The Constitutionality of Decolonization by Associated Statehood: Puerto Rico\u27s Legal Status Reconsidered

International and constitutional law arguably collide in the legal arrangement between the United States and Puerto Rico. As a matter of international law, it is unclear that this arrangement conforms to customary international and treaty obligations. As a matter of national law, it is unclear that the Constitution permits an arrangement between Puerto Rico and the United States—short of separation (independence as a State) or integration (admission to the Union as a state)—that could conform to these international obligations. In particular, the Appointments Clause and the Constitution\u27s voting provisions may well be in tension with contemporary international law relative to Puerto Rico. In this Article, we seek, partly through an internal dialogue, to clarify several unacknowledged or underappreciated legal tensions in the U.S.-Puerto Rico relationship and to explore ways to resolve them. One of us adopts a plain-meaning, originalist view of the Constitution, which underscores the arguable constitutional defects in the current U.S.-Puerto Rico relationship. The other does not embrace originalism and therefore would not exclude resolution of the tensions between international and constitutional law by means of constitutional interpretation. We agree, however, that those tensions can no longer be neglected in a State committed to the rule of law and that several of the most troubling can be resolved— with a modest amount of political will and creativity— in a manner that effectively elides the oft-intractable debates in modern constitutional theory: substantive, even if not formal, international legal compliance can be uncontroversially established. Above all, we seek to reframe and facilitate a long-overdue discussion about how to reconcile U.S. international obligations toward Puerto Rico with the Constitution. I always thought that, when we should acquire Canada and Louisiana it would be proper to govern them as provinces, and allow them no voice in our councils. In wording the third section of the fourth article [of the Constitution], I went as far as circumstances would permit to establish the exclusion. —Gouverneur Morri

The Oyster River Culvert Analysis Project

Studies have already detected intensification of precipitation events consistent with climate change projections. Communities may have a window of opportunity to prepare, but information sufficiently quantified and localized to support adaptation programs is sparse: published literature is typically characterized by general resilience building or regional vulnerability studies. The Fourth Assessment Report of the IPCC observed that adaptation can no longer be postponed pending the effective elimination of uncertainty. Methods must be developed that manage residual uncertainty, providing community leaders with decision-support information sufficient for implementing infrastructure adaptation programs. This study developed a local-scale and actionable protocol for maintaining historical risk levels for communities facing significant impacts from climate change and population growth. For a coastal watershed, the study assessed the capacity of the present stormwater infrastructure capacity for conveying expected peak flow resulting from climate change and population growth. The project transferred coupled-climate model projections to the culvert system, in a form understandable to planners, resource managers and decision-makers; applied standard civil engineering methods to reverse-engineer culverts to determine existing and required capacities; modeled the potential for LID methods to manage peak flow in lieu of, or combination with, drainage system upsizing; and estimated replacement costs using local and national construction cost data. The mid-21st century, most likely 25-year, 24-hour precipitation is estimated to be 35% greater than the TP-40 precipitation for the SRES A1b trajectory, and 64% greater than the TP-40 value for the SRES A1fi trajectory. 5% of culverts are already undersized for the TP-40 event to which they should have been designed. Under the most likely A1b trajectory, an additional 12% of culverts likely will be undersized, while under the most likely A1fi scenario, an additional 19% likely will be undersized. These conditions place people and property at greater risk than that historically acceptable from the TP-4025-year design storm. This risk level may be maintained by a long-term upgrade program, utilizing existing strategies to manage uncertainty and costs. At the upper-95% confidence limit for the A1fi 25-year event, 65% of culverts are adequately sized, and building the remaining 35%, and planned, culverts to thrice the cross-sectional area specified from TP-40 should provide adequate capacity through this event. Realizable LID methods can mitigate significant impacts from climate change and population growth, however effectiveness is limited for the more pessimistic climate change projections. Results indicate that uncertainty in coupled-climate model projections is not an impediment to adaptation. This study makes a significant contribution toward the generation of reliable and specific estimates of impacts from climate change, in support of programs to adapt civil infrastructures. This study promotes a solution to today\u27s arguably most significant challenge in civil infrastructure adaptation: translating the extensive corpus of adaptation theory and regional-scale impacts analyses into localscale action

Pancreatic cysts suspected to be branch duct intraductal papillary mucinous neoplasm without concerning features have low risk for development of pancreatic cancer.

