Buscando a los padres y hermanos de Benita de Lema: el uso de apellidos en Galicia antes de 1790

This genealogical reconstitution of the families of Benita de Lema eighteenth century woman from Cee, La Coruña explores the use of surnames during this period in Galicia. Documentation drawn from parish, notary and court records shows her as mother and daughter interacting with family and society and demonstrates the flexibility in the selection of surnames throughout much of that century in Galicia. In Galicia men and women during the time before 1790 could select surnames from their fathers or mothers, from their extended pedigree, or even from their spouse’s family, and often did so.La reconstrucción genealógica de las líneas de Benita de Lema, mujer del siglo XVIII y natural de Cee (La Coruña), indaga acerca del uso de apellidos durante esta época en Galicia. Documentos sacados de registros parroquiales, de protocolos y de la audiencia real muestran, además de su filiación, su relación con la sociedad, y evidencia, al propio tiempo, la flexibilidad en la selección de apellidos durante la mayor parte de aquel siglo. Los hombres y las mujeres que vivieron durante el período anterior a 1790 podían escoger entre los apellidos de sus padres o sus madres, de sus linajes extendidos, o incluso entre los apellidos de las familias de sus cónyuges. [gl] A reconstrución xenealóxica das liñas de Benita de Lema, muller do século XVIII e natural de Cee (A Coruña), indaga acerca do uso de apelidos durante esta época en Galicia. Documentos tirados de rexistros parroquiais, de protocolos e da audiencia real mostran, ademais da súa filiación, a súa relación coa sociedade, e evidencia, ao propio tempo, a flexibilidade na selección de apelidos durante a maior parte daquel século. Os homes e as mulleres que viviron durante o período anterior a 1790 podían escoller entre os apelidos dos seus pais ou das súas nais, das súas liñaxes estendidas, ou mesmo entre os apelidos das familias dos seus cónxuxes

Antimicrobial Activity of Silver-Bonded Fabrics for the Creation of Nursing Scrubs

Hospital acquired infections (HAIs) are contracted by patients at or after the time of admission. It is estimated that annually 100,000 patients die worldwide due to HAI related causes and the frequency of HAIs has not decreased in the past 20 years. While many sanitation protocols are designed to reduce direct transmission of HAIs, current research is investigating how indirect transmission of HAIs may be reduced through use of antimicrobial scrubs. We investigated the antimicrobial activity of silver, a metal well known to disrupt cell membrane functions and thus kill bacteria, as an agent to be incorporated into the fabric used to make nursing scrubs. This antimicrobial fabric was tested by depositing S. aureus or K. pneumoniae onto swatches of the cloth for 0, 4, 12, and 24 hours. The surviving bacteria were then enumerated by spread-plating onto nutrient-rich agar. The results of this study could yield valuable insight into a potential method for reducing the frequency of HAIs worldwide

Bond Repudiation, Tax Codes, the Appropriations Process and Restitution Post-Eminent Domain Reform

This brief comment suggests where the anti-eminent domain movement might be heading next

The New Constitutional Right to Maintenance in the United States

The 2003, United States Supreme Court case of Lawrence v. Texas is not a maintenance case. It abolished laws against sodomy. In doing so, however, it overruled the case which prevented a right to maintenance in the United States. In the 1937 case of West Coast Hotel v. Parrish, the Supreme Court, although sustaining a minimum wage law, nevertheless did so on the sole basis of demoting liberty (supposed by the Court to forbid minimum wage laws) to an unenforceable interest. The notion of an unenforceable interest was part of the scrutiny regime established in West Coast Hotel. The regime said that most facts—including maintenance—were subject to government discretion as long as that discretion was rationally related to a legitimate government interest. This, the Court felt, was necessary in order to rein in liberty. Lawrence v. Texas has ended that regime by finding an individually enforceable right to liberty, elevating it from its previously unenforceable status as an interest. We currently have no idea what standard the United States Government must meet in order to violate the new individually enforceable right to liberty. However, the scrutiny regime has clearly been abolished because its basis—the demotion of liberty to an unenforceable interest—has been overruled. Even as an unenforceable interest, the Supreme Court had prepared the ground for a Constitutional reevaluation of maintenance in a case pursuant to West Coast Hotel. In United States v. Carolene Products, the Court sustained a law banning substitute ingredients in milk, on the basis that maintenance is important to health. Nevertheless, in 1989, the Court, in DeShaney v. Winnebago County, found specifically that maintenance was not an individually enforceable right; it based this decision on the idea that liberty had been demoted to an unenforceable interest. The anomaly—and the larger dispute as to whether liberty ever had anything to do with minimum wage laws or maintenance in the first place—ended with Lawrence v. Texas. We are in the same position with respect to maintenance as we are with respect to liberty. The Court has not yet indicated no idea what standard the United States Government must meet in order to violate the new individually enforceable right to maintenance. However, we do know one thing: maintenance is now an individually enforceable right in the United States. This is a profound change in the Constitutional history of the United States which, given the predominance of the United States in world legal policy, will affect the social policies of every other nation

