Chipping Away : The Misguided Trend Toward Resolving Merits Disputes as Part of the Class Certification Calculus

This Article traces the development of class certification by several circuit courts to embrace merits scrutiny at the class certification stage and critically examines the jurisprudential principles motivating it

Particulate and water-soluble carbon measured in recent snow at Summit, Greenland

Water-soluble organic carbon (WSOC), waterinsoluble particulate organic carbon (WIOC), and particulate elemental carbon (EC) were measured simultaneously for the first time on the Greenland Ice Sheet in surface snow and in a 3-meter snow pit. Snow pit concentrations reveal that, on average, WSOC makes up the majority (89%) of carbonaceous species, followed by WIOC (10%) and EC (1%). The enhancement of OC relative to EC (ratio 99:1) in Greenland snow suggests that, along with atmospheric particulate matter, gaseous organics contribute to snow-phase OC. Comparison of summer surface snow concentrations in 2006 with past summer snow pit layers (2002 – 2005) found a significant depletion in WSOC (20 – 82%) and WIOC (46 – 65%) relative to EC for 3 of the 4 years. The apparent substantial loss of WSOC and WIOC in aged snow suggests that post-depositional processes, such as photochemical reactions, need to be considered in linking ice core records of organics to atmospheric concentrations. Citation: Hagler, G. S. W., M. H. Bergin, E. A. Smith, J. E. Dibb, C. Anderson, and E. J. Steig (2007), Particulate and water-soluble carbon measured in recent snow at Summit, Greenland, Geophys. Res. Lett., 34, L16505, doi:10.1029/2007GL030110

Warming of the Antarctic ice-sheet surface since the 1957 International Geophysical Year

Assessments of Antarctic temperature change have emphasized the contrast between strong warming of the Antarctic Peninsula and slight cooling of the Antarctic continental interior in recent decades. This pattern of temperature change has been attributed to the increased strength of the circumpolar westerlies, largely in response to changes in stratospheric ozone. This picture, however, is substantially incomplete owing to the sparseness and short duration of the observations. Here we show that significant warming extends well beyond the Antarctic Peninsula to cover most of West Antarctica, an area of warming much larger than previously reported. West Antarctic warming exceeds 0.1 °C per decade over the past 50 years, and is strongest in winter and spring. Although this is partly offset by autumn cooling in East Antarctica, the continent-wide average near-surface temperature trend is positive. Simulations using a general circulation model reproduce the essential features of the spatial pattern and the long-term trend, and we suggest that neither can be attributed directly to increases in the strength of the westerlies. Instead, regional changes in atmospheric circulation and associated changes in sea surface temperature and sea ice are required to explain the enhanced warming in West Antarctica