BackgroundThe risk of developing pancreatic cancer is uncertain in patients with clinically suspected branch duct intraductal papillary mucinous neoplasm (BD-IPMN) based on the "high-risk stigmata" or "worrisome features" criteria proposed in the 2012 international consensus guidelines ("Fukuoka criteria").MethodsRetrospective case series involving patients referred for endoscopic ultrasound (EUS) of indeterminate pancreatic cysts with clinical and EUS features consistent with BD-IPMN. Rates of pancreatic cancer occurring at any location in the pancreas were compared between groups of patients with one or more Fukuoka criteria ("Highest-Risk Group", HRG) and those without these criteria ("Lowest-Risk Group", LRG).ResultsAfter exclusions, 661 patients comprised the final cohort (250 HRG and 411 LRG patients), 62% female with an average age of 67 years and 4 years of follow up. Pancreatic cancer, primarily adenocarcinoma, occurred in 60 patients (59 HRG, 1 LRG). Prevalent cancers diagnosed during EUS, immediate surgery, or first year of follow up were found in 48/661 (7.3%) of cohort and exclusively in HRG (33/77, 42.3%). Using Kaplan-Meier method, the cumulative incidence of cancer at 7 years was 28% in HRG and 1.2% in LRG patients (P<0.001).ConclusionsThis study supports using Fukuoka criteria to stratify the immediate and long-term risks of pancreatic cancer in presumptive BD-IPMN. The risk of pancreatic cancer was highest during the first year and occurred exclusively in those with "high-risk stigmata" or "worrisome features" criteria. After the first year all BD-IPMN continued to have a low but persistent cancer risk

The Effect of Polysialic Acid Expression on Glioma Cell Nano-mechanics

YesPolysialic acid (PolySia) is an important carbohydrate bio-polymer that is commonly over-expressed on tumours of neuroendocrine origin and plays a key role in tumour progression. PolySia exclusively decorates the neural cell adhesion molecule (NCAM) on tumour cell membranes, modulating cell-cell interactions, motility and invasion. In this preliminary study, we examine the nano-mechanical properties of isogenic C6 rat glioma cells - transfected cells engineered to express the enzyme polysialyltransferase ST8SiaII, which synthesises polySia (C6-STX cells) and wild type cells (C6-WT). We demonstrate that polySia expression leads to reduced elastic and adhesive properties but also more visco-elastic compared to non-expressing wild type cells. Whilst differences in cell elasticity between healthy and cancer cells is regularly assigned to changes in the cytoskeleton, we show that in this model system the change in properties at the nano-level is due to the polySia on the transfected cell membrane surface

Physical and mental health comorbidity is common in people with multiple sclerosis: nationally representative cross-sectional population database analysis

<b>Background</b> Comorbidity in Multiple Sclerosis (MS) is associated with worse health and higher mortality. This study aims to describe clinician recorded comorbidities in people with MS. <p></p> <b>Methods</b> 39 comorbidities in 3826 people with MS aged ≥25 years were compared against 1,268,859 controls. Results were analysed by age, gender, and socioeconomic status, with unadjusted and adjusted Odds Ratios (ORs) calculated using logistic regression. <p></p> <b>Results</b> People with MS were more likely to have one (OR 2.44; 95% CI 2.26-2.64), two (OR 1.49; 95% CI 1.38-1.62), three (OR 1.86; 95% CI 1.69-2.04), four or more (OR 1.61; 95% CI 1.47-1.77) non-MS chronic conditions than controls, and greater mental health comorbidity (OR 2.94; 95% CI 2.75-3.14), which increased as the number of physical comorbidities rose. Cardiovascular conditions, including atrial fibrillation (OR 0.49; 95% CI 0.36-0.67), chronic kidney disease (OR 0.51; 95% CI 0.40-0.65), heart failure (OR 0.62; 95% CI 0.45-0.85), coronary heart disease (OR 0.64; 95% CI 0.52-0.71), and hypertension (OR 0.65; 95% CI 0.59-0.72) were significantly less common in people with MS. <p></p> <b>Conclusion</b> People with MS have excess multiple chronic conditions, with associated increased mental health comorbidity. The low recorded cardiovascular comorbidity warrants further investigation

In the Shadow of the Transiting Disk: Imaging epsilon Aurigae in Eclipse

Eclipses of the single-line spectroscopic binary star, epsilon Aurigae, provide an opportunity to study the poorly-defined companion. We used the MIRC beam combiner on the CHARA array to create interferometric images during eclipse ingress. Our results demonstrate that the eclipsing body is a dark disk that is opaque and tilted, and therefore exclude alternative models for the system. These data constrain the geometry and masses of the components, providing evidence that the F-star is not a massive supergiant star.Comment: As submitted to Nature. Published in Nature April 8, 2010