Environmental Law: States May No Longer Bring a Federal Common Law Nuisance Action to Abate Interstate Water Pollution

City of Milwaukee v. Illinois, 101 S.Ct. 1784 (1981). In the landmark decision Erie Railroad v. Tomkins, the United States Supreme Court set forth the general proposition that the federal courts may not provide their own rules of decision under the guise of federal common law. Since Erie, however, in cases involving a significant federal interest, the Court has consistently backed away from this rather harsh limitation on federal judicial power. In the City of Milwaukee v. Illinois decision, the United States Supreme Court apparently came full circle, returning to its rule preventing federal courts from fashioning federal common law, at least in the context of interstate water pollution controversies. The immediate effect of City of Milwaukee is to preclude the states from bringing common law nuisance actions demanding relief from the harmful effects of extraterritorial pollution. Just nine years prior to City of Milwaukee, in Illinois v. Milwaukee, a case involving the same dispute and parties, the Supreme Court gave formal recognition to the federal common law nuisance action for the abatement of water pollution crossing state boundaries. More important, the Illinois v. Milwaukee Court held that because interstate pollution is a federal concern, the nuisance action qualified for a grant of 28 U.S.C. § 1331 federal question jurisdiction. Because of the Supreme Court\u27s holding that it was no longer the only forum available to hear such a dispute between two states, for the first time, a state could initiate a common law nuisance action in a federal district court. Congress severely criticized the judicial response to water pollution as being far too ad hoc and sporadic” a method for adequately dealing with the mounting pollution problem. Just six months after Illinois v. Milwaukee, Congress passed the Federal Water Pollution Control Act Amendments of 1972 (FWPCAA). The new regulatory scheme changed the approach to water pollution from one of state control and authority to a federal framework of standards and enforcement. Both Congress and the Supreme Court regarded the FWPCAA as a comprehensive legislative response to the inadequacies of past pollution control efforts. In Illinois v. Milwaukee, the Court acknowledged that, in time, the legislature might take action which would preempt any further need for the federal common law nuisance action. City of Milwaukee v. Illinois provided the Court with the first opportunity to determine the propriety of maintaining a federal common law nuisance action in light of the FWPCAA. This case note explores whether, by abolishing such a nuisance action, the Court has laid to rest what Congress intended to be an important mechanism for enforcing and effectuating the FWPCAA

Spam1-associated transmission ratio distortion in mice: Elucidating the mechanism

BACKGROUND: While transmission ratio distortion, TRD, (a deviation from Mendelian ratio) is extensive in humans and well-documented in mice, the underlying mechanisms are unknown. Our earlier studies on carriers of spontaneous mutations of mouse Sperm Adhesion Molecule 1 (Spam1) suggested that TRD results from biochemically different sperm, due to a lack of transcript sharing through the intercellular cytoplasmic bridges of spermatids. These bridges usually allow transcript sharing among genetically different spermatids which develop into biochemically and functionally equivalent sperm. OBJECTIVES: The goals of the study were to provide support for the lack of sharing (LOS) hypothesis, using transgene and null carriers of Spam1, and to determine the mechanism of Spam1-associated TRD. METHODS: Carriers of Spam1-Hyal5 BAC transgenes were mated with wild-type female mice and the progeny analyzed for TRD by PCR genotyping. Sperm from transgene and Spam1 null carriers were analyzed using flow cytometry and immunocytochemistry to detect quantities of Spam1 and/or Hyal5. Transgene-bearing sperm with Spam1 overexpression were detected by fluorescence in situ hybridization. In wild-type animals, EM studies of in situ transcript hybridization of testis sections and Northern analysis of biochemically fractionated testicular RNA were performed to localize Spam1 transcript. Finally, AU-rich motifs identified in the 3' UTR of Spam1 RNA were assayed by UV cross-linking to determine their ability to interact with testicular RNA binding proteins. RESULTS: The Tg8 line of transgene carriers had a significant (P < 0.001) TRD, due to reduced fertilizing ability of transgene-bearing sperm. These sperm retained large cytoplasmic droplets engorged with overexpressed Spam1 or Hyal5 protein. Caudal sperm from transgene carriers and caput sperm of null carriers showed a bimodal distribution of Spam1, indicating that the sperm in a male were biochemically different with respect to Spam1 quantities. Spam1 RNA was absent from the bridges, associated exclusively with the ER, and was shown to be anchored to the cytoskeleton. This compartmentalization of the transcript, mediated by cytoskeletal binding, occurs via protein interactions with 3' UTR AU-rich sequences that are likely involved in its stabilization. CONCLUSION: We provide strong support for the LOS hypothesis, and have elucidated the mechanism of Spam1-associated TRD

