Shall Businesses Profit If Their Owners Lose Their Souls? Examining Whether Closely Held Corporations May Seek Exemptions from the Contraceptive Mandate

May for–profit, secular corporations claim the protection of the Religious Freedom Restoration Act (RFRA)? This question is central to numerous lawsuits against the federal government in which business owners argue that certain regulations under the Patient Protection & Affordable Care Act substantially burden the exercise of their religion. This Note examines the threshold hurdle that for–profit business owners must clear to successfully state a claim under RFRA: the question of whether the businesses are “persons” the statute protects. This is an issue of first impression for the U.S. Supreme Court, and it has split the circuit courts of appeal. First, this Note provides an overview of free exercise jurisprudence, with a focus on the ebbs and flows of the Supreme Court’s exemption doctrine. This overview includes a discussion of the Religious Freedom Restoration Act and the laws, regulations, and religious objections that form the basis of the current disputes. Second, this Note introduces the conflict among circuit courts and their varying interpretations of whether for–profit corporations are “persons” under RFRA. Third, this Note assesses this conflict by examining RFRA’s text and the context in which Congress enacted the statute. Nothing within this context precludes corporations from stating RFRA claims. In addition, this Note examines legislative history that supports application of the Dictionary Act, which explains that the word “person” in federal statutes includes corporations. This Note ultimately concludes that RFRA does indeed grant corporations the ability to seek exemptions, but that the statute will require courts to undertake the task of ascertaining the proper contours of the law as applied to different corporate forms

Stand-replacing wildfires increase nitrification for decades in southwestern ponderosa pine forests.

Stand-replacing wildfires are a novel disturbance within ponderosa pine (Pinus ponderosa) forests of the southwestern United States, and they can convert forests to grasslands or shrublands for decades. While most research shows that soil inorganic N pools and fluxes return to pre-fire levels within a few years, we wondered if vegetation conversion (ponderosa pine to bunchgrass) following stand-replacing fires might be accompanied by a long-term shift in N cycling processes. Using a 34-year stand-replacing wildfire chronosequence with paired, adjacent unburned patches, we examined the long-term dynamics of net and gross nitrogen (N) transformations. We hypothesized that N availability in burned patches would become more similar to those in unburned patches over time after fire as these areas become re-vegetated. Burned patches had higher net and gross nitrification rates than unburned patches (P < 0.01 for both), and nitrification accounted for a greater proportion of N mineralization in burned patches for both net (P < 0.01) and gross (P < 0.04) N transformation measurements. However, trends with time-after-fire were not observed for any other variables. Our findings contrast with previous work, which suggested that high nitrification rates are a short-term response to disturbance. Furthermore, high nitrification rates at our site were not simply correlated with the presence of herbaceous vegetation. Instead, we suggest that stand-replacing wildfire triggers a shift in N cycling that is maintained for at least three decades by various factors, including a shift from a woody to an herbaceous ecosystem and the presence of fire-deposited charcoal

Association is not causation: treatment effects cannot be estimated from observational data in heart failure

Aims: Treatment ‘effects’ are often inferred from non-randomized and observational studies. These studies have inherent biases and limitations, which may make therapeutic inferences based on their results unreliable. We compared the conflicting findings of these studies to those of prospective randomized controlled trials (RCTs) in relation to pharmacological treatments for heart failure (HF). Methods and results: We searched Medline and Embase to identify studies of the association between non-randomized drug therapy and all-cause mortality in patients with HF until 31 December 2017. The treatments of interest were: angiotensin-converting enzyme inhibitors, angiotensin receptor blockers, beta-blockers, mineralocorticoid receptor antagonists (MRAs), statins, and digoxin. We compared the findings of these observational studies with those of relevant RCTs. We identified 92 publications, reporting 94 non-randomized studies, describing 158 estimates of the ‘effect’ of the six treatments of interest on all-cause mortality, i.e. some studies examined more than one treatment and/or HF phenotype. These six treatments had been tested in 25 RCTs. For example, two pivotal RCTs showed that MRAs reduced mortality in patients with HF with reduced ejection fraction. However, only one of 12 non-randomized studies found that MRAs were of benefit, with 10 finding a neutral effect, and one a harmful effect. Conclusion: This comprehensive comparison of studies of non-randomized data with the findings of RCTs in HF shows that it is not possible to make reliable therapeutic inferences from observational associations. While trials undoubtedly leave gaps in evidence and enrol selected participants, they clearly remain the best guide to the treatment of patients