Anencephaly: Concepts of Personhood, Ethical Questions, and Nursing Care

Anencephaly is a neural tube defect that severely limits the lifespan of affected infants. While these infants have no higher brain function, they are still persons, and should be given the same moral and ethical considerations as healthy infants. With this in mind, organ donation procedures should follow the same guidelines that apply to other donors. Because a large part of nursing care for anencephalic infants is palliative care, nurses need appropriate training to care effectively for both the infant and the family, providing for physical, emotional, psychological, and spiritual needs

Finding New Constitutional Rights through the Supreme Court’s Evolving “Government Purpose” Test under Minimum Scrutiny

By now we all are familiar with the litany of cases which refused to find elevated scrutiny for so-called “affirmative” or “social” rights such as education, welfare or housing: Lindsey v. Normet, San Antonio School District v. Rodriguez, Dandridge v. Williams, DeShaney v. Winnebago County. There didn’t seem to be anything in minimum scrutiny which could protect such facts as education or housing, from government action. However, unobtrusively and over the years, the Supreme Court has clarified and articulated one aspect of minimum scrutiny which holds promise for vindicating facts. You will recall that under minimum scrutiny government’s action is sustained if it is rationally related to a legitimate government purpose. That has seemed hopelessly vague. However, through a series of cases the Supreme Court has now made it clear that the three prongs of the test—rationality, relationship and government—are questions of fact for the trier of fact. This opens up the possibility that civil discovery can show, with respect to criteria for these prongs, that government fails to meet minimum scrutiny. Actually, the tendency of the Court’s minimum scrutiny jurisprudence is to severely disfavor discretion, and strongly favor factual showing, in minimum scrutiny adjudication

Did You Happen to Notice that Lawrence v. Texas Overruled West Coast Hotel v. Parrish?

The article points out, for the first time, the way in which Lawrence v. Texas overruled West Coast Hotel v. Parrish. Lawrence\u27s overruling of West Coast is the first step in the demise of the minimum scrutiny regime, which the Court established in West Coast in 1937

Why Guru Nanak Is Another Nail in the Coffin of West Coast Hotel v. Parrish

In Guru Nanak v. Sutter, the Ninth Circuit upheld RLUIPA by accepting its conflation of individualized assessments and substantial burden. Although RLUIPA involved a misreading of Oregon v. Smith, it was a misreading the Ninth Circuit adopted. The question is, why did Sutter counsel allow the misreading of Smith, especially since Smith lost? It is because, in general, the American bar has failed to see that there has been a substantial corrosion of the scrutiny regime established by West Coast Hotel v. Parrish. They are in denial: they can\u27t believe that the scrutiny regime could ever fall. And yet, the Court in Lawrence v. Texas -- which established an individually enforceable right to liberty -- not only implicitly overruled the West Coast rationale that liberty needed to be controlled -- but also, it set up a test which is not even part of the scrutiny regime. Guru Nanak affirms the undermining of the scrutiny regime, and RLUIPA will probably be upheld if Guru Nanak is appealed. Part of the reason it will be upheld, is that those opposing RLUIPA do not know how to argue in our new Constitutional epoch, an epoch in which West Coast Hotel has been left far behind. Together, Guru Nanak and Lawrence argue a revisiting of all health and welfare regulation. The bar should take note

Every Law Maintains an Important Fact: The Supreme Doctrine of the New Fourth Constitutional Epoch

Every law maintains an important fact: out of the political welter this doctrine has emerged as the supreme doctrine of the new fourth Constitutional epoch. It is widely understood that the scrutiny regime instituted by West Coast Hotel v. Parrish, is but one of three which have determined applications of the Constitution since its ratification. However, what is less widely known is that three recent cases illustrate how the third epoch has ended and the concerns of the new epoch. Currently the cases are litigated in terms of the meaning of, every, maintain and important