NLRA Preemption of State Law Actions for Wrongful Discharge in Violation of Public Policy

This Note considers the circumstances under which the NLRA should preempt state law tort suits for discharge in contravention of public policy by employees covered by a collective bargaining agreement, and by at-will employees. Part I discusses the rationale behind the preemption doctrine and outlines the tests the Supreme Court has adopted for determining when the NLRA preempts state laws. Part II argues that the specific rationale behind the Court\u27s preemption tests are inapplicable to the typical public policy wrongful discharge action. Part III identifies the ways in which public policy wrongful discharge actions might infringe on the NLRA. It proposes a preemption test that courts should use to determine when the NLRA preempts these actions. Finally, Part IV applies this test to various types of wrongful discharge actions by at-will and union employees. It concludes that the NLRA does not preempt certain types of actions for wrongful discharge in violation of public policy

Isolation of Nuclei from Physarum flavicomum: Demonstration of Nuclear Cyclic Acid AMP Phosphodiesterase

Cyclic AMP phosphodiesterase activity in the nucleus of the myxomycete Physarum flavicomum was demonstrated by cytochemical staining utilizing electron microscopy and by enzymatic assays with tritiated cyclic AMP as the substrate. Cytochemical staining showed Physarum\u27s plasmodial phosphodiesterase activity to be located in the nucleus, along the plasma membrane, in vesicles, and free in the cytoplasm. Nuclear phosphodiesterase, which may be cell cycle dependent, was primarily located in the nucleolus. Nuclei from three to five day old microplasmodial cultures were isolated by the method of Henney and Yee. Whole cells were collected through centrifugation and washed. Pellets were homogenized in a medium composed of 0.01 MTris-HC1 (pH 7.2 at 4 °C), 0.25 M sucrose, 0.01% Triton X-100, and 5mM CaC1₂. Nuclei were collected through double filtration and two 1.0 M sucrose density gradient centrifugations. After the nuclei were washed, microscopic examination revealed a purity of over 90%. Radioactive assays of the nuclear preparations demonstrated phosphodiesterase activity consistant with that indicated by cytochemical localization. The specific activity of the nuclear enzyme was 15 nMole of cyclic AMP hydrolyzed /min/mg. of protein

The Effect of a Mini-Conference on Teacher Beliefs About the Reading Process

The present study was undertaken to appraise the degree to which teacher beliefs about the reading process might be updated through attendance at a weekend mini-conference. The mini-conference focused on classroom application of findings from contemporary psycholinguistic research

Assessment of Scale-Loss to Atlantic Salmon (Salmo Salar L.) Smolts from Passage Through an Archimedean Screw Turbine

The potential for external damage to Atlantic salmon (Salmo salar L.) smolts from passage through an Archimedean screw turbine was tested with controlled field trials at two turbine speeds. Change in external condition of smolts was measured by grading photographs of individual fish for scale-loss before and after the tests. Results were compared between turbine-passed and control smolts. There were no significant differences in proportions of fish with new scale-loss between treatment and control smolts. New scale-loss of between 4 and 30% was seen in 7.46% of turbine-passed smolts, exceeding the prevalence in control smolts by 2.46%. Of these, 1.49% had minor scale-loss of 5-9%. Minor scale-loss was more prevalent for both groups at the faster turbine speed, although differences between treatment and control groups were more apparent at the slower speed

Can We Update Experienced Teachers\u27 Beliefs and Practices in Reading?

A recent review charting the impact of educational research on classroom teaching found that teaching practices, particularly in reading, were rarely modified to reflect current research findings (Clifford, 1973). Clifford chronicled the fragmentary, one short nature of much of the educational research produced and reported over the last fifty years. He suggested that a more unified body of cumulative research findings in a cohesive area of investigation might stand a better chance of influencing change in the classroom

Reasoning Guides for Critical Comprehension

We will describe here a process for using classroom media as powerful interactive sources of information that enhance students\u27 critical comprehension

Reasoning Guides: Fostering Reading in Content Areas

There is little doubt that a student stands a good chance of comprehending difficult content area material when actual life experiences can be related to an author\u27s intent. The importance of a reader\u27s prior knowledge and experiences in the meaningful reception, integration, and retention of new concepts is a widely held precept in learning theory (Ausubel, 1968; Smith, 1978)

Development of the judicial definition of materiality

Determining what should be considered a material item has been a problem for both the accounting profession and the courts. By reviewing the court cases involving the issue of materiality, the authors have determined where differences in the materiality standard as applied by the courts exist. The judicial definition of materiality has developed over time, and current trends with important variations are observed. Based upon the authors\u27 analysis, the following judicial definition of materiality, with its possible variations, is suggested: Would the reasonable (or speculative) investor (or layman) consider important (or be influenced by) this information in determining his course of action

Session E9: Migration of Atlantic Salmon (Salmo Salar) at Low-Head Archimedean Screw Hydropower Schemes

Abstract: There has been a rapid increase in development of small-scale hydropower schemes across Europe. Such schemes may impact upon migratory fish populations through modification of migration pathways. There is a clear need for scientific evidence to inform guidelines for the design, placement and management of small-scale hydropower schemes for the protection of migratory fish. The proliferation of the Archimedean screw turbine (AST) for lowhead applications is concerning because although these turbines are purported to cause negligible damage to fish passing through them, the available data is limited. The studies presented assess the impacts of low-head AST hydropower schemes on migrating populations of anadromous Atlantic salmon (Salmo salar) in Scotland. Smolts were tracked through an AST hydropower scheme on the river Don using radio tags and passive integrated transponder (PIT) tags. Smolt movements through alternative passage routes were observed using an array of fixed loggers at the hydro scheme. The proportion of radio tagged fish which passed through the turbine was 27% (7/26). The majority of PIT tagged smolts passed through the turbine channel within 27 minutes. Passage behaviour is considered in the context of the scheme’s operation and environmental conditions. Adult fish were tracked using radio and PIT tags at three AST hydropower schemes with distinctive designs and operational regimes: on the middle reaches of the river Don, the upper reaches of the Don, and on the Ettrick water. A mixture of fine-scale radio detection zones and PIT antennas was used to investigate attraction to the competing flows at each of the turbine and fish pass or depleted stretch outflows, and the efficiency and efficacy of the fish pass. Behaviours at these regions are related to the turbine operation, scheme layout and the resulting hydrodynamics at the regions of interest