to extend § 1782 to private arbitral tribunals while the Fourth and Sixth Circuits broadly interpret the statutory language to apply § 1782 to private arbitral tribunals. In the Eleventh Circuit, the doctrine is in flux