Summary of San Juan v. PSC Industrial Outsourcing, 126 Nev. Adv. Op. 35

The Supreme Court affirmed the district court’s summary judgment ruling in favor of PSC as to third party vicarious liability for the torts of an independent contractor. Specifically, the court held PSC, as hirer of independent contractor DTI, was not liable under the peculiar risk doctrine regardless of whether the independent contractor was incompetent or insolvent

A Precise Estimate of the Radius of HD 149026b

We present Spitzer 8 micron transit observations of the extrasolar planet system HD 149026. At this wavelength, transit light curves are weakly affected by stellar limb-darkening, allowing for a simpler and more accurate determination of planetary parameters. We measure a planet-star radius ratio of R_p/R_s = 0.05158 +/- 0.00077, and in combination with ground-based data and independent constraints on the stellar mass and radius, we derive an orbital inclination of i = 85.4 +0.9/-0.8 deg. and a planet radius of 0.755 +/- 0.040 Jupiter radii. These measurements further support models in which the planet is greatly enriched in heavy elements.Comment: To appear in the Proceedings of the 253rd IAU Symposium: "Transiting Planets", May 2008, Cambridge, M

Resolving the Surfaces of Extrasolar Planets With Secondary Eclipse Light Curves

We present a method that employs the secondary eclipse light curves of transiting extrasolar planets to probe the spatial variation of their thermal emission. This technique permits an observer to resolve the surface of the planet without the need to spatially resolve its central star. We evaluate the feasibility of this technique for the HD 209458 system [..]. We consider two representations of the planetary thermal emission; a simple model parameterized by a sinusoidal dependence on longitude and latitude, as well as the results of a three-dimensional dynamical simulation of the planetary atmosphere previously published by Cooper & Showman. We find that observations of the secondary eclipse light curve are most sensitive to a longitudinal offset in the geometric and photometric centroids of the hemisphere of the planet visible near opposition. To quantify this signal, we define a new parameter, the ``uniform time offset,'' which measures the time lag between the observed secondary eclipse and that predicted by a planet with a uniform surface flux distribution. We compare the predicted amplitude of this parameter for HD 209458 with the precision with which it could be measured with IRAC. We find that IRAC observations at 3.6um a single secondary eclipse should permit sufficient precision to confirm or reject the Cooper & Showman model of the surface flux distribution for this planet. We quantify the signal-to-noise ratio for this offset in the remaining IRAC bands (4.5um, 5.8um, and 8.0um), and find that a modest improvement in photometric precision (as might be realized through observations of several eclipse events) should permit a similarly robust detection.Comment: AASTeX 5.2, 24 pages, 5 figures, accepted for publication in ApJ; v2: clarifications, updated to version accepted by ApJ; v3: try to reduce spacin

The EVIL-MC Model for Ellipsoidal Variations of Planet-Hosting Stars and Applications to the HAT-P-7 System

We present a new model for Ellipsoidal Variations Induced by a Low-Mass Companion, the EVIL-MC model. We employ several approximations appropriate for planetary systems to substantially increase the computational efficiency of our model relative to more general ellipsoidal variation models and improve upon the accuracy of simpler models. This new approach gives us a unique ability to rapidly and accurately determine planetary system parameters. We use the EVIL-MC model to analyze Kepler Quarter 0-2 (Q0-2) observations of the HAT-P-7 system, an F-type star orbited by a nearly Jupiter-mass companion. Our analysis corroborates previous estimates of the planet-star mass ratio q = (1.10 +/- 0.06) x 10^(-3), and we have revised the planet's dayside brightness temperature to 2680 +10/-20 K. We also find a large difference between the day- and nightside planetary flux, with little nightside emission. Preliminary dynamical+radiative modeling of the atmosphere indicates this result is qualitatively consistent with high altitude absorption of stellar heating. Similar analyses of Kepler and CoRoT photometry of other planets using EVIL-MC will play a key role in providing constraints on the properties of many extrasolar systems, especially given the limited resources for follow-up and characterization of these systems. However, as we highlight, there are important degeneracies between the contributions from ellipsoidal variations and planetary emission and reflection. Consequently, for many of the hottest and brightest Kepler and CoRoT planets, accurate estimates of the planetary emission and reflection, diagnostic of atmospheric heat budgets, will require accurate modeling of the photometric contribution from the stellar ellipsoidal variation.Comment: Accepted to ApJ; minor revisions to original submission; An IDL version of the EVIL-MC model is publicly available at http://www.lpl.arizona.edu/~bjackson/idl_code/index.htm

Near-Infrared Thermal Emission from TrES-3b: A Ks-band detection and an H-band upper limit on the depth of the secondary eclipse

