Collateral Estoppel and the Right to a Jury Trial: \u3ci\u3eShore v. Parklane Hosiery Co.\u3c/i\u3e, 565 F.2d 815 (2d Cir. 1977), \u3ci\u3ecert. granted\u3c/i\u3e, 46 U.S.L.W. 3674-75 (U.S. May 2, 1978) (No. 77-1305)

Determining when the United States Constitution requires a jury trial in civil actions involves the analysis of various policy considerations. Two considerations—a party\u27s right to a jury trial and the use of collateral estoppel—have seemingly clashed in two federal courts of appeals decisions. This Note discusses the holding in Shore v. Parklane Hosiery Co. and the reasons the second circuit felt Rachal v. Hill was wrongly decided. Finally, the effect of these two decisions on various policy considerations of both procedure and the security laws is examined. I. Introduction II. The Facts III. The Decision of the Court of Appeals … A. Rachal v. Hill … B. The Policy Grounds … C. The Historical Grounds IV. Analysis V. Conclusio

X-ray Spectral Signatures of the Photon Bubble Model for Ultraluminous X-ray Sources

The nature of ultraluminous X-ray sources in nearby galaxies is one of the major open questions in modern X-ray astrophysics. One possible explanation for these objects is an inhomogeneous, radiation dominated accretion disk around a $\sim 10 M_{\odot}$ black hole -- the so-called ``photon bubble'' model. While previous studies of this model have focused primarily on its radiation-hydrodynamics aspects, in this paper, we provide an analysis of its X-ray spectral (continuum and possible edge and line) characteristics. Compton reflection between high and low density regions in the disk may provide the key to distinguishing this model from others, such as accretion onto an intermediate mass black hole. We couple a Monte Carlo/Fokker-Planck radiation transport code with the XSTAR code for reflection to simulate the photon spectra produced in a photon bubble model for ULXs. We find that reflection components tend to be very weak and in most cases not observable, and make predictions for the shape of the high-energy Comptonizing spectra. In many cases the Comptonization dominates the spectra even down to $\sim$ a few keV. In one simulation, a \sim 9 \kev feature was found, which may be considered a signature of photon bubbles in ULXs; furthermore, we make predictions of high energy power-laws which may be observed by future instruments.Comment: Accepted for publication in the Astrophysical Journa

Network synchronization of groups

In this paper we study synchronized motions in complex networks in which there are distinct groups of nodes where the dynamical systems on each node within a group are the same but are different for nodes in different groups. Both continuous time and discrete time systems are considered. We initially focus on the case where two groups are present and the network has bipartite topology (i.e., links exist between nodes in different groups but not between nodes in the same group). We also show that group synchronous motions are compatible with more general network topologies, where there are also connections within the groups

Cognitive impact of neuronal antibodies: encephalitis and beyond

Abstract: Cognitive dysfunction is a common feature of autoimmune encephalitis. Pathogenic neuronal surface antibodies are thought to mediate distinct profiles of cognitive impairment in both the acute and chronic phases of encephalitis. In this review, we describe the cognitive impairment associated with each antibody-mediated syndrome and, using evidence from imaging and animal studies, examine how the nature of the impairment relates to the underlying neuroimmunological and receptor-based mechanisms. Neuronal surface antibodies, particularly serum NMDA receptor antibodies, are also found outside of encephalitis although the clinical significance of this has yet to be fully determined. We discuss evidence highlighting their prevalence, and association with cognitive outcomes, in a number of common disorders including cancer and schizophrenia. We consider mechanisms, including blood-brain barrier dysfunction, which could determine the impact of these antibodies outside encephalitis and account for much of the clinical heterogeneity observed

A negative effect of a pathogen on its vector? A plant pathogen increases the vulnerability of its vector to attack by natural enemies

Plant pathogens that are dependent on arthropod vectors for transmission from host to host may enhance their own success by promoting vector survival and/or performance. The effect of pathogens on vectors may be direct or indirect, with indirect effects mediated by increases in host quality or reductions in the vulnerability of vectors to natural enemies. We investigated whether the bird cherry-oat aphid Rhopalosiphum padi, a vector of cereal yellow dwarf virus (CYDV) in wheat, experiences a reduction in rates of attack by the parasitoid wasp Aphidius colemani when actively harboring the plant pathogen. We manipulated the vector status of aphids (virus carrying or virus free) and evaluated the impact on the rate of attack by wasps. We found that vector status did not influence the survival or fecundity of aphids in the absence of parasitoids. However, virus-carrying aphids experienced higher rates of parasitism and greater overall population suppression by parasitoid wasps than virus-free aphids. Moreover, virus-carrying aphids were accepted as hosts by wasps more often than virus-free aphids, with a greater number of wasps stinging virus-carrying aphids following assessment by antennal palpations than virus-free aphids. Therefore, counter to the prevailing idea that persistent vector-borne pathogens enhance the performance of their vectors, we found that infectious aphids actively carrying a plant pathogen experience greater vulnerability to natural enemies. Our results suggest that parasitoids may contribute to the successful biological control of CYDV by disproportionately impacting virus-carrying vectors, and thus reducing the proportion of vectors in the population that are infectious

A negative effect of a pathogen on its vector? A plant pathogen increases the vulnerability of its vector to attack by natural enemies

Plant pathogens that are dependent on arthropod vectors for transmission from host to host may enhance their own success by promoting vector survival and/or performance. The effect of pathogens on vectors may be direct or indirect, with indirect effects mediated by increases in host quality or reductions in the vulnerability of vectors to natural enemies. We investigated whether the bird cherry-oat aphid Rhopalosiphum padi, a vector of cereal yellow dwarf virus (CYDV) in wheat, experiences a reduction in rates of attack by the parasitoid wasp Aphidius colemani when actively harboring the plant pathogen. We manipulated the vector status of aphids (virus carrying or virus free) and evaluated the impact on the rate of attack by wasps. We found that vector status did not influence the survival or fecundity of aphids in the absence of parasitoids. However, virus-carrying aphids experienced higher rates of parasitism and greater overall population suppression by parasitoid wasps than virus-free aphids. Moreover, virus-carrying aphids were accepted as hosts by wasps more often than virus-free aphids, with a greater number of wasps stinging virus-carrying aphids following assessment by antennal palpations than virus-free aphids. Therefore, counter to the prevailing idea that persistent vector-borne pathogens enhance the performance of their vectors, we found that infectious aphids actively carrying a plant pathogen experience greater vulnerability to natural enemies. Our results suggest that parasitoids may contribute to the successful biological control of CYDV by disproportionately impacting virus-carrying vectors, and thus reducing the proportion of vectors in the population that are infectious