Compelling Interests and Contraception

On the eve of Griswold v. Connecticut’s fiftieth anniversary, employers are bringing challenges under the Religious Freedom Restoration Act (RFRA) to federal laws requiring them to include contraception in the health insurance benefits that they offer their employees. In Burwell v. Hobby Lobby Stores, five Justices asserted that the government has compelling interests in ensuring employees access to contraception, but did not discuss those interests in any detail. In what follows, we clarify those interests by connecting discussion in the Hobby Lobby opinions and the federal government’s briefs to related cases on compelling interests and individual rights in the areas of race and sex equality. The government’s compelling interests, we argue, are best understood from within two horizons: they encompass not only core concerns of the community in promoting public health and facilitating women’s integration in the workplace, but also crucial concerns of the employees who are the intended beneficiaries of federal law’s contraceptive coverage requirement—interests that sound in bodily integrity, personal autonomy, and equal citizenship. Further, as we show, a full accounting of the government’s compelling interests attends both to their material and expressive dimensions. This more comprehensive account of the government’s compelling interests in providing employees access to contraception matters both in political debate and in RFRA litigation as courts determine whether the government has pursued its interests by the least restrictive means. The more comprehensive account offered here is less susceptible to compromise and tradeoffs than is an account focused only on material interests in public health and contraceptive cost

Contraception as a Sex Equality Right

Challenges to federal law requiring insurance coverage of contraception are occurring on the eve of the 50th Anniversary of the U.S. Supreme Court’s decision in Griswold v. Connecticut. It is a good time to reflect on the values served by protecting women’s access to contraception. In 1965, the Court ruled in Griswold that a law criminalizing the use of contraception violated the privacy of the marriage relationship. Griswold offered women the most significant constitutional protection since the Nineteenth Amendment gave women the right to vote, constitutional protection as important as the cases prohibiting sex discrimination that the Court would decide in the next decade—perhaps even more so. Griswold is conventionally understood to have secured liberty for women. But the right to contraception also secures equality for women, as Ruth Bader Ginsburg saw clearly in the 1970s and as the Court eventually would explain in Planned Parenthood v. Casey

Large-scale Ferrofluid Simulations on Graphics Processing Units

We present an approach to molecular-dynamics simulations of ferrofluids on graphics processing units (GPUs). Our numerical scheme is based on a GPU-oriented modification of the Barnes-Hut (BH) algorithm designed to increase the parallelism of computations. For an ensemble consisting of one million of ferromagnetic particles, the performance of the proposed algorithm on a Tesla M2050 GPU demonstrated a computational-time speed-up of four order of magnitude compared to the performance of the sequential All-Pairs (AP) algorithm on a single-core CPU, and two order of magnitude compared to the performance of the optimized AP algorithm on the GPU. The accuracy of the scheme is corroborated by comparing the results of numerical simulations with theoretical predictions

Pregnancy and Sex Role Stereotyping: From Struck to Carhart

The guarantee of equal protection of the laws extends to women as well as men. Yet for the first 100 years of the Fourteenth Amendment’s life, the Supreme Court never found a law unconstitutional on the grounds that it discriminated on the basis of sex. Between 1970 and 1980, social movement advocacy and brilliant litigation by Ruth Bader Ginsburg and others changed our constitutional law. Over the course of the decade, the Court extended the anti-stereotyping principle from discrimination on the basis of race to discrimination on the basis of sex. But fidelity to the principle had its limits. In short, the Court’s 1970s cases hold that the antistereotyping principle constrains laws that classify by sex, but do not find the principle violated where government regulates pregnancy. Our Essay unsettles this familiar story by making three points. First, we show that in the 1970s, Ruth Bader Ginsburg and the women’s movement argued that the antistereotyping principle applied to pregnancy; the movement viewed the regulation of pregnant women as a paradigmatic site of sex-role stereotyping. Second, we show that even though the Court initially had difficulty seeing that sex role stereotypes were sometimes implicated in cases concerning the regulation of pregnancy, the Court’s constitutional decisions have increasingly come to recognize the relationship between pregnancy discrimination and sex discrimination. Third, we suggest that the Court and other constitutional interpreters should revisit Geduldig and read the decision’s holding more precisely—and narrowly—as recognizing that, while there are legitimate reasons for regulating pregnancy, such regulation can be animated by invidious or traditionally stereotypical judgments. This understanding has implications for both equal protection and reproductive rights cases

