Compensation for Environmental Damage: Progressively Casting a Wider Net, but What’s the Catch?

In the case Certain Activities Carried Out by Nicaragua in the Border Area (Costa Rica v. Nicaragua)–-Compensation Owed by The Republic of Nicaragua to The Republic of Costa Rica (the Costa Rica case), the International Court of Justice (ICJ) had to ascertain the compensation amount due by Nicaragua for the environmental damage it had caused to Costa Rica. This was the first time the ICJ was asked to weigh in and settle an environmental damage compensation claim between two states. After a concise introduction in Part I, this Article will first review the distinction between state responsibility for wrongful acts (as applicable in the Costa Rica case) and the international liability of states in the absence of wrongfulness in Part II. In Part III a detailed analysis of the Costa Rica case will be undertaken, with as its starting point the explicit acknowledgment by the ICJ that compensation is, indeed, due for damage caused to the environment, in and of itself, even if that damage is caused to non-marketable components of the environment, such as damageto a wetland or damage to an ecosystem. Next, this Article will critique the absence of transparency in the ICJ judgment on the valuation method it applied to calculate the final compensation amount as well as the paltry sum which Nicaragua ultimately owed to Costa Rica in this case. The general reluctance by the ICJ to apply punitive damages, in principle, does open an interesting comparative law debate on how common law and civil law countries differ in applying punitive damages in environmental cases. Where punitive damages may not be uniformly applied in national jurisdictions, most domestic courts do readily appoint experts in environmental matters given the inherent technical and scientific nature of such disputes. Therefore, this Article suggests the view that moving forward the ICJ should more actively appoint its own independent experts in environmental disputes, rather than merely relying on the evidence brought forward by the parties. This would go a long way in arriving at more robust scientific conclusions which in turn would allow the ICJ to contribute in a more meaningful manner to the development of international environmental and climate change law. Part IV seeks to demonstrate how domestic responses by the judiciary or the legislature increasingly tend to go further and be more proactive compared to the approaches of international regimes and adjudicating bodies when addressing environmental damage claims. This is illustrated based on a brief analysis of both the Deepwater Horizon and Erika oil spill cases and contrasted with the cases handled and interpretation given by the International Oil Pollution Compensation Funds when interpreting terms such as “environment” and “environmental damage.” Part V offers some concluding thoughts on the overall contribution of the ICJ’s Costa Rica case, including the suggestion that the court could have adopted a more “proactive judicial policy” in such an important transboundary environmental dispute between states

Acute Burkitt\u27s Leukemia: Case Report and Literature Review

The occurrence of leukemia in Burkitt\u27s lymphoma, with or without visceral or nodal tumefaction is uncommon, and its initial presentation as leukemia is even more unusual. Because it has a poor chemotherapeutic response and a grave prognosis, it is important to recognize this unusual leukemia correctly. Our report describes the clinical and pathologic findings of Burkitt\u27s lymphoma cell leukemia in a five-year-old white boy who presented with abdominal distension, hepatosplenomegaly, and lymphadenopathy. Blood examination revealed normocytic normochromic anemia, erythroblastosis, slight leukocytosis, and the presence of numerous (24%) blasts. A diagnosis of Burkitt\u27s lymphoma was established on the basis of morphologic, cytochemical, and immunologic studies performed on the blasts. When the chemotherapy protocol for the lymphoma was administered, the patient responded well initially but suffered uric acid nephropathy, which was successfully treated. However, within two weeks he had a rapid relapse of leukemia and died four months after admission

Angle Dependent Magnetoresistance of the Layered Organic Superconductor \kappa-(ET)2Cu(NCS)2: Simulation and Experiment

