Beyond Marbury : Jurisdictional Self-Dealing In Seminole Tribe

In Seminole Tribe v. Florida, the Supreme Court held that the Constitution\u27s Article III embodies a principle of state sovereign immunity which so constrains the federal judicial power that it prohibits Congress from granting federal courts subject matter jurisdiction over private lawsuits to enforce Article I legislation against states. At the same time, however, and again in Idaho v. Coeur d\u27Alene Tribe, the Court reaffirmed its own Ex parte Young doctrine, under which the Court itself unilaterally granted federal courts subject matter jurisdiction over private lawsuits to coerce states to comply with federal law despite state sovereign immunity. Neither in Seminole Tribe nor in Coeur d\u27Alene Tribe did the Court explain how Article HI could so limit Congress\u27s power to grant subject matter jurisdiction in such lawsuits, while leaving intact the Court\u27s own power to do so under Ex parte Young. Arguing that Ex parte Young and the Young doctrine rest on no affirmative principle of law, Professor Fitzgerald suggests that Young\u27s survival of Seminole Tribe reflects the Court\u27s claim for itself of a freestanding judicial power to regulate access to federal courts for private lawsuits challenging state interests--a judicial power that now outstrips both ordinary judicial review and also Congress\u27s constitutional authority over the federal courts

Suspecting the States: Supreme Court Review of State-Court State-Law Judgments

At the Supreme Court these days, it is unfashionable to second-guess states\u27 fealty to federal law without real proof that they are ignoring it. As the Court declared in Alden v. Maine: We are unwilling to assume the States will refuse to honor the Constitution or obey the binding laws of the United States. The good faith of the States thus provides an important assurance that \u27this Constitution, and the Laws of the United States which shall be made in Pursuance thereof ... shall be the supreme Law of the Land.\u27 Accordingly, without proof that a state has systematic[ally] shirked its supremacy clause duty to honor Article I legislation, the Court appears unwilling to enforce compliance in a particular case. Likewise, the Court makes Congress prove a broad pattern of federal-law transgressions by many states before it can hold any state accountable to individuals for violating their constitutional rights. Indeed, a handful of even egregious anecdotes simply cannot overcome the Court\u27s presumption that all states can be trusted to meet their federal-law duties

Psoriasis, psoriatic arthritis, and rheumatoid arthritis: Is all inflammation the same?

AbstractObjectivesTo review the pathophysiology, co-morbidities, and therapeutic options for psoriasis, psoriatic arthritis and rheumatoid arthritis in order to further understand the similarities and differences in treatment paradigms in the management of each disease. New targets for individualized therapeutic decisions are also identified with the aim of improving therapeutic outcome and reducing toxicity.Search strategyUsing the PubMed database, we searched literature published from 2000 to 2015 using combinations of the key words “psoriasis,” “psoriatic arthritis,” “rheumatoid arthritis,” “pathogenesis,” “immunomodulation,” and “treatment.”Inclusion and exclusion criteriaThis was a non-systematic review and there were no formal inclusion and exclusion criteria.Data extractionAbstracts identified in the search were screened for relevance and articles considered appropriate evaluated further. References within these selected articles were also screened. Information was extracted from 198 articles for inclusion in this report.Data synthesisThere was no formal data synthesis. Articles were reviewed and summarized according to disease area (psoriasis, psoriatic arthritis, and rheumatoid arthritis).Headline resultsThe pathophysiology of psoriasis, psoriatic arthritis, and rheumatoid arthritis involves chronic inflammation mediated by pro-inflammatory cytokines. Dysfunction in integrated signaling pathways affecting different constituents of the immune system result in varying clinical features in the three diseases. Co-morbidities, including cardiovascular disease, malignancies, and non-alcoholic fatty liver disease are increased. Increased understanding of the immunopathogenesis allowed development of targeted treatments; however, despite a variety of potentially predictive genetic, protein and cellular biomarkers, there is still significant unmet need in these three inflammatory disorders