Struck by Stereotype: Ruth Bader Ginsburg on Pregnancy Discrimination as Sex Discrimination

It was always recognition that one thing that conspicuously distinguishes women from men is that only women become pregnant; and if you subject a woman to disadvantageous treatment on the basis of her pregnant status, which was what was happening to Captain Struck, you would be denying her equal treatment under the law.(1

Remediasi Kesalahan Menyelesaikan Soal USAha Energi Menggunakan Strategi Systematic Approach To Problem Solving Berbasis Multirepresentasi di SMA

This study aims to determine the effectiveness of remediation using the systematic approach to problem solving strategy based on multiple representations to reduce the number of errors in answering essay test about work and energy in grade XI MIA SMAN 7 Pontianak. The study uses the form of one group pretest-posttest design and the research instrument used is test descriptions that consist of five items. The population in this study is XI MIA students of SMAN 7 Pontianak who have studied about work and energy. Sampling was carried out with the intact group and obtained class XI MIA 3 which consists of 34 students. The analysis showed there was an average decrease in the percentage of the number of errors in answering the test by 59.83% moderate. The study also found the decrease in the number of errors for each student with the highest number in the high category as many as 24 students

Interplay between T Regulatory and T Helper 17 Lymphocytes in Modulation of Immunity to Blood Stage Malaria Infection

Malaria claims millions of lives worldwide each year. While a pro-inflammatory immune response is required to control parasite replication and promote clearance of infected erythrocytes, considerable disease pathology is caused by an excessive and dysregulated inflammatory reactivity to blood stage infection. Clinical symptoms, including fever and chills, correspond to production by CD4+ T helper (Th) lymphocytes of high levels of pro-inflammatory cytokines including tumour necrosis factor-α, interleukin-12 and interferon- γ in response to parasite components released upon erythrocyte rupture. Differentiation into specific effector Th subsets is directed by polarizing cytokines and expression of master transcription factors. From a perspective of homeostasis, further regulatory Th subsets have been described that secrete specific cytokines to modulate the effector immune response and thus play a pivotal role in protecting the body from direct and indirect pathogenic effects of malaria infection. In particular, T regulatory (Treg) lymphocytes are associated with immune tolerance and play a crucial role in suppressing the host response by inhibiting the function of effector subsets such as Th1 and Th17. This prevents inflammation produced downstream by (non-T) effectors cells. Treg lymphocytes, exemplified by CD4+CD25+Foxp3+ cells, gradually increase in number during infection to achieve and maintain the homeostasis of an otherwise imbalanced T cell response. This editorial discusses the production of Treg and Th17 lymphocytes and the interrelated roles played by their signature cytokines during malaria infection and considers the contribution of each to parasite clearance or progression

Infrared and Raman spectroscopic characterization of the hydrogen-bonding network in l-serine crystal

The IR spectra (4000-400 cm-1) of neat and isotopically substituted (ND/OD <= 10% D and [congruent with]30% D) polycrystalline l-serine ([alpha]-amino-[beta]-hydroxypropionic acid; HO-CH2-CH(NH3)+-COO-) were recorded in the temperature range 300-10 K and assigned. The isotopic-doping/low-temperature methodology, which allows for decoupling of individual proton vibrational modes from the crystal bulk vibrations, was used for estimating the lengths and energies of the different H-bonds present in l-serine crystal. To this end, the frequency shifts observed in both the NH/OH stretching and out-of-plane bending spectral regions (relatively to reference values for these vibrations in non-hydrogen-bonded l-serine molecules) were used, together with previously developed empirical correlations between these spectral parameters and the H-bond properties. In addition, the room-temperature Raman spectrum (4000-150 cm-1) of a single crystal of neat l-serine was also recorded and interpreted. A systematic comparison was made between the spectroscopic data obtained currently for l-serine and previously for dl-serine, revealing that the vibrational spectra of the two crystals reflect well the different characteristics of their hydrogen-bond networks, and also correlate accurately with the different susceptibility of the two crystals to pressure-induced strain.http://www.sciencedirect.com/science/article/B6THW-4K4WMR3-2/1/211ac428c09ebc9eb45cf3b81d93fcb