I Pronounce You Man and Man. You May Now File Jointly for Bankruptcy: DOMA\u27s Unconstitutionality and Its Effect on Joint Bankruptcy Filings for Same-Sex Couples

Windsor v. United States marked the erosion of the Defense of Marriage Act of 1996. Post-Windsor, the operative definition sections of that Act\u27defining \u27marriage\u27 and \u27spouse\u27 for \u27any Act of Congress\u27\u27no longer control. The meaning of marriage and spouse under federal law and, specifically, the Bankruptcy Code is now unclear. This Article argues that lawfully married same-sex couples should be allowed to file for bankruptcy jointly under 11 U.S.C. § 302 in all bankruptcy courts, even if the couple files jointly in a state that does not recognize their union. Under federalism principles, the Bankruptcy Code should apply the definitions of marriage and spouse from the state of celebration to provide same-sex couples equal access to the federal bankruptcy system. This Article proposes an interpretive framework that permits same-sex couples to file for bankruptcy jointly in any state while leaving state-level restrictions on marriages between same-sex couples untouched

Whitebark Pine as a Foundation and Keystone Species: Functional Roles and Community Interactions

Whitebark pine (Pinus albicaulis), a non-commercial five-needle white pine (Family Pinaceae, Subgenus Strobus), and the only North American stone pine (Subsection Cembrae), inhabits upper subalpine and treeline zones throughout the western United States and Canada. The most northerly in distribution of western North American white pines, it occurs across 18∞ of latitude and 21∞ of longitude, and comprises diverse community types--successional, climax, and treeline, mesic to xeric, and pure to mixed associations. Studies within the last three decades have elucidated a unique ecology for whitebark pine, derived in part from obligate seed dispersal by Clarkís nutcrackers, but also from its multiple functional roles. These roles include facilitating community development after fire, acting as a nurse tree on harsh sites, and protracting snow melt at treeline, thus regulating downstream flows. Whitebark pine seeds are an important wildlife food for granivorous birds and mammals, including black bears and grizzly bears in the Greater Yellowstone Area and elsewhere. Whitebark pine may be considered both a foundation and a keystone species for promoting regional biodiversity, influencing ecosystem processes, and facilitating community development and stability. Furthermore, in some treeline ecosystems, whitebark pine is the most frequent conifer to initiate formation of tree islands, which in turn may facilitate treeline response to climate change. Whitebark pine communities are experiencing dramatic declines as a result of widespread infection by the non-native fungal pathogen Cronartium ribicola, which causes white pine blister rust, advancing succession from fire suppression, and widespread outbreaks of mountain pine beetles (Dendroctonus ponderosae), particularly in the Greater Yellowstone Ecosystem. Furthermore, climate change is predicted to result in range shifts for whitebark pine both to higher elevations and more northern latitudes. As whitebark pine declines as a functional component in subalpine and treeline ecosystems, the resulting structural and functional changes in communities may have multiple effects, particularly on regional biodiversity

The Effects Of Prophylactic Probiotic Use On Reducing Group B Streptococcus Colonization In Pregnant People

Group B Streptococcus (GBS) is a gram-positive coccus that normally colonizes the digestive and genital tract (Puopolo & Madoff, 2023). Worldwide, approximately 18% of pregnant people[1] carry GBS, and in the United States of America (USA), approximately 25% of pregnant people are GBS positive (Center for Disease Control and Prevention, 2022). GBS can be passed onto an infant during birth when it travels through the vaginal canal, a process called vertical transmission. Unfortunately, for newborns who have an immature immune system, GBS can result in early onset GBS disease requiring a lengthy stay in the NICU or even death. Currently, in the USA, the treatment for pregnant people positive for GBS is intravenous antibiotics during labor, which reduces the risk of vertical transmission (Baker, 2023). While effective at decreasing GBS, the systemic antibiotics wipe out beneficial bacteria throughout the body and, most importantly for pregnant people, the genital tract. As a result, both the pregnant person’s and infant’s microbiome are negatively impacted, thereby subjecting them to other infections. Because of the negative effects of antibiotics, researchers have explored alternative treatments to reduce GBS colonization. One such alternative is using prophylactic probiotics during pregnancy, which is the question discussed here. [1] For the purpose of this paper, pregnant persons/people are those who are assigned female at birth regardless of gender presentation

