The Trilogy of Personal Jurisdiction and the Importance of \u3cem\u3eFord\u3c/em\u3e

Litigants and judges alike have struggled to understand and resolve the parameters of personal jurisdiction, particularly in product liability cases. This results in significant costs and time which is likely to be of little benefit to anyone. Much of this confusion arises from two problems: (1) most of the early Supreme Court decisions on personal jurisdiction arose from contractual disputes; and (2) when the economy expanded after World War II, and new automobiles, commercial aircraft, appliances, and other complex products appeared, the Court’s attempts to resolve personal jurisdiction issues were unsuccessful. For over three decades, the Supreme Court failed to produce a clear majority opinion, while at the same time, these cases were becoming more common and complex. In the past decade, however, the Court has quietly produced a trilogy of virtually unanimous opinions that offer pathways to resolve personal jurisdiction disputes. These decisions will be particularly useful in product liability cases of all kinds, which often involve suit-related events occurring across multiple jurisdictions. Once lawyers and judges understand this clarified framework, it should become easier for plaintiffs to make better decisions about where to bring their case and enable both plaintiffs and defendants to spend less time and expense litigating personal jurisdiction disputes

An Investigation of Item Type in a Standards-Based Assessment

Large-scale state assessment programs use both multiple-choice and open-ended items on tests for accountability purposes. Certainly, there is an intuitive belief among some educators and policy makers that open-ended items measure something different than multiple-choice items. This study examined two item formats in custom-built, standards-based tests of achievement in Reading and Mathematics at grades 3-8. In this paper, we raise questions about the value of including open-ended items, given scoring costs, time constraints, and the higher probability of missing data from test-takers. Accessed 19,320 times on https://pareonline.net from December 10, 2007 to December 31, 2019. For downloads from January 1, 2020 forward, please click on the PlumX Metrics link to the right

Ovarian Teratoma Masquerading as a CSF Pseudocyst in a Female with a Ventriculoperitoneal Shunt

Background. In today's fast-paced and high-acuity emergency departments, clinicians are often compelled to triage cases so rapidly that a differential diagnosis consistent with the history and physical examination is not comprehensive. Case Report. This case report describes the unexpected finding of a cystic ovarian neoplasm in a young female with an abdominal mass and a ventriculoperitoneal shunt, initially diagnosed as a cerebrospinal fluid pseudocyst. We use this case to illustrate that the astute clinician must always synthesize a diagnosis from all data sources and not to rely on initial radiographic evaluations. Conclusions. This remarkable case demonstrates that all differential diagnoses must be entertained in order to rapidly and accurately diagnose a patient with a cystic abdominal mass

Exploring how paramedics are deployed in general practice and the perceived benefits and drawbacks: a mixed-methods scoping study

Background: General practice in the UK faces continuing challenges to balance a workforce shortage against rising demand. The NHS England GP Forward View proposes development of the multidisciplinary, integrated primary care workforce to support frontline service delivery, including the employment of paramedics. However, very little is known about the safety, clinical effectiveness, or cost-effectiveness of paramedics working in general practice. Research is needed to understand the potential benefits and drawbacks of this model of workforce organisation. Aim: To understand how paramedics are deployed in general practice, and to investigate the theories and drivers that underpin this service development. Design & setting: A mixed-methods study using a literature review, national survey, and qualitative interviews. Method: A three-phase study was undertaken that consisted of: a literature review and survey; meetings with key informants (KIs); and direct enquiry with relevant staff stakeholders (SHs). Results: There is very little evidence on the safety and cost-effectiveness of paramedics working in general practice and significant variation in the ways that paramedics are deployed, particularly in terms of the patients seen and conditions treated. Nonetheless, there is a largely positive view of this development and a perceived reduction in GP workload. However, some concerns centre on the time needed from GPs to train and supervise paramedic staff. Conclusion: The contribution of paramedics in general practice has not been fully evaluated. There is a need for research that takes account of the substantial variation between service models to fully understand the benefits and consequences for patients, the workforce, and the NHS

A Computational and Experimental Investigation of the Origin of Selectivity in the Chiral Phosphoric Acid Catalyzed Enantioselective Minisci Reaction.

The Minisci reaction is one of the most valuable methods for directly functionalizing basic heteroarenes to form carbon-carbon bonds. Use of prochiral, heteroatom-substituted radicals results in stereocenters being formed adjacent to the heteroaromatic system, generating motifs which are valuable in medicinal chemistry and chiral ligand design. Recently a highly enantioselective and regioselective protocol for the Minisci reaction was developed, using chiral phosphoric acid catalysis. However, the precise mechanism by which this process operated and the origin of selectivity remained unclear, making it challenging to develop the reaction more generally. Herein we report further experimental mechanistic studies which feed into detailed DFT calculations that probe the precise nature of the stereochemistry-determining step. Computational and experimental evidence together support Curtin-Hammett control in this reaction, with initial radical addition being quick and reversible, and enantioselectivity being achieved in the subsequent slower, irreversible deprotonation. A detailed survey via DFT calculations assessed a number of different possibilities for selectivity-determining deprotonation of the radical cation intermediate. Computations point to a clear preference for an initially unexpected mode of internal deprotonation enacted by the amide group, which is a crucial structural feature of the radical precursor, with the assistance of the associated chiral phosphate. This unconventional stereodetermining step underpins the high enantioselectivities and regioselectivities observed. The mechanistic model was further validated by applying it to a test set of substrates possessing varied structural features.EPSRC GSSK ERC Leverhulme Trust Isaac Newton Trus

Lunar-sourced GEO Powersats: An Integrated ISRU System

Solar power satellites (powersats) can be built almost entirely from lunar resources. When C-class asteroids are also included as ore bodies a complete powersat can be built through insitu resource utilization (ISRU) given appropriate processing and transportation technology.This article provides an in-depth overview of the technical feasibility and economic viabilityof lunar construction and operations for powersat component construction and delivery togeostationary earth orbit (GEO). Techno-economic analysis suggests a return on investmentin seven years assuming a three percent discount rate. Electrical power collected in GEO andbeamed to terrestrial receivers by the powersats can be sold as baseload power in the wholesale electricity market to generate revenue. This work presents a complete concept of operationsfrom initial rocket launches to regolith harvesting through transport to GEO. Lunarinfrastructure can be constructed of modules to optimize size and weight for launch costs.Future growth can be derived from using ISRU to build additional processing bases. A scale-up in this manner can provide 22% of the world’s energy needs by the end of a 20-year period.This work builds upon previous studies and completes the architectural description ofpredominantly lunar-sourced GEO powersats