New Kadampa Buddhists and Jungian psychological type

Building on previous studies on Canadian Anglicans and Catholics, this study examines and discusses the psychological type profile of 31 adherents to New Kadampa Buddhism. Like Anglicans and Catholics, Buddhists preferred introversion (I). Like Anglicans who preferred intuition (N) and unlike Catholics who preferred sensing (S), Buddhists displayed a preference for intuition (N). Unlike Anglicans and Catholics who both preferred feeling (F), Buddhists displayed a balance between feeling (F) and thinking (T). Like Anglicans and unlike Catholics, Buddhists preferred the Apollonian temperament (NF) over the Epimethean temperament (SJ). These data are discussed to interpret the psychological appeal of New Kadampa Buddhism

Enantiopure planar chiral and chiral-at-metal iridacycles derived from bulky cobalt sandwich complexes

Reaction of (η5-(S)-2-(4-methylethyl)oxazolinylcyclopentadienyl)(η4-tetraphenylcyclobutadiene)cobalt with [IrCp*Cl2]2 in acetonitrile with KPF6 and KOt-Bu resulted in S,Sp,SIr and S,Rp,RIr configured acetonitrile and Cp* coordinated cationic iridacycles (d.r. up to 4.8 : 1 – kinetic control), the planar chiral configuration dictating the configuration of the pseudo-tetrahedral iridium-based stereogenic centre. Addition of water to the cycloiridation reaction resulted in an increase in yield (up to 78%) at the cost of diastereoselectivity. Use of the corresponding substrate containing a t-Bu rather than an i-Pr substituted oxazoline gave exclusively the S,Sp,SIr diastereoisomer, and under the same conditions (S)-2-ferrocenyl- 4-(1,1-dimethylethyl)oxazoline cycloiridated to give only the S,Sp,SIr diastereoisomer. Substitution reactions of the title complexes at iridium proceeded with retention of configuration, a computational study revealing the proposed coordinatively unsaturated intermediate of a dissociative mechanism to display a relatively weak Co-Ir interaction, and a pronounced steric effect as the basis of stereocontrol

Poverty and Parenthood across Modern Nations: Findings from the Luxembourg Income Study

All modern societies face the issue of how to best support its children when labor and capital markets fail to produce adequate levels of income for their parents. Public and private means of economic and social support are mixed in rich nations to provide for both a minimally adequate level of economic and social support for families with children, and an equal opportunity for economic and social success amongst all children in the society. If we accept these goals, we might then measure failure to achieve the first outcome (adequacy) by the child poverty rate, and progress toward the second goal (equal opportunity) by the narrowness of the spread in incomes between the rich and poor in any a society. However, not all nations equally achieve these goals. If we create such measures as this, previous research has established that the United States has both the highest child poverty rate (20 percent or more) and the widest economic distance from poor to rich children of any modern (OECD) society. Others have published repeatedly on the high economic and social costs of child poverty in the United States and its social consequences. In fact, this disturbing outcome has provoked us to begin a set of wider and more complete studies designed to isolate the factors which produce poor child outcomes in the United States in comparison to those found in other nations. This paper is the second in a series of three related papers which try to examine why we find this outcome. The general rubric under which we are operating is termed 'the cost of children.' The rest of this introductory section of the paper discusses this project, the findings of our first paper on differences in poverty amongst men and women, and subsequent papers to follow. The second part of the paper presents our thoughts on the piece of the puzzle which we address here: the economic situation of parents and the poverty cost of parenthood. Next we discuss our definitions, data and methods (section III), results (section IV) and finally a summary discussion and conclusions (section V)

Functional Imaging of Audio-Visual Selective Attention in Monkeys and Humans : How do Lapses in Monkey Performance Affect Cross-Species Correspondences?

The cross-species correspondences and differences in how attention modulates brain responses in humans and animal models are poorly understood. We trained 2 monkeys to perform an audio-visual selective attention task during functional magnetic resonance imaging (fMRI), rewarding them to attend to stimuli in one modality while ignoring those in the other. Monkey fMRI identified regions strongly modulated by auditory or visual attention. Surprisingly, auditory attention-related modulations were much more restricted in monkeys than humans performing the same tasks during fMRI. Further analyses ruled out trivial explanations, suggesting that labile selective-attention performance was associated with inhomogeneous modulations in wide cortical regions in the monkeys. The findings provide initial insights into how audio-visual selective attention modulates the primate brain, identify sources for "lost" attention effects in monkeys, and carry implications for modeling the neurobiology of human cognition with nonhuman animals.Peer reviewe