Electoral Due Process

Elections and their aftermath are matters left to the states by the U.S. Constitution. But the Supreme Court has made clear that the right to vote is federally protected, and fiercely so. When an election failure takes place and deprives citizens of their votes, challengers must resort to state law remedies. Many states have procedural requirements for election challenges that are stringent to the point of being prohibitive. This Note argues that the due process concerns raised by these burdensome state procedures are amplified by their voting rights context. Where a voter must take to the courts to vindicate her right to vote, she should not be further deprived by an unfair process. Federal courts hearing cases about unfair election-challenge procedures have been reluctant to interfere and are thus overly deferential to the states. This Note offers a new approach for “electoral due process” claims—an approach that is properly preservative of voters’ substantive rights and their rights to a fair hearing

The Holy Grail: A road map for unlocking the climate record stored within Mars' polar layered deposits

In its polar layered deposits (PLD), Mars possesses a record of its recent climate, analogous to terrestrial ice sheets containing climate records on Earth. Each PLD is greater than 2 ​km thick and contains thousands of layers, each containing information on the climatic and atmospheric state during its deposition, creating a climate archive. With detailed measurements of layer composition, it may be possible to extract age, accumulation rates, atmospheric conditions, and surface activity at the time of deposition, among other important parameters; gaining the information would allow us to “read” the climate record. Because Mars has fewer complicating factors than Earth (e.g. oceans, biology, and human-modified climate), the planet offers a unique opportunity to study the history of a terrestrial planet’s climate, which in turn can teach us about our own planet and the thousands of terrestrial exoplanets waiting to be discovered. During a two-part workshop, the Keck Institute for Space Studies (KISS) hosted 38 Mars scientists and engineers who focused on determining the measurements needed to extract the climate record contained in the PLD. The group converged on four fundamental questions that must be answered with the goal of interpreting the climate record and finding its history based on the climate drivers. The group then proposed numerous measurements in order to answer these questions and detailed a sequence of missions and architecture to complete the measurements. In all, several missions are required, including an orbiter that can characterize the present climate and volatile reservoirs; a static reconnaissance lander capable of characterizing near surface atmospheric processes, annual accumulation, surface properties, and layer formation mechanism in the upper 50 ​cm of the PLD; a network of SmallSat landers focused on meteorology for ground truth of the low-altitude orbiter data; and finally, a second landed platform to access ~500 ​m of layers to measure layer variability through time. This mission architecture, with two landers, would meet the science goals and is designed to save costs compared to a single very capable landed mission. The rationale for this plan is presented below. In this paper we discuss numerous aspects, including our motivation, background of polar science, the climate science that drives polar layer formation, modeling of the atmosphere and climate to create hypotheses for what the layers mean, and terrestrial analogs to climatological studies. Finally, we present a list of measurements and missions required to answer the four major questions and read the climate record. 1. What are present and past fluxes of volatiles, dust, and other materials into and out of the polar regions? 2. How do orbital forcing and exchange with other reservoirs affect those fluxes? 3. What chemical and physical processes form and modify layers? 4. What is the timespan, completeness, and temporal resolution of the climate history recorded in the PLD

The Holy Grail: A road map for unlocking the climate record stored within Mars' polar layered deposits

In its polar layered deposits (PLD), Mars possesses a record of its recent climate, analogous to terrestrial ice sheets containing climate records on Earth. Each PLD is greater than 2 ​km thick and contains thousands of layers, each containing information on the climatic and atmospheric state during its deposition, creating a climate archive. With detailed measurements of layer composition, it may be possible to extract age, accumulation rates, atmospheric conditions, and surface activity at the time of deposition, among other important parameters; gaining the information would allow us to “read” the climate record. Because Mars has fewer complicating factors than Earth (e.g. oceans, biology, and human-modified climate), the planet offers a unique opportunity to study the history of a terrestrial planet’s climate, which in turn can teach us about our own planet and the thousands of terrestrial exoplanets waiting to be discovered. During a two-part workshop, the Keck Institute for Space Studies (KISS) hosted 38 Mars scientists and engineers who focused on determining the measurements needed to extract the climate record contained in the PLD. The group converged on four fundamental questions that must be answered with the goal of interpreting the climate record and finding its history based on the climate drivers. The group then proposed numerous measurements in order to answer these questions and detailed a sequence of missions and architecture to complete the measurements. In all, several missions are required, including an orbiter that can characterize the present climate and volatile reservoirs; a static reconnaissance lander capable of characterizing near surface atmospheric processes, annual accumulation, surface properties, and layer formation mechanism in the upper 50 ​cm of the PLD; a network of SmallSat landers focused on meteorology for ground truth of the low-altitude orbiter data; and finally, a second landed platform to access ~500 ​m of layers to measure layer variability through time. This mission architecture, with two landers, would meet the science goals and is designed to save costs compared to a single very capable landed mission. The rationale for this plan is presented below. In this paper we discuss numerous aspects, including our motivation, background of polar science, the climate science that drives polar layer formation, modeling of the atmosphere and climate to create hypotheses for what the layers mean, and terrestrial analogs to climatological studies. Finally, we present a list of measurements and missions required to answer the four major questions and read the climate record. 1. What are present and past fluxes of volatiles, dust, and other materials into and out of the polar regions? 2. How do orbital forcing and exchange with other reservoirs affect those fluxes? 3. What chemical and physical processes form and modify layers? 4. What is the timespan, completeness, and temporal resolution of the climate history recorded in the PLD

Unlocking the Climate Record Stored within Mars’ Polar Layered Deposits

In the icy beds of its polar layered deposits (PLD), Mars likely possesses a record of its recent climate history, analogous to terrestrial ice sheets that contain records of Earth's past climate. Both northern and southern PLDs store information on the climatic and atmospheric state during the deposition of each layer (WPs: Becerra et al.; Smith et al). Reading the climate record stored in these layers requires detailed measurements of layer composition, thickness, isotope variability, and near-surface atmospheric measurements. We identify four fundamental questions that must be answered in order to interpret this climate record and decipher the recent climatic history of Mars: 1. Fluxes: What are the present and past fluxes of volatiles, dust, and other materials into and out of the polar regions? 2. Forcings: How do orbital/axial forcing and exchange with other reservoirs affect those fluxes? 3. Layer Processes: What chemical and physical processes form and modify layers? 4. Record: What is the timespan, completeness, and temporal resolution of the climate history recorded in the PLD? In a peer reviewed report (1), we detailed a sequence of missions, instruments, and architecture needed to answer these questions. Here, we present the science drivers and a mission concept for a polar lander that would enable a future reading of the past few million years of the Martian climate record. The mission addresses as-yet-unachieved science goals of the current Decadal Survey and of MEPAG for obtaining a record of Mars climate and has parallel goals to the NEXSAG and ICE-SAG reports

Perseverance Rover’s Early Adventures in Jezero Crater, Mars

For decades, NASA has been exploring Mars with a fleet of spacecraft to understand the role of water in its history and look for areas that in the past could have supported life. This work has paved the way for the Mars 2020 Perseverance Rover, which landed on Feb 18, 2021 in Jezero Crater with the ambitious mission to search for evidence of ancient bacterial life and to collect rock samples for eventual return to Earth. In the short time since landing, Perseverance has already been hard at work testing out its new capabilities and getting to know its new home. From engineering checkouts to commissioning of capabilites to deploying Ingenuity (the Mars helicopter), to beginning her science journey. Each sol (what we call a day on Mars) has been packed with activities. Find out about her early adventures and challenges as she begins her exploration journey on Mars