Judge Posner Got It Right: Requiring Abortion Doctors to Have Hospital Admitting Privileges Places an Undue Burden on a Woman Seeking an Abortion

Anti-abortion activists have sought to undermine and restrict a woman\u27s right to choose ever since 1992, when the Supreme Court replaced Roe v. Wade\u27s strict scrutiny analysis with the looser undue burden test in Southeastern Pennsylvania v. Casey. Under Casey\u27s undue burden test, a state regulation cannot have the purpose or effect of placing a significant obstacle in the path of a woman seeking an abortion of a nonviable fetus. However, the Casey Court failed to define the types of regulations that would run afoul of the undue burden test and create a substantial obstacle in the path of a woman seeking an abortion. As a result of this ambiguity, anti-abortion advocates have spent the last two decades trying to test the boundaries of the undue burden test. One popular approach has been to promulgate incremental regulations that chip away at a woman\u27s right to seek an abortion. Targeted Regulation of Abortion Providers (TRAP) laws are one form of these incremental regulations. One such TRAP law is at issue in the Seventh Circuit\u27s case Planned Parenthood of Wisconsin Inc. v. Van Hollen. The TRAP law at issue was a Wisconsin law requiring abortion doctors to have admitting privileges at a hospital within thirty miles of a clinic where an abortion is performed. Although the question before the court was technically limited to whether the preliminary injunction prohibiting the Wisconsin law from going into effect was justified, Judge Posner reasoned that that law was unconstitutional and should be struck. When the Supreme Court decides to hear a case involving a similar admitting privileges TRAP law, the Court should use Judge Posner\u27s reasoning as a guide to strike down the law. These admitting privileges statutes are unconstitutional because: (1) these laws place an undue burden on a woman seeking an abortion by dramatically impacting the practical availability of abortion within a state; (2) these laws bear no rational relationship to their purported purpose of protecting maternal health; and (3) these laws violate equal protections of the law by singling out abortion doctors for increased oversight

Leveraging Predictive Policing Algorithms to Restore Fourth Amendment Protections in High-Crime Areas in a Post-Wardlow World

Rapid technological changes have led to an explosion in Big Data collection and analysis through complex computerized algorithms. Law enforcement has not been immune to these technological developments. Many local police departments are now using highly advanced predictive policing technologies to predict when and where crime will occur in their communities, and to allocate crime-fighting resources based on these predictions. Although predictive policing technology has an array of the potential uses, the scope of this Note is limited to addressing how the statistical outputs from these technologies can be used to restore eroded Fourth Amendment rights in alleged high-crime areas. As the use of sophisticated predictive policing software becomes more widespread, courts will need to address how the statistical outputs from this technology factor into the reasonable suspicion calculus when a police officer performs a Terry stop in an alleged “high-crime” area. This Note argues that uniform standards and best practices must be developed to guide law enforcement’s use of predictive policing software, and that this software should be leveraged as a tool to help restore eroded Fourth Amendment rights

Judge Posner Got It Right: Requiring Abortion Doctors to Have Hospital Admitting Privileges Places an Undue Burden on a Woman Seeking an Abortion

Anti-abortion activists have sought to undermine and restrict a woman\u27s right to choose ever since 1992, when the Supreme Court replaced Roe v. Wade\u27s strict scrutiny analysis with the looser undue burden test in Southeastern Pennsylvania v. Casey. Under Casey\u27s undue burden test, a state regulation cannot have the purpose or effect of placing a significant obstacle in the path of a woman seeking an abortion of a nonviable fetus. However, the Casey Court failed to define the types of regulations that would run afoul of the undue burden test and create a substantial obstacle in the path of a woman seeking an abortion. As a result of this ambiguity, anti-abortion advocates have spent the last two decades trying to test the boundaries of the undue burden test. One popular approach has been to promulgate incremental regulations that chip away at a woman\u27s right to seek an abortion. Targeted Regulation of Abortion Providers (TRAP) laws are one form of these incremental regulations. One such TRAP law is at issue in the Seventh Circuit\u27s case Planned Parenthood of Wisconsin Inc. v. Van Hollen. The TRAP law at issue was a Wisconsin law requiring abortion doctors to have admitting privileges at a hospital within thirty miles of a clinic where an abortion is performed. Although the question before the court was technically limited to whether the preliminary injunction prohibiting the Wisconsin law from going into effect was justified, Judge Posner reasoned that that law was unconstitutional and should be struck. When the Supreme Court decides to hear a case involving a similar admitting privileges TRAP law, the Court should use Judge Posner\u27s reasoning as a guide to strike down the law. These admitting privileges statutes are unconstitutional because: (1) these laws place an undue burden on a woman seeking an abortion by dramatically impacting the practical availability of abortion within a state; (2) these laws bear no rational relationship to their purported purpose of protecting maternal health; and (3) these laws violate equal protections of the law by singling out abortion doctors for increased oversight

Leveraging Predictive Policing Algorithms to Restore Fourth Amendment Protections in High-Crime Areas in a Post-Wardlow World

