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

Reference Systems in Spatial Memory for Vertical Locations

Three experiments investigated the frame of reference used in memory to represent vertical spatial layouts perceivable from a single viewpoint. We tested for the selection of three different reference systems: the body orientation, the visual vertical of the surrounding room, and the direction of gravity. Participants learned and retrieved differently colored objects on a vertical board with body and room orientations varying in relation to gravity and each other systematically. Across all three experiments participants were quicker or more accurate in memory recall when they saw the vertical spatial layout in the same orientation in relation to their body vertical as during learning, irrespective of the direction of gravity or visual room upright. These results indicate that spatial long-term memories for small-scale vertical relations are mainly defined in an egocentric reference system with respect to the body vertical despite the availability of alternative highly salient allocentric reference directions