The use of electric fields for edible coatings and films development and production: A review

Edible films and coatings can provide additional protection for food, while being a fully biodegradable, environmentally friendly packaging system. A diversity of raw materials used to produce edible coatings and films are extracted from marine and agricultural sources, including animals and plants. Electric fields processing holds advantage in producing safe, wholesome and nutritious food. Recently, the presence of a moderate electric field during the preparation of edible coatings and films was shown to influence their main properties, demonstrating its usefulness to tailor edible films and coatings for specific applications. This manuscript reviews the main aspects of the use of electric fields in the production of edible films and coatings, including the effect in their transport and mechanical properties, solubility and microstructure.Fundação para a Ciência e a Tecnologia (FCT), Portugal.Coordenação de Aperfeiçoamento de Pessoal de Nível Superior (CAPES), Brasil

Appointment letter for Dean Samuel D. Thurman

Appointment letter for Dean Samuel D. Thurman from University of Utah Board of Regents

Application of Spectral Algorithm Applied to Spatially Registered Bi-Parametric MRI to Predict Prostate Tumor Aggressiveness: A Pilot Study

Background: Current prostate cancer evaluation can be inaccurate and burdensome. Quantitative evaluation of Magnetic Resonance Imaging (MRI) sequences non-invasively helps prostate tumor assessment. However, including Dynamic Contrast Enhancement (DCE) in the examined MRI sequence set can add complications, inducing possible side effects from the IV placement or injected contrast material and prolonging scanning time. More accurate quantitative MRI without DCE and artificial intelligence approaches are needed. Purpose: Predict the risk of developing Clinically Significant (Insignificant) prostate cancer CsPCa (CiPCa) and correlate with the International Society of Urologic Pathology (ISUP) grade using processed Signal to Clutter Ratio (SCR) derived from spatially registered bi-parametric MRI (SRBP-MRI) and thereby enhance non-invasive management of prostate cancer. Methods: This pilot study retrospectively analyzed 42 consecutive prostate cancer patients from the PI-CAI data collection. BP-MRI (Apparent Diffusion Coefficient, High B-value, T2) were resized, translated, cropped, and stitched to form spatially registered SRBP-MRI. Efficacy of noise reduction was tested by regularizing, eliminating principal components (PC), and minimizing elliptical volume from the covariance matrix to optimize the SCR. MRI guided biopsy (MRBx), Systematic Biopsy (SysBx), combination (MRBx + SysBx), or radical prostatectomy determined the ISUP grade for each patient. ISUP grade ≥ 2 (Results: High correlation coefficients (R) (>0.55) and high AUC (=1.0) for linear and/or logistic fit from processed SCR and z-score for SRBP-MRI greatly exceed fits using prostate serum antigen, prostate volume, and patient age (R ~ 0.17). Patients assessed with combined MRBx + SysBx and from individual MRI scanners achieved higher R (DR = 0.207+/−0.118) than all patients used in the fits. Conclusions: In the first study, to date, spectral approaches for assessing tumor aggressiveness on SRBP-MRI have been applied and tested and achieved high values of R and exceptional AUC to fit the ISUP grade and CsPCA/CiPCA, respectively

Gastrodoudenal Embolization: Indications, Technical Pearls, and Outcomes

The gastroduodenal artery (GDA) is frequently embolized in cases of upper GI bleed that has failed endoscopic therapy. Additionally, it may be done for GDA pseudoaneurysms or as an adjunctive procedure prior to Yttrim-90 (Y90) treatment of hepatic tumors. This clinical review will summarize anatomy and embryology of the GDA, indications, outcomes and complications of GDA embolization