A Case Against School Choice: Carson Ex Rel. O.C. v. Makin and the Future of Maine\u27s Nonsectarian Requirement

School choice advocates, such as the nonprofit libertarian law firm, The Institute for Justice, have spent decades arguing that states violate the Free Exercise Clause when they exclude private religious schools from public programs that otherwise provide public dollars to non-religious private schools. Recently, in Espinoza v. Montana Department of Revenue, the Supreme Court effectively agreed with that sentiment. After this victory, the Institute for Justice returned to the state of Maine to represent three sets of parents in a renewed effort to defeat Maine’s nonsectarian requirement in federal court. Maine’s nonsectarian requirement provides that private religious schools may not participate in Maine’s town tuitioning program, which allows students in towns that do not have public schools to receive state funding to attend a private or public school of their choice. This Note analyzes that case: Carson ex rel. O.C. v. Makin. In Carson, the First Circuit affirmed the trial court’s decision that Maine’s nonsectarian requirement does not violate the Free Exercise Clause. I posit that the reasoning the First Circuit deployed in Carson may not be durable and that if the Supreme Court were to grant the plaintiff-appellants’ petition for certiorari, the Court would likely invalidate Maine’s nonsectarian requirement. I then analyze the effect the elimination of the nonsectarian requirement would have on Maine’s public schools and how school choice opponents may wish to move forward. More specifically, I suggest that Maine and the rest of the nation should consider investing in its public schools before outsourcing public education to private entities and interest groups

The Dynamics of Plant Cell-Wall Polysaccharide Decomposition in Leaf-Cutting Ant Fungus Gardens

The degradation of live plant biomass in fungus gardens of leaf-cutting ants is poorly characterised but fundamental for understanding the mutual advantages and efficiency of this obligate nutritional symbiosis. Controversies about the extent to which the garden-symbiont Leucocoprinus gongylophorus degrades cellulose have hampered our understanding of the selection forces that induced large scale herbivory and of the ensuing ecological footprint of these ants. Here we use a recently established technique, based on polysaccharide microarrays probed with antibodies and carbohydrate binding modules, to map the occurrence of cell wall polymers in consecutive sections of the fungus garden of the leaf-cutting ant Acromyrmex echinatior. We show that pectin, xyloglucan and some xylan epitopes are degraded, whereas more highly substituted xylan and cellulose epitopes remain as residuals in the waste material that the ants remove from their fungus garden. These results demonstrate that biomass entering leaf-cutting ant fungus gardens is only partially utilized and explain why disproportionally large amounts of plant material are needed to sustain colony growth. They also explain why substantial communities of microbial and invertebrate symbionts have evolved associations with the dump material from leaf-cutting ant nests, to exploit decomposition niches that the ant garden-fungus does not utilize. Our approach thus provides detailed insight into the nutritional benefits and shortcomings associated with fungus-farming in ants

Volatile and Organic Compositions of Sedimentary Rocks in Yellowknife Bay, Gale crater, Mars

H₂O, CO₂, SO₂, O₂, H₂, H₂S, HCl, chlorinated hydrocarbons, NO and other trace gases were evolved during pyrolysis of two mudstone samples acquired by the Curiosity rover at Yellowknife Bay within Gale crater, Mars. H₂O/OH-bearing phases included 2:1 phyllosilicate(s), bassanite, akaganeite, and amorphous materials. Thermal decomposition of carbonates and combustion of organic materials are candidate sources for the CO₂. Concurrent evolution of O₂ and chlorinated hydrocarbons suggest the presence of oxychlorine phase(s). Sulfides are likely sources for S-bearing species. Higher abundances of chlorinated hydrocarbons in the mudstone compared with Rocknest windblown materials previously analyzed by Curiosity suggest that indigenous martian or meteoritic organic C sources may be preserved in the mudstone; however, the C source for the chlorinated hydrocarbons is not definitively of martian origin

X-ray Diffraction Results from Mars Science Laboratory: Mineralogy of Rocknest at Gale Crater

The Mars Science Laboratory rover Curiosity scooped samples of soil from the Rocknest aeolian bedform in Gale crater. Analysis of the soil with the Chemistry and Mineralogy (CheMin) x-ray diffraction (XRD) instrument revealed plagioclase (~An57), forsteritic olivine (~Fo62), augite, and pigeonite, with minor K-feldspar, magnetite, quartz, anhydrite, hematite, and ilmenite. The minor phases are present at, or near, detection limits. The soil also contains 27 ± 14 weight percent x-ray amorphous material, likely containing multiple Fe^(3+)- and volatile-bearing phases, including possibly a substance resembling hisingerite. The crystalline component is similar to the normative mineralogy of certain basaltic rocks from Gusev crater on Mars and of martian basaltic meteorites. The amorphous component is similar to that found on Earth in places such as soils on the Mauna Kea volcano, Hawaii