Rapid technological changes have led to an explosion in Big Data collection and analysis through complex computerized algorithms. Law enforcement has not been immune to these technological developments. Many local police departments are now using highly advanced predictive policing technologies to predict when and where crime will occur in their communities, and to allocate crime-fighting resources based on these predictions. Although predictive policing technology has an array of the potential uses, the scope of this Note is limited to addressing how the statistical outputs from these technologies can be used to restore eroded Fourth Amendment rights in alleged high-crime areas. As the use of sophisticated predictive policing software becomes more widespread, courts will need to address how the statistical outputs from this technology factor into the reasonable suspicion calculus when a police officer performs a Terry stop in an alleged “high-crime” area. This Note argues that uniform standards and best practices must be developed to guide law enforcement’s use of predictive policing software, and that this software should be leveraged as a tool to help restore eroded Fourth Amendment rights

Optical and X-ray Properties of the Swift BAT-detected AGN

The Swift Gamma-Ray Burst satellite has detected a largely unbiased towards absorption sample of local ($\approx 0.03$) AGN, based solely on their 14--195 keV flux. In the first 9 months of the survey, 153 AGN sources were detected. The X-ray properties in the 0.3--10 keV band have been compiled and presented based on analyses with XMM-Newton, Chandra, Suzaku, and the Swift XRT (Winter et al. 2009). Additionally, we have compiled a sub-sample of sources with medium resolution optical ground-based spectra from the SDSS or our own observations at KPNO. In this sample of 60 sources, we have classified the sources using standard emission line diagnostic plots, obtained masses for the broad line sources through measurement of the broad H$\beta$ emission line, and measured the [OIII] 5007\AA luminosity of this sample. Based on continuum fits to the intrinsic absorption features, we have obtained clues about the stellar populations of the host galaxies. We now present the highlights of our X-ray and optical studies of this unique sample of local AGNs, including a comparison of the 2--10 keV and 14--195 keV X-ray luminosities with the [OIII] 5007\AA luminosity and the implications of our results towards measurements of bolometric luminosities.Comment: 4 pages, 2 figures, to appear in proceedings for 'X-ray Astronomy 2009', Bologna 09/2009, AIP Conference Series, Eds. A. Comastri, M. Cappi, L. Angelin

[O III]λ5007\lambda 5007 and X-ray Properties of a Complete Sample of Hard X-ray Selected AGNs in the Local Universe

We study the correlation between the [O III]$\lambda 5007$ and X-ray luminosities of local Active Galactic Nuclei (AGNs), using a complete, hard X-ray ($>10$ keV) selected sample in the Swift/BAT 9-month catalog. From our optical spectroscopic observations at the South African Astronomical Observatory and the literature, a catalog of [O III]$\lambda 5007$ line flux for all 103 AGNs at Galactic latitudes of $|b|>15^\circ$ is complied. Significant correlations with intrinsic X-ray luminosity ($L_{\rm X}$) are found both for observed ($L_{\rm [O~III]}$) and extinction-corrected ($L_{\rm [O~III]}^{\rm cor}$) luminosities, separately for X-ray unabsorbed and absorbed AGNs. We obtain the regression form of $L_{\rm [O~III]}$ $\propto L_{\rm 2-10\; keV}^{1.18\pm0.07}$ and $L_{\rm [O~III]}^{\rm cor}$ $\propto L_{\rm 2-10\; keV}^{1.16\pm0.09}$ from the whole sample. The absorbed AGNs with low ($<$0.5\%) scattering fractions in soft X-rays show on average smaller $L_{\rm [O~III]}/L_{\rm X}$ and $L_{\rm [O~III]}^{\rm cor}/L_{\rm X}$ ratios than the other absorbed AGNs, while those in edge-on host galaxies do not. These results suggest that a significant fraction of this population are buried in tori with small opening angles. By using these $L_{\rm [O~III]}$ vs. $L_{\rm X}$ correlations, the X-ray luminosity function of local AGNs (including Compton thick AGNs) in a standard population synthesis model gives much better agreement with the [O III]$\lambda 5007$ luminosity function derived from the Sloan Digital Sky Survey than previously reported. This confirms that hard X-ray observations are a very powerful tool to find AGNs with high completeness.Comment: 14 pages including 11 figures and 3 tables, accepted for publication in ApJ. In this manuscript, the observed 14-195 keV luminosities in Table 1 have been corrected to be exactly the same as in the original Swift/BAT 9-month catalog. Accordingly, Figures 2(a) and 3(a) and a part of Tables 2 and 3 have been updated. The changes from the previous version are small and do not affect the tex

Neuronal human BACE1 knock-in induces systemic diabetes in mice

Acknowledgements The authors thank S. Tammireddy (Diabetes and Cardiovascular Science, University of the Highlands and Islands, Inverness, UK) for technical support with the lipidomics component. Funding We would like to thank R. Simcox, Romex Oilfield Chemicals, for financial support for KP, and acknowledge additional contributions from the Scottish Alzheimer’s Research UK network for the lipidomics work. The College of Life Science and Medicine, University of Aberdeen, sponsored the imaging study. MD was funded by British Heart Foundation and Diabetes UK; NM was funded by a British Heart Foundation Intermediate Fellowship; KS was funded by a European Foundation for the Study of Diabetes/Lilly programme grant; and RD was funded by an Institute of Medical Sciences PhD studentship.Peer reviewedPublisher PDFPublisher PD