A Jurisprudential Quilt of Tribal Civil Jurisdiction: An Analysis of Tribal Court Approaches to Determining Civil Adjudicatory Jurisdiction

In 1998, Tammy Lang embezzled approximately $8,000 from the Ho-Chunk Nation’s child daycare. Lang was a non-Indianemployed by the tribe as the Director for the Ho-Chunk Nation’s Head Start program. However, instead of supporting the children of the tribe, she abused her position to steal the tribe’s money to start her own business. The FBI declined to prosecute Lang, and the Ho-Chunk Nation could not prosecute Lang. As a result, the Ho-Chunk Nation was left with few choices: it could let this injustice stand; it could attempt recovery in state or federal court, subjecting itself to the laws of another sovereign; or the Ho-Chunk Nation could assert its sovereignty and sue Lang in its own courts.The Ho-Chunk Nation sued Lang for civil conversion in its own courts. Before the Ho-Chunk Tribal Court could render a verdict against Lang, the court had to determine it had jurisdiction, both subject-matter jurisdiction and personal jurisdiction. The Ho-Chunk Nation’s Tribal Court based subject-matter jurisdiction on the personnel manual Lang signed, which acts as the Nation’s employment law, and on Lang violating the laws and the constitution of the Nation.The court based personal jurisdiction on Lang’s employment by the nation and the mutually consented to relationship. The Ho-Chunk Nation Trial Court ordered Tammy Lang to return to the Tribe the embezzled funds and to “repay the Nation for its attorney fees for each hearing appearance.

PALEOECOLOGY AND FUNCTIONAL MORPHOLOGY OF THE PERMIAN LYTTONIID BRACHIOPOD PIRGULIA

The lyttoniid brachiopods of the Permian exhibit a unique valve morphology: a branched lobate structure takes the form of the dorsal valve. In one group of lyttoniids, the genus Pirgulia, the ventral valve wraps around to form a cone that fully encloses the lobate structure. This has consequences for the dynamics of water flow and mode of life possible for these heteromorphic brachiopods. Here, we describe the skeletal microstructure and morphology of Pirgulia collected from the Upper Permian Sosio Limestone megablocks of Sicily and housed at the Yale Peabody Museum. We reconstruct the paleoecology of Pirgulia, characterizing it as semi-infaunal in soft sediment. By analogy to Richthofenia, the conical ventral valve and flapping dorsal valve functional morphology could have resisted fouling and assisted feeding in this environment. By comparison with the functional morphology of Pirgulia with other lyttoniids and richthofenids, we propose a revised mode of life for this genus, which involves adaptation to secondary soft-bottom substrates and support by sediment sticking. Despite constraints to the fundamental brachiopod body plan, modification of the valves in Pirgulia to achieve a conical morphology allowed it to inhabit a paleoecological niche distinct from that of other reef-building lyttoniids

Health Insurance Exchanges: Legal Issues

Health insurance exchanges (HIE) are entities that organize the market for health insurance by connecting small businesses and individuals into larger pools that spread the risk for insurance companies, while facilitating the availability, choice and purchase of private health insurance for the uninsured. While there are legal issues that warrant consideration under a federal, state, or private exchange framework, those issues are not insurmountable barriers to implementation

IgE-Mediated Hypersensitivity Reactions to Cannabis in Laboratory Personnel

Background: There have been sporadic reports of hypersensitivity reactions to plants of the Cannabinaceae family (hemp and hops), but it has remained unclear whether these reactions are immunologic or nonimmunologic in nature. Objective: We examined the IgE-binding and histamine-releasing properties of hashish and marijuana extracts by CAP-FEIA and a basophil histamine release test. Methods: Two workers at a forensic laboratory suffered from nasal congestion, rbinitis, sneezing and asthmatic symptoms upon occupational contact with hashish or marijuana, which they had handled frequently for 25 and 16 years, respectively. Neither patient had a history of atopic disease. Serum was analyzed for specific IgE antibodies to hashish or marijuana extract by research prototype ImmunoCAP, and histamine release from basophils upon exposure to hashish or marijuana extracts was assessed. Results were matched to those of 4 nonatopic and 10 atopic control subjects with no known history of recreational or occupational exposure to marijuana or hashish. Results: Patient 1 had specific IgE to both hashish and marijuana (CAP class 2), and patient 2 to marijuana only (CAP class 2). Controls proved negative for specific IgE except for 2 atopic individuals with CAP class 1 to marijuana and 1 other atopic individual with CAP class 1 to hashish. Stimulation of basophils with hashish or marijuana extracts elicited histamine release from basophils of both patients and 4 atopic control subjects. Conclusions: Our results suggest an IgE-related pathomechanism for hypersensitivity reactions to marijuana or hashish. Copyright (C) 2011 S. Karger AG, Base

Adjuvanted recombinant zoster vaccine in adult autologous stem cell transplant recipients : polyfunctional immune responses and lessons for clinical practice

