“Inextricably Intertwined” Explicable at Last?: Rooker-Feldman Analysis After the Supreme Court’s Exxon Mobil Decision

The Supreme Court\u27s March 2005 decision in \u27Exxon Mobil Corp. v. Saudi Basic Industries Corp.\u27 substantially limited the Rooker-Feldman doctrine, under which lower federal courts largely lack jurisdiction to engage in what amounts to de facto review of state-court decisions. Exxon Mobil\u27s holding is quite narrow--entry of a final state-court judgment does not destroy federal-court jurisdiction already acquired over parallel litigation. But the Court\u27s articulation of when Rooker-Feldman applies, and its approach in deciding the case, have significant implications for several aspects of Rooker-Feldman jurisprudence. Chief among our claims is that although the Court did not expressly repudiate or limit the applicability of the inextricably intertwined formulation from prior cases, which had been a primary test for many lower courts, that concept appears to have been relegated to some secondary role and no longer to be a general or threshold test. The Exxon Mobil Court properly did not elaborate on just what the concept\u27s role should be, but we offer a suggestion based on an earlier Ninth Circuit decision. We also discuss the apparent impact of Exxon Mobil on other aspects of Rooker-Feldman doctrine as the lower federal courts had developed it, including relation to preclusion doctrines, the significance of whether the federal plaintiff was plaintiff or defendant in state court, and the doctrine\u27s applicability a) to those not parties to prior state-court litigation, b) to interlocutory state-court rulings and decisions of lower state courts, and c) when federal-court plaintiffs did not raise their federal claims in state court. A February 2006 per curiam decision applying Exxon Mobil, Lance v. Dennis, reinforces the Court\u27s position on some of these issues

\u3ci\u3eIxodes Dentatus\u3c/i\u3e (Acari: Ixodidae) in Michigan: First State Records and Occurrence on a Human

An Ixodes dentatus adult female was taken from a cottontail rabbit in Kalamazoo County, and a nymph from a child in Berrien County, in 1992 in Michigan. These findings represent the first records of I.dentatus in the state, and document an unusual parasitization of a human being by this species of tick

Urban Resurgence and the Consumer City

Cities make it easier for humans to interact, and one of the main advantages of dense, urban areas is that they facilitate social interactions. This paper provides evidence suggesting that the resurgence of big cities in the 1990s is due, in part, to the increased demand for these interactions and due to the reduction in big city crime, which had made it difficult for urban residents to enjoy these social amenities. However, while density is correlated with consumer amenities, we show that it is not correlated with social capital and that there is no evidence that sprawl has hurt civic engagement.

BARLEY PRODUCTION COSTS: A CROSS-BORDER COMPARISON

Barley production costs are compared for five states and three Canadian provinces. A stochastic simulation, incorporating yield and exchange-rate risk, is used to characterize regional cost advantages in terms of probabilities.barley, production costs, yield risk, simulation analysis, Agricultural Finance, Production Economics,

Improved (e,e') response functions at intermediate momentum transfers: the 3He case

A possibility of extending the applicability range of non-relativistic calculations of electronuclear response functions in the quasielasic peak region is studied. We show that adopting a particular model for determining the kinematical inputs of the non-relativistic calculations can extend this range considerably, almost eliminating the reference frame dependence of the results. We also show that there exists one reference frame, where essentially the same result can be obtained with no need of adopting the particular kinematical model. The calculation is carried out with the Argonne V18 potential and the Urbana IX three-nucleon interaction. A comparison of these improved calculations with experimental data shows a very good agreement for the quasielastic peak positions at $q=500,$ 600, 700 MeV/c and for the peak heights at the two lower $q$--values, while for the peak height at $q=700$ MeV/c one finds differences of about 20%.Comment: 10 pages, 4 figure

SHOPPING FOR MEAT: EMPIRICAL DEMAND ESTIMATION FOR NATURAL BEEF ACROSS STORE CHOICES

Conventional supermarkets concentrate on capturing the largest pool of consumers to generate profits from the industry's low margins. Selling to the largest pool of customers means that marketing, promotion, stocking and service decisions are based on the tastes and preferences of an average consumer. Innovators in the grocery industry, recognizing a shift in consumer tastes and preferences, are changing the industry to attract smaller segments of consumers. The theory presented here demonstrates a method to understand the value of product diversification and a model of the gains from providing products that may not have broad appeal to the average customer base. The increase in retail returns through this approach of developing in-store niches lies not in increased single-item purchases of any one consumer, but through the increased number of items purchased (a larger bundle) by an individual on a single shopping trip.Demand and Price Analysis, Food Consumption/Nutrition/Food Safety,

The Efficiency of Private Universities As Measured By Graduation Rates

It is well known that human capital is enhanced by graduation from a college or university. How efficient are such institutions in conveying this mark of human capital? Efficiency and productivity in private higher education is measured by using undergraduate graduation rates as the output, and demographic variables, the quality of the students, and the annual expenditures (adjusted for academic mission) as inputs. Tests of several models using OLS and stochastic frontier analysis confirm that private schools can increase their graduation rates by increasing focused expenditures and through more selective admissions. Estimated elasticities are reported and point toward increasing expenditures as the most responsive method. Estimate graduation efficiencies of 93.0, 91.5, and near 100% are also reported for four, five and six year graduation rates respectively. A rank correlation with the U S News and World Report 2008 rankings is consistent with our measure of relative efficiencies

Welfare Reform in Agricultural California

When welfare reforms were enacted in 1996, a higher than average percentage of residents in the agricultural heartland of California, the San Joaquin Valley, received cash assistance. Average annual unemployment rates during the 1990s ranged from 12% to 20%, and 15% to 20% of residents in major farming counties received cash benefits. This analysis develops and estimates a two-equation cross-sectionally correlated and timewise autoregressive model to test the hypothesis that in agricultural areas, seasonal work, low earnings, and high unemployment, as well as few entry-level jobs that offer wages and benefits equivalent to welfare benefits, promote welfare use and limit the potential of local labor markets to absorb ex-welfare recipients.cross-sectionally correlated and timewise autoregressive model, farm workers, immigration, welfare reform, Public Economics,