Expanding the Scope of the Federal Arbitration Act: An Examination of the Seventh Circuit\u27s Opinion in Green v. U.S. Cash Advance, Illinois, LLC

The Roberts Court\u27s expansive interpretation of the Federal Arbitration Act (FAA) has ushered in a new era of pro-arbitration jurisprudence, allowing lower courts to categorically enforce arbitration agreements. Underlying this zealous application is Section 2 of the FAA, which states that arbitration agreements are valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of a contract. In Green v. U.S. Cash Advance, Illinois, LLC, the Seventh Circuit enforced an arbitration agreement between a consumer and payday lender, despite the fact that the named arbitration forum had been unavailable since the inception of the agreement. In reaching their conclusion, the majority rejected the integral part test, used by the Third, Fifth and Eleventh Circuits, which bars the judicial appointment of a substitute arbitrator when the named arbitration forum was an integral part of the agreement. The dissent also rejected this test but passionately argued that the arbitration clause was unenforceable based on principles of contract law. This Comment chronicles the passage of the FAA and the Supreme Court\u27s recent arbitration decisions. It discusses the Green case at the district court and appellate levels, and it addresses other circuit court decisions in similar fact situations. This Comment argues that the Seventh Circuit majority made the wrong decision in Green. It also argues that the majority and dissent wrongly rejected the integral part test implemented by other circuits when determining whether Section 5 of the FAA can be invoked

Surface EMG Evaluation of Sonographer Scanning Postures

Abstract Objectives This paper presents a technique for general quantitative evaluation of musculoskeletal impact through the evaluation of postural tests to assess two specific muscle groups. The two muscle groups chosen were the left upper trapezius, utilized while operating an ultrasound system's control panel, and the right suprascapular fossa, utilized while scanning. Surface electromyography (SEMG) was used to quantitatively measure muscular activity of these regions of the neck and shoulder. Methods Twenty-two sonographers subjects were evaluated using surface electromyography (SEMG) while performing standardized tasks typical of Diagnostic Medical Sonographers. SEMG was used to compare muscular activity in specific muscle(s) associated with postures employed to perform these tasks. Results This study shows large and statistically significant reductions in muscle activity by modifying scanning technique and workstation arrangement. The left upper trapezius muscle activity decreased 65% by changing from a 50˚ forward shoulder flexion (reach) to a neutral (0° reach) position. The right suprascapular fossa activity showed a reduction of 46% between a postural stance of 75° abduction and 30° abduction. There was an even more dramatic reduction of 78% by providing support under the forearm at the same 30° abduction. Consequently, the total reduction from the first position to the third position was demonstrated to be an 88% decrease in muscular activity. 1 Conclusion The results of this study illustrate the benefit of optimized scanning technique, workstation utilization and use of adjustable workstation equipment. The overall reduction of 88% between 75° abduction, and a supported 30° abduction, shows the improvement possible with proper scan technique, support devices and versatile workstation equipment such as the ultrasound system, ergonomic chair and exam table

The role of red and processed meat in colorectal cancer development : a perspective

Peer reviewe

Acute reduction of serum 8-iso-PGF2-alpha and advanced oxidation protein products in vivo by a polyphenol-rich beverage; a pilot clinical study with phytochemical and in vitro antioxidant characterization

<p>Abstract</p> <p>Background</p> <p>Measuring the effects of the acute intake of natural products on human biomarker concentrations, such as those related to oxidation and inflammation, can be an advantageous strategy for early clinical research on an ingredient or product.</p> <p>Methods</p> <p>31 total healthy subjects were randomized in a double-blinded, placebo-controlled, acute pilot study with post-hoc subgroup analysis on 20 of the subjects. The study examined the effects of a single dose of a polyphenol-rich beverage (PRB), commercially marketed as "SoZo^®", on serum anti-inflammatory and antioxidant markers. In addition, phytochemical analyses of PRB, and <it>in vitro </it>antioxidant capacity were also performed.</p> <p>Results</p> <p>At 1 hour post-intake, serum values for 8-iso-PGF2-alpha and advanced oxidation protein products decreased significantly by 40% and 39%, respectively. Additionally, there was a trend toward decreased C-reactive protein, and increased nitric oxide levels. Both placebo and PRB treatment resulted in statistically significant increases in hydroxyl radical antioxidant capacity (HORAC) compared to baseline; PRB showed a higher percent change (55-75% versus 23-74% in placebo group), but the two groups did not differ significantly from each other.</p> <p>Conclusions</p> <p>PRB produced statistically significant changes in several blood biomarkers related to antioxidant/anti-inflammatory effects. Future studies are justified to verify results and test for cumulative effects of repeated intakes of PRB. The study demonstrates the potential utility of acute biomarker measurements for evaluating antioxidant/anti-inflammatory effects of natural products.</p

The Role of HIV-Related Knowledge and Ethnicity in Determining HIV Risk Perception and Willingness to Undergo HIV Testing Among Rural Women in Burkina Faso

We conducted a random community based survey of 300 young (15–29 years) rural women in Nouna, Burkina Faso. Only one-third of women were aware that a person could have HIV without having symptoms and these women were significantly more likely to classify themselves to be at high risk for getting HIV. Furthermore, multiple partners, Bwaba ethnicity and having mentioned a health worker as a source of HIV information were significantly associated with perceived high personal risk. Perceived willingness to participate in VCT was high (69%). The dissemination of information on the asymptomatic nature of HIV infection could potentially be very important in forming risk perception, awareness, and their willingness to participate in HIV interventions.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/44011/1/10461_2005_Article_3905.pd