PLAIN LANGUAGE SUMMARY What is the context? After haematopoletic stem cell transplantation, patlents have impaired immunity from conditioning chemotherapy regimens, often exacerbated by underlying diseases, putting them at high risk of developing herpes zoster. In this population, antiviral prophylaxis is the current standard of care to reduce herpes zoster risk. Vaccination provides an additional means to prevent herpes zoster. Live-attenuated vaccines are generally contraindicated in immuonocompromised patients. A non-live, adjuvanted recombinant zoster vaccine (RZV, Shingrix, GSK), has been approved for use in adults 250 years of age in the European Union, United States, Canada, Australia, Japan, and China. This vaccine is highly efficacious at preventing herpes zoster in adults over 50 years of age, as demonstrated in large, placebo-controlled randomised trials. Importantly, Shingrix use is not contraindicated in immunocompromised conditions, and was found to be highly efficacious in adults who had recently undergone autologous haematopoleticstem cell transplant. What is new? In autologous haematopoietic stem cell transplant recipients in whom Shingrix has demonstrated efficacy, two doseselicited high and persistent immune responses. Date presented here further support our understanding of the impact of specific factors such as age or underlying diseases on the vaccine's effect in the population studies, as well as the characteristics of the elicited cell-mediated immune responses. What is the impact? These results indicate that Shingrix, given shortly after haematopoletic stem cell transplant, can induce robust immune responses and reduce the risk of herpes zoster, even in individuals with immunosuppression due to underlying disease and/or use of immunosuppressive therapies, regardless of age or underlying disease. Immunocompromised individuals, particularly autologous hematopoietic stem cell transplant (auHSCT) recipients, are at high risk for herpes zoster (HZ). We provide an in-depth description of humoral and cell-mediated immune (CMI) responses by age (protocol-defined) or underlying disease (post-hoc) as well as efficacy by underlying disease (post-hoc) of the adjuvanted recombinant zoster vaccine (RZV) in a randomized observer-blind phase III trial (ZOE-HSCT, NCT01610414). 1846 adult auHSCT recipients were randomized to receive a first dose of either RZV or placebo 50-70 days post-auHSCT, followed by the second dose at 1-2 months (M) later. In cohorts of 114-1721 participants, at 1 M post-second vaccine dose: Anti-gE antibody geometric mean concentrations (GMCs) and median gE-specific CD4[2+] T-cell frequencies (CD4 T cells expressing >= 2 of four assessed activation markers) were similar between 18-49 and >= 50-year-olds. Despite lower anti-gE antibody GMCs in non-Hodgkin B-cell lymphoma (NHBCL) patients, CD4[2+] T-cell frequencies were similar between NHBCL and other underlying diseases. The proportion of polyfunctional CD4 T cells increased over time, accounting for 79.6% of gE-specific CD4 T cells at 24 M post-dose two. Vaccine efficacy against HZ ranged between 42.5% and 82.5% across underlying diseases and was statistically significant in NHBCL and multiple myeloma patients. In conclusion, two RZV doses administered early post-auHSCT induced robust, persistent, and polyfunctional gE-specific immune responses. Efficacy against HZ was also high in NHBCL patients despite the lower humoral response.Peer reviewe

Acute Cholecystitis Is a Common Complication after Allogeneic Stem Cell Transplantation and Is Associated with the Use of Total Parenteral Nutrition

AbstractThe incidence and risk factors for acute cholecystitis after allogeneic hematopoietic stem cell transplantation (HSCT) are not well defined. Of 644 consecutive adult transplants performed at our institution between 2001 and 2011, acute cholecystitis occurred in the first year of transplant in 32 patients (5.0%). We conducted 2 retrospective case-control studies of this population to determine risk factors for cholecystitis after HSCT and to evaluate the performance of different methods of imaging to diagnosis cholecystitis in patients undergoing HSCT compared with non-HSCT patients. In the HSCT population, development of cholecystitis was associated with an increased 1-year overall mortality rate (62.5% versus 19.8%, P < .001). The risk of developing cholecystitis was higher in patients who received total parenteral nutrition (TPN) (adjusted odds ratio, 3.41; P = .009). There was a trend toward more equivocal abdominal ultrasound findings in HSCT recipients with acute cholecystitis compared with nontransplant patients (50.0% versus 30.6%, P = .06). However, hepatobiliary iminodiacetic acid (HIDA) scans were definitively positive for acute cholecystitis in most patients in both populations (80.0% of HSCT recipients versus 77.4% of control subjects, P = .82). In conclusion, acute cholecystitis is a common early complication of HSCT, the risk is increased in patients who receive TPN, and it is associated with high 1-year mortality. In HSCT recipients with findings suggestive of acute cholecystitis, especially those receiving TPN, early use of HIDA scan may be considered over ultrasound

Insulin stimulated protein phosphorylation in human plasma liver membranes: Detection of endogenous or plasma membrane associated substrates for insulin receptor kinase

The present work discloses a procedure for preparation of human liver plasma membranes containing catalytically competent insulin receptor kinase. In addition to insulin promoted phosphorylation of the [beta]-subunit of insulin receptor kinase, insulin promoted phosphorylation of pp120 and two other new proteins was demonstrated. The new proteins with molecular weights of 50,000 and 120,000 do not bind to WGA, pp120 antibody or insulin receptor antibody, but bind to the antiphosphotyrosyl antibody. The identity and physiological significance of these putative substrates for insulin receptor kinase remains to be established.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/26468/1/0000003.pd