Elemental Geochemistry of Sedimentary Rocks at Yellowknife Bay, Gale Crater, Mars

Sedimentary rocks examined by the Curiosity rover at Yellowknife Bay, Mars, were derived from sources that evolved from approximately average Martian crustal composition to one influenced by alkaline basalts. No evidence of chemical weathering is preserved indicating arid, possibly cold, paleoclimates and rapid erosion/deposition. Absence of predicted geochemical variations indicates that magnetite and phyllosilicates formed by diagenesis under low temperature, circum-neutral pH, rock-dominated aqueous conditions. High spatial resolution analyses of diagenetic features, including concretions, raised ridges and fractures, indicate they are composed of iron- and halogen-rich components, magnesium-iron-chlorine-rich components and hydrated calcium-sulfates, respectively. Composition of a cross-cutting dike-like feature is consistent with sedimentary intrusion. Geochemistry of these sedimentary rocks provides further evidence for diverse depositional and diagenetic sedimentary environments during the early history of Mars

Mineralogy of a Mudstone at Yellowknife Bay, Gale Crater, Mars

Sedimentary rocks at Yellowknife Bay (Gale Crater) on Mars include mudstone sampled by the Curiosity rover. The samples, John Klein and Cumberland, contain detrital basaltic minerals, Ca-sulfates, Fe oxide/hydroxides, Fe-sulfides, amorphous material, and trioctahedral smectites. The John Klein smectite has basal spacing of ~10 Å indicating little interlayer hydration. The Cumberland smectite has basal spacing at ~13.2 Å as well as ~10 Å. The ~13.2 Å spacing suggests a partially chloritized interlayer or interlayer Mg or Ca facilitating H_2O retention. Basaltic minerals in the mudstone are similar to those in nearby eolian deposits. However, the mudstone has far less Fe-forsterite, possibly lost with formation of smectite plus magnetite. Late Noachian/Early Hesperian or younger age indicates that clay mineral formation on Mars extended beyond Noachian time

The Petrochemistry of Jake_M: A Martian Mugearite

“Jake_M,” the first rock analyzed by the Alpha Particle X-ray Spectrometer instrument on the Curiosity rover, differs substantially in chemical composition from other known martian igneous rocks: It is alkaline (>15% normative nepheline) and relatively fractionated. Jake_M is compositionally similar to terrestrial mugearites, a rock type typically found at ocean islands and continental rifts. By analogy with these comparable terrestrial rocks, Jake_M could have been produced by extensive fractional crystallization of a primary alkaline or transitional magma at elevated pressure, with or without elevated water contents. The discovery of Jake_M suggests that alkaline magmas may be more abundant on Mars than on Earth and that Curiosity could encounter even more fractionated alkaline rocks (for example, phonolites and trachytes)

A Habitable Fluvio-Lacustrine Environment at Yellowknife Bay, Gale Crater, Mars

The Curiosity rover discovered fine-grained sedimentary rocks, inferred to represent an ancient lake, preserve evidence of an environment that would have been suited to support a Martian biosphere founded on chemolithoautotrophy. This aqueous environment was characterized by neutral pH, low salinity, and variable redox states of both iron and sulfur species. C, H, O, S, N, and P were measured directly as key biogenic elements, and by inference N and P are assumed to have been available. The environment likely had a minimum duration of hundreds to tens of thousands of years. These results highlight the biological viability of fluvial-lacustrine environments in the post-Noachian history of Mars

A Case Against School Choice: Carson Ex Rel. O.C. v. Makin and the Future of Maine\u27s Nonsectarian Requirement

School choice advocates, such as the nonprofit libertarian law firm, The Institute for Justice, have spent decades arguing that states violate the Free Exercise Clause when they exclude private religious schools from public programs that otherwise provide public dollars to non-religious private schools. Recently, in Espinoza v. Montana Department of Revenue, the Supreme Court effectively agreed with that sentiment. After this victory, the Institute for Justice returned to the state of Maine to represent three sets of parents in a renewed effort to defeat Maine’s nonsectarian requirement in federal court. Maine’s nonsectarian requirement provides that private religious schools may not participate in Maine’s town tuitioning program, which allows students in towns that do not have public schools to receive state funding to attend a private or public school of their choice. This Note analyzes that case: Carson ex rel. O.C. v. Makin. In Carson, the First Circuit affirmed the trial court’s decision that Maine’s nonsectarian requirement does not violate the Free Exercise Clause. I posit that the reasoning the First Circuit deployed in Carson may not be durable and that if the Supreme Court were to grant the plaintiff-appellants’ petition for certiorari, the Court would likely invalidate Maine’s nonsectarian requirement. I then analyze the effect the elimination of the nonsectarian requirement would have on Maine’s public schools and how school choice opponents may wish to move forward. More specifically, I suggest that Maine and the rest of the nation should consider investing in its public schools before outsourcing public education to private entities and interest groups