Race at the Pivot Point: The Future of Race-Based Policies to Remedy De Jure Segregation After Parents Involved in Community Schools

This article examines the perhaps unintended consequences of changing legal doctrine. Most commentary on the U.S. Supreme Court Parents Involved in Community Schools (“PICS”) decision explores PICS’ impact upon voluntary race-based policies to remedy unintentional de facto racial segregation. In contrast, this analysis explores PICS’ impact upon mandatory race-based policies to remedy government-sponsored de jure racial segregation. After PICS, the Fourteenth Amendment’s essence and character can turn on a finding of unitary status, a purely factual and somewhat subjective determination reviewable only for clear error. Under the Equal Protection Clause, a school district found to operate a de jure segregated school system may be forced to use race-based policies to undo the effects of such segregation. The instant, however, that a district judge signs the court order granting that school district unitary status, the Equal Protection Clause then forbids the school district from using the identical race-based policies to address the effects of de facto segregation. PICS thus has injected into the Equal Protection Clause’s schizophrenic identity a never-before-seen wrinkle called a pivot point.The pivot point arises when school systems constitutionally required to use race-based policies to remedy de jure segregation become constitutionally prohibited from using the same race-based policies to address de facto segregation voluntarily. After exploring PICS’ effect on de jure school systems’ legal obligations, we explore the ramifications of a constitutional standard that abruptly transforms legal obligations on the basis of a subjective factual determination. This pivot point may induce bizarre effects in familiar legal processes, with unpredictable consequences. In its zeal to alter Brown v. Board of Education’s legacy, the PICS majority overlooked the structural impact of its decision on de jure systems governed by a very different vision of the Equal Protection Clause. The resulting pivot point is a testament to the dangers of parsing individual rights too finely at the expense of maintaining stability in legal structure and process

Developmental Regulation of Hepatitis B Virus Biosynthesis by Hepatocyte Nuclear Factor 4α

The host cellular factors that promote persistent viral infections in vivo are, in general, poorly understood. Utilizing the hepatitis B virus (HBV) transgenic mouse model of chronic infection, we demonstrate that the nuclear receptor, hepatocyte nuclear factor 4α (HNF4α, NR2A1), is essential for viral biosynthesis in the liver. The dependency of HBV transcription on HNF4α links viral biosynthesis and persistence to a developmentally regulated transcription factor essential for host viability

Systems Integration of Biodefense Omics Data for Analysis of Pathogen-Host Interactions and Identification of Potential Targets

The NIAID (National Institute for Allergy and Infectious Diseases) Biodefense Proteomics program aims to identify targets for potential vaccines, therapeutics, and diagnostics for agents of concern in bioterrorism, including bacterial, parasitic, and viral pathogens. The program includes seven Proteomics Research Centers, generating diverse types of pathogen-host data, including mass spectrometry, microarray transcriptional profiles, protein interactions, protein structures and biological reagents. The Biodefense Resource Center (www.proteomicsresource.org) has developed a bioinformatics framework, employing a protein-centric approach to integrate and support mining and analysis of the large and heterogeneous data. Underlying this approach is a data warehouse with comprehensive protein + gene identifier and name mappings and annotations extracted from over 100 molecular databases. Value-added annotations are provided for key proteins from experimental findings using controlled vocabulary. The availability of pathogen and host omics data in an integrated framework allows global analysis of the data and comparisons across different experiments and organisms, as illustrated in several case studies presented here. (1) The identification of a hypothetical protein with differential gene and protein expressions in two host systems (mouse macrophage and human HeLa cells) infected by different bacterial (Bacillus anthracis and Salmonella typhimurium) and viral (orthopox) pathogens suggesting that this protein can be prioritized for additional analysis and functional characterization. (2) The analysis of a vaccinia-human protein interaction network supplemented with protein accumulation levels led to the identification of human Keratin, type II cytoskeletal 4 protein as a potential therapeutic target. (3) Comparison of complete genomes from pathogenic variants coupled with experimental information on complete proteomes allowed the identification and prioritization of ten potential diagnostic targets from Bacillus anthracis. The integrative analysis across data sets from multiple centers can reveal potential functional significance and hidden relationships between pathogen and host proteins, thereby providing a systems approach to basic understanding of pathogenicity and target identification

Genome of Diuraphis noxia, a global aphid pest of small grains

Background: The Russian wheat aphid, Diuraphis noxia Kurdjumov, is one of the most important pests of small grains throughout the temperate regions of the world. This phytotoxic aphid causes severe systemic damage symptoms in wheat, barley, and other small grains as a direct result of the salivary proteins it injects into the plant while feeding.Results: We sequenced and de novo assembled the genome of D. noxia Biotype 2, the strain most virulent to resistance genes in wheat. The assembled genomic scaffolds span 393 MB, equivalent to 93% of its 421 MB genome, and contains 19,097 genes. D. noxia has the most AT-rich insect genome sequenced to date (70.9%), with a bimodal CpG(O/E) distribution and a complete set of methylation related genes. The D. noxia genome displays a widespread, extensive reduction in the number of genes per ortholog group, including defensive, detoxification, chemosensory, and sugar transporter groups in comparison to the Acyrthosiphon pisum genome, including a 65% reduction in chemoreceptor genes. Thirty of 34 known D. noxia salivary genes were found in this assembly. These genes exhibited less homology with those salivary genes commonly expressed in insect saliva, such as glucose dehydrogenase and trehalase, yet greater conservation among genes that are expressed in D. noxia saliva but not detected in the saliva of other insects. Genes involved in insecticide activity and endosymbiont-derived genes were also found, as well as genes involved in virus transmission, although D. noxia is not a viral vector.Conclusions: This genome is the second sequenced aphid genome, and the first of a phytotoxic insect. D. noxia's reduced gene content of may reflect the influence of phytotoxic feeding in shaping the D. noxia genome, and in turn in broadening its host range. The presence of methylation-related genes, including cytosine methylation, is consistent with other parthenogenetic and polyphenic insects. The D. noxia genome will provide an important contrast to the A. pisum genome and advance functional and comparative genomics of insects and other organisms.Peer reviewedBiochemistry and Molecular Biolog

Evidence-Based Federal Civil Rulemaking: A New Contemporaneous Case Coding Rule

This Article proposes a new Federal Rule concerning the federal courts’ online case management/electronic case filing system (CM/ECF). Whenever a party, the court clerk, or the presiding judge in a civil lawsuit electronically files a document, the Model Rule requires her to answer standardized online questions about that document. These questions are limited to indisputable factual information about case-related outcomes. By answering these questions, the filer codes research variables contemporaneously with the filing of every document. Such mandatory contemporaneous coding would provide comprehensive, reliable, and inexpensive descriptive empirical data6 for evidence-based rulemaking. This Federal Courts CM/ECF Descriptive Dataset should be publicly available. Part I of this article explains why evidence-based policymaking needs not only objective descriptive data to provide a universal baseline for policy evaluation but also a paradigm shift in the way evidence is viewed and used in policymaking. Part II reviews the history of empirical research of federal civil rulemaking from its humble beginning, through its acceptance and institutionalization, to today’s so-called “New Legal Realist” or “Empirical Legal Studies” movement. Part III summarizes the CM/ECF revolution in the federal courts and explains how contemporaneous coding can code more federal cases at less cost than current methods. Finally, Part IV explains the proposed empirical coding Model Rule and provides sample coding outcomes