Phaffia rhodozyma: colorful odyssey

Phaffia rhodozyma was isolated by Herman Phaff in the 1960s, during his pioneering studies of yeast ecology. Initially, the yeast was isolated from limited geographical regions, but isolates were subsequently obtained from Russia, Chile, Finland, and the United States. The biological diversity of the yeast is more extensive than originally envisioned by Phaff and his collaborators, and at least two species appear to exist, including the anamorph Phaffia rhodozyma and the teleomorph Xanthophyllomyces dendrorhous. The yeast has attracted considerable biotechnological interest because of its ability to synthesize the economically important carotenoid astaxanthin (3,3´-dihydroxy-β, β-carotene-4,4´-dione) as its major pigment. This property has stimulated research on the biology of the yeast as well as development of the yeast as an industrial microorganism for astaxanthin production by fermentation. Our laboratory has isolated several mutants of the yeast affected in carotenogenesis, giving colonies a vivid array of pigmentation. We have found that nutritional and environmental conditions regulate astaxanthin biosynthesis in the yeast, and have demonstrated that astaxanthin protects P. rhodozyma from damage by reactive oxygen species. We proposed in the 1970s that P. rhodozyma could serve as an economically important pigment source in animal diets including salmonids, lobsters, and the egg yolks of chickens and quail, in order to impart characteristic and desirable colors. Although P. rhodozyma/Xanthomyces dendrorhous has been studied by various researchers for nearly 30 years, it still attracts interest from yeast biologists and biotechnologists. There is a bright and colorful outlook for P. rhodozyma/X. dendrorhous from fundamental and applied research perspectives

Cause-in-Fact After Burrage v. United States

What significance, if any, should state courts assign to the U.S. Supreme Court’s unanimous 2014 decision in Burrage v United States? In Burrage, the Supreme Court relied on “ordinary meaning” and “traditional understanding” in concluding that causation elements in federal criminal statutes nearly always require so-called “but-for” causation. State courts, by contrast, traditionally have applied two important modifications to the but-for test: (1) an acceleration rule, which assigns liability to defendants who hasten “even by a moment” the coming to fruition of the proscribed harm; and (2) a contribution rule, which assigns liability to defendants who “contribute” incrementally to the underlying causal mechanism. This Article defends the state courts’ approach. It argues that the acceleration rule and the contribution rule both are necessary to address cases where the but-for test fails to capture ordinary usage. Specifically, these supplementary rules are necessary to address cases of spurious, or preempted, causal sufficiency and cases of causal overdetermination

When Provocation Is No Excuse: Making Gun Owners Bear the Risks of Carrying in Public

Markeis McGlockton, an unarmed 28-year-old African-American father of three, was shot to death in front of his five-year-old son by “wannabe police officer” Michael Drejka during an argument over parking. Because McGlockton had shoved Drejka before Drejka shot him, Drejka was convicted only of heat-of-passion manslaughter, not murder. This Article argues that the heat-of-passion defense shouldn’t be available in cases like Drejka’s—cases where the defendant was carrying a loaded gun in public at the time of the provocation and used the gun to kill his provoker. The heat-of-passion defense is a concession to the difficulty of complying with the law’s demands in moments of passion. In cases like Drejka’s, however, the defendant’s difficulty in complying with the homicide law is of his own making. If he had taken the same precaution that most people take against such difficulties—namely, not carrying a loaded gun in public—he wouldn’t have had any trouble not killing his provoker. In defending the proposed limit on the heat-of-passion defense, this Article will advance three novel claims about the criminal law: (1) that self-mediated risk—risk that is mediated by the actor’s own future volitional conduct—sometimes suffices to make conduct morally blameworthy; (2) that even decisions by an actor that appear to represent core exercises of protected individual liberties—the decision to form racist beliefs, for example, or the decision to carry a gun outside the home—sometimes can supply the locus of moral blame in criminal prosecutions; and (3) that in cases where the actor’s fault inheres in self-mediated risk, the law’s usual reluctance to impute moral blame doesn’t apply

Cause-in-Fact After Burrage v. United States

What significance, if any, should state courts assign to the U.S. Supreme Court’s unanimous 2014 decision in Burrage v United States? In Burrage, the Supreme Court relied on “ordinary meaning” and “traditional understanding” in concluding that causation elements in federal criminal statutes nearly always require so-called “but-for” causation. State courts, by contrast, traditionally have applied two important modifications to the but-for test: (1) an acceleration rule, which assigns liability to defendants who hasten “even by a moment” the coming to fruition of the proscribed harm; and (2) a contribution rule, which assigns liability to defendants who “contribute” incrementally to the underlying causal mechanism. This Article defends the state courts’ approach. It argues that the acceleration rule and the contribution rule both are necessary to address cases where the but-for test fails to capture ordinary usage. Specifically, these supplementary rules are necessary to address cases of spurious, or preempted, causal sufficiency and cases of causal overdetermination

Habit, Crime, and Culpability

Courts and scholars long have distinguished the wrongdoing component of criminal liability from the culpability component. In the old days, wrongdoing was thought to be crime’s physical, objective component— the “evil-doing hand.” Culpability, by contrast, was the mental, subjective component—the “evil-meaning mind.” Nowadays, most scholars agree with Holmes that even the wrongdoing component requires proof of the actor’s mental state. If the wrongdoing component requires proof of the actor’s mental state, though, what’s the point of the culpability requirement? For now, the dominant answer appears to be that the culpability requirement is a concession to human weakness. In this Article, I will develop a different view. I will argue that the culpability requirement is less a concession to human weakness than to the varieties of human rationality. Building on insights by philosopher Michael Bratman and others, I will argue that rationality can take at least two fundamentally different forms. The wrongdoing requirement is concerned only with conduct’s time-slice rationality—with the act’s downstream risks and utilities as measured from the moment of the act. Conduct that isn’t time- slice rational, however, still can embody a second kind of rationality, namely, temporally extended rationality. This second variety of rationality is present, for example, when an actor’s conduct is attributable to desirable habits of thinking, feeling, or behaving. The culpability requirement is best understood as addressed to this second kind of rationality. It absolves just those actors whose conduct, though wrongful, nevertheless is a product of desirable habits