A structured approach to VO reconfigurations through Policies

One of the strength of Virtual Organisations is their ability to dynamically and rapidly adapt in response to changing environmental conditions. Dynamic adaptability has been studied in other system areas as well and system management through policies has crystallized itself as a very prominent solution in system and network administration. However, these areas are often concerned with very low-level technical aspects. Previous work on the APPEL policy language has been aimed at dynamically adapting system behaviour to satisfy end-user demands and - as part of STPOWLA - APPEL was used to adapt workflow instances at runtime. In this paper we explore how the ideas of APPEL and STPOWLA can be extended from workflows to the wider scope of Virtual Organisations. We will use a Travel Booking VO as example.Comment: In Proceedings FAVO 2011, arXiv:1204.579

Autism Spectrum Disorder Among US Children (2002–2010): Socioeconomic, Racial, and Ethnic Disparities

Objectives. To describe the association between indicators of socioeconomic status (SES) and the prevalence of autism spectrum disorder (ASD) in the United States during the period 2002 to 2010, when overall ASD prevalence among children more than doubled, and to determine whether SES disparities account for ongoing racial and ethnic disparities in ASD prevalence

Outcomes of the 2019 GRAPPA workshop on continuous composite indices for the assessment of psoriatic arthritis and membership-recommended next steps

OBJECTIVE: Improving the assessment of psoriatic arthritis (PsA) is a key purpose of the Group for Research and Assessment of Psoriasis and PsA (GRAPPA). Herein, we report the proceedings of the GRAPPA composites workshop at the 2019 GRAPPA annual meeting and the membership\u27s recommended next steps. METHODS: A review of continuous composite measures was conducted in an introductory workshop, followed by 10 breakout group sessions and a final plenary session for feedback and voting. RESULTS: Participants included 154 members: 87 rheumatologists, 18 dermatologists, 2 rheumatologist/dermatologists, 12 patient research partners, 14 academics, 1 methodologist, and 20 industry members. Of voting members, 88.8% agreed a need exists for a continuous composite measure for routine practice, but only 62% were currently using a composite measure. Of these, 27% were using the 28-joint count Disease Activity Score (DAS), which is not a PsA-specific measure; 20% were using a PsA-specific measure such as PsA DAS (PASDAS), Composite Psoriatic Disease Activity Index (CPDAI), or Disease Activity Index for PsA (DAPSA). Members agreed that the existing measures were not feasible in their current forms (CPDAI 83%, PASDAS 82%, and DAPSA 47%) and that modification should be tested. The majority (76%) agreed that disease effect should be measured separately from disease activity. CONCLUSION: The GRAPPA membership supports the need for a continuous composite measure of disease activity for use in routine clinical care, the separate measurement of disease effect and activity, and the testing of modifications to candidate instruments rather than the development of new measures

Interventions to Modify Psychological Well-Being: Progress, Promises, and an Agenda for Future Research

Psychological well-being, characterized by feelings, cognitions, and strategies that are associated with positive functioning (including hedonic and eudaimonic well-being), has been linked with better physical health and greater longevity. Importantly, psychological well-being can be strengthened with interventions, providing a strategy for improving population health. But are the effects of well-being interventions meaningful, durable, and scalable enough to improve health at a population-level? To assess this possibility, a cross-disciplinary group of scholars convened to review current knowledge and develop a research agenda. Here we summarize and build on the key insights from this convening, which were: (1) existing interventions should continue to be adapted to achieve a large-enough effect to result in downstream improvements in psychological functioning and health, (2) research should determine the durability of interventions needed to drive population-level and lasting changes, (3) a shift from individual-level care and treatment to a public-health model of population-level prevention is needed and will require new infrastructure that can deliver interventions at scale, (4) interventions should be accessible and effective in racially, ethnically, and geographically diverse samples. A discussion examining the key future research questions follows