Whitebark Pine Stand Condition, Tree Abundance, and Cone Production as Predictors of Visitation by Clark's Nutcracker

Accurately quantifying key interactions between species is important for developing effective recovery strategies for threatened and endangered species. Whitebark pine (Pinus albicaulis), a candidate species for listing under the Endangered Species Act, depends on Clark's nutcracker (Nucifraga columbiana) for seed dispersal. As whitebark pine succumbs to exotic disease and mountain pine beetles (Dendroctonus ponderosae), cone production declines, and nutcrackers visit stands less frequently, reducing the probability of seed dispersal.We quantified whitebark pine forest structure, health metrics, and the frequency of nutcracker occurrence in national parks within the Northern and Central Rocky Mountains in 2008 and 2009. Forest health characteristics varied between the two regions, with the northern region in overall poorer health. Using these data, we show that a previously published model consistently under-predicts the proportion of survey hours resulting in nutcracker observations at all cone density levels. We present a new statistical model of the relationship between whitebark pine cone production and the probability of Clark's nutcracker occurrence based on combining data from this study and the previous study.Our model clarified earlier findings and suggested a lower cone production threshold value for predicting likely visitation by nutcrackers: Although nutcrackers do visit whitebark pine stands with few cones, the probability of visitation increases with increased cone production. We use information theoretics to show that beta regression is a more appropriate statistical framework for modeling the relationship between cone density and proportion of survey time resulting in nutcracker observations. We illustrate how resource managers may apply this model in the process of prioritizing areas for whitebark pine restoration

Invasive Pathogen Threatens Bird-Pine Mutualism: Implications for Sustaining a High-Elevation Ecosystem

Human-caused disruptions to seed-dispersal mutualisms increase the extinction risk for both plant and animal species. Large-seeded plants can be particularly vulnerable due to highly specialized dispersal systems and no compensatory regeneration mechanisms. Whitebark pine ( Pinus albicaulis), a keystone subalpine species, obligately depends upon the Clark\u27s Nutcracker (Nucifraga columbiana) for dispersal of its large, wingless seeds. Clark\u27s Nutcracker, a facultative mutualist with whitebark pine, is sensitive to rates of energy gain, and emigrates from subalpine forests during periods of cone shortages. The invasive fungal pathogen Cronartium ribicola, which causes white pine blister rust, reduces whitebark pine cone production by killing cone-bearing branches and trees. Mortality from blister rust reaches 90% or higher in some whitebark pine forests in the Northern Rocky Mountains, USA, and the rust now occurs nearly rangewide in whitebark pine. Our objectives were to identify the minimum level of cone production necessary to elicit seed dispersal by nutcrackers and to determine how cone production is influenced by forest structure and health. We quantified forest conditions and ecological interactions between nutcrackers and whitebark pine in three Rocky Mountain ecosystems that differ in levels of rust infection and mortality. Both the frequency of nutcracker occurrence and probability of seed dispersal were strongly related to annual whitebark pine cone production, which had a positive linear association with live whitebark pine basal area, and negative linear association with whitebark pine tree mortality and rust infection. From our data, we estimated that a threshold level of similar to 1000 cones/ha is needed for a high likelihood of seed dispersal by nutcrackers ( probability \u3e= 0.7), and that this level of cone production can be met by forests with live whitebark pine basal area \u3e5.0 m(2)/ha. The risk of mutualism disruption is greatest in northernmost Montana ( USA), where three-year mean cone production and live basal area fell below predicted threshold levels. There, nutcracker occurrence, seed dispersal, and whitebark pine regeneration were the lowest of the three ecosystems. Managers can use these threshold values to differentiate between restoration sites requiring planting of rust-resistant seedlings and sites where nutcracker seed dispersal can be expected