The angle-dependences of the magnetoresistance of two different isotopic substitutions (deuterated and undeuterated) of the layered organic superconductor \kappa-(ET)2Cu(NCS)2 are presented. The angle dependent magnetoresistance oscillations (AMRO) arising from the quasi-one-dimensional (Q1D) and quasi-two-dimensional (Q2D) Fermi surfaces in this material are often confused. By using the Boltzman transport equation extensive simulations of the AMRO are made that reveal the subtle differences between the different species of oscillation. No significant differences are observed in the electronic parameters derived from quantum oscillations and AMRO for the two isotopic substitutions. The interlayer transfer integrals are determined for both isotopic substitutions and a slight difference is observed which may account for the negative isotope effect previously reported [1]. The success of the semi-classical simulations suggests that non-Fermi liquid effects are not required to explain the interlayer-transport in this system.Comment: 15 pages, 16 figure

Pericardial Tamponade in Acute Myeloid Leukemia

We are reporting a case of acute myeloid leukemia in a child with pericardial effusion and cardiac tamponade, with a review of the literature. Morphologic and cytochemical evidence was used to diagnose acute myeloid leukemia, and radiologic, electrocardiographic, echocardiographic, cytologic, and histologic evidence confirmed the diagnosis of tamponade and pericardial leukemic involvement. Pericardiotomy and pericardial window drainage successfully relieved the tamponade, and conventional chemotherapy was used to induce a remission

To Implant or not to Implant?: The Role of Imaging

Missing teeth are best replaced by implants, provided the implant is placed in a way that it fulfills esthetic, functional and biomechanical requirements. The assessment of the proposedimplant site requires a very specific and accurate data. This could be accomplished by various imaging modalities starting from two-dimensional traditional radiographs to three-dimensional computed tomography and cone beam computed tomography. The purpose of this article is to provide an overview of different imaging modalities, the type of imaging best suited at different time frames of implant placement and effective radiation dose to the patient in these imaging modalities

From LTL and Limit-Deterministic B\"uchi Automata to Deterministic Parity Automata

Controller synthesis for general linear temporal logic (LTL) objectives is a challenging task. The standard approach involves translating the LTL objective into a deterministic parity automaton (DPA) by means of the Safra-Piterman construction. One of the challenges is the size of the DPA, which often grows very fast in practice, and can reach double exponential size in the length of the LTL formula. In this paper we describe a single exponential translation from limit-deterministic B\"uchi automata (LDBA) to DPA, and show that it can be concatenated with a recent efficient translation from LTL to LDBA to yield a double exponential, \enquote{Safraless} LTL-to-DPA construction. We also report on an implementation, a comparison with the SPOT library, and performance on several sets of formulas, including instances from the 2016 SyntComp competition

Immunocytologic Methods in the Diagnosis of Orbital Tumors

The pathologic diagnosis was supported or confirmed in three out of four cases that had an adequate cytologic specimen. The results demonstrate that adjunctive immunocytologic techniques can be used in combination with fine-needle aspiration for a variety of orbital tumors. The pathologic diagnosis was supported or confirmed in three out of four cases that had an adequate cytologic specimen. The results demonstrate that adjunctive immunocytologic techniques can be used in combination with fine-needle aspiration for a variety of orbital tumors

HPLC Method for Determination of p-coumaric acid from the Medicinal Herb Leptadinia reticulata

The aim of present study was to develop and validate a simple, precise and rapid HPLC method for the quantification of p-coumaric acid in Leptadinia reticulata extractst. The analysis was performed by reverse-phase chromatography on an phenomenex C18 columns with isocratic elution of Methanol and 0.8%-Formic acid in water (6:4) at a flow rate of 1.0mL/min, a column temperature of 35°C, photodiode array detector detection at 326 nm. The method validated in terms of linearity accuracy precision LOD, LOQ and stability. The herb Leptidinia reticulata contains 0.17% p-coumaric acid. The linear range of method was 0.25-50µg/ml with correlation coefficient of 0.9993, the recovery was 98-99.4% and the relative standard deviation is 0.98 % (n=6). The developed method was found to be a relatively simple, precise and reproducible for the quantification of p-coumaric acid. The method does not employ any derivatization procedure and can be used as a quality control tool for the routine analysis of    p-coumaric acid from an herb Leptadinia reticulata