We present H and Ks-band photometry bracketing the secondary eclipse of the hot Jupiter TrES-3b using the Wide-field Infrared Camera on the Canada-France-Hawaii Telescope. We detect the secondary eclipse of TrES-3b with a depth of 0.133+/-0.017% in Ks-band (8-sigma) - a result in sharp contrast to the eclipse depth reported by de Mooij & Snellen. We do not detect its thermal emission in H-band, but place a 3-sigma limit on the depth of the secondary eclipse in this band of 0.051%. A secondary eclipse of this depth in Ks requires very efficient day-to-nightside redistribution of heat and nearly isotropic reradiation, conclusion that is in agreement with longer wavelength, mid-infrared Spitzer observations. Our 3-sigma upper-limit on the depth of our H-band secondary eclipse also argues for very efficient redistribution of heat and suggests that the atmospheric layer probed by these observations may be well homogenized. However, our H-band upper limit is so constraining that it suggests the possibility of a temperature inversion at depth, or an absorbing molecule, such as methane, that further depresses the emitted flux at this wavelength. The combination of our near-infrared measurements and those obtained with Spitzer suggest that TrES-3b displays a near isothermal dayside atmospheric temperature structure, whose spectrum is well approximated by a blackbody. We emphasize that our strict H-band limit is in stark disagreement with the best-fit atmospheric model that results from longer wavelength observations only, thus highlighting the importance of near-infrared observations at multiple wavelengths in addition to those returned by Spitzer in the mid-infrared to facilitate a comprehensive understanding of the energy budgets of transiting exoplanets.Comment: ApJ accepted, 8 pages, 7 figures, in EmulateApJ forma

Worlds Beyond: A Strategy for the Detection and Characterization of Exoplanets Executive Summary of a Report of the ExoPlanet Task Force Astronomy and Astrophysics Advisory Committee Washington, DC June 23, 2008

[No abstract

NLTT 41135: a field M-dwarf + brown dwarf eclipsing binary in a triple system, discovered by the MEarth observatory

We report the discovery of an eclipsing companion to NLTT 41135, a nearby M5 dwarf that was already known to have a wider, slightly more massive common proper motion companion, NLTT 41136, at 2.4 arcsec separation. Analysis of combined-light and radial velocity curves of the system indicates that NLTT 41135B is a 31-34 +/- 3 MJup brown dwarf (where the range depends on the unknown metallicity of the host star) on a circular orbit. The visual M-dwarf pair appears to be physically bound, so the system forms a hierarchical triple, with masses approximately in the ratio 8:6:1. The eclipses are grazing, preventing an unambiguous measurement of the secondary radius, but follow-up observations of the secondary eclipse (e.g. with the James Webb Space Telescope) could permit measurements of the surface brightness ratio between the two objects, and thus place constraints on models of brown dwarfs.Comment: 15 pages, 6 figures, 10 tables, emulateapj format. Accepted for publication in Ap

A Spitzer Transmission Spectrum for the Exoplanet GJ 436b, Evidence for Stellar Variability, and Constraints on Dayside Flux Variations

In this paper we describe a uniform analysis of eight transits and eleven secondary eclipses of the extrasolar planet GJ 436b obtained in the 3.6, 4.5, and 8.0 micron bands using the IRAC instrument on the Spitzer Space Telescope between UT 2007 June 29 and UT 2009 Feb 4. We find that the best-fit transit depths for visits in the same bandpass can vary by as much as 8% of the total (4.7 sigma significance) from one epoch to the next. Although we cannot entirely rule out residual detector effects or a time-varying, high-altitude cloud layer in the planet's atmosphere as the cause of these variations, we consider the occultation of active regions on the star in a subset of the transit observations to be the most likely explanation. We reconcile the presence of magnetically active regions with the lack of significant visible or infrared flux variations from the star by proposing that the star's spin axis is tilted with respect to our line of sight, and that the planet's orbit is therefore likely to be misaligned. These observations serve to illustrate the challenges associated with transmission spectroscopy of planets orbiting late-type stars; we expect that other systems, such as GJ 1214, may display comparably variable transit depths. Our measured 8 micron secondary eclipse depths are consistent with a constant value, and we place a 1 sigma upper limit of 17% on changes in the planet's dayside flux in this band. Averaging over the eleven visits gives us an improved estimate of 0.0452% +/- 0.0027% for the secondary eclipse depth. We combine timing information from our observations with previously published data to produce a refined orbital ephemeris, and determine that the best-fit transit and eclipse times are consistent with a constant orbital period. [ABRIDGED]Comment: 26 pages, 18 figures, 7 tables in emulateapj format. Accepted for publication in Ap

Secondary Eclipse Photometry of WASP-4b with Warm Spitzer

We present photometry of the giant extrasolar planet WASP-4b at 3.6 and 4.5 micron taken with the Infrared Array Camera on board the Spitzer Space Telescope as part of Spitzer's extended warm mission. We find secondary eclipse depths of 0.319+/-0.031% and 0.343+/-0.027% for the 3.6 and 4.5 micron bands, respectively and show model emission spectra and pressure-temperature profiles for the planetary atmosphere. These eclipse depths are well fit by model emission spectra with water and other molecules in absorption, similar to those used for TrES-3 and HD 189733b. Depending on our choice of model, these results indicate that this planet has either a weak dayside temperature inversion or no inversion at all. The absence of a strong thermal inversion on this highly irradiated planet is contrary to the idea that highly irradiated planets are expected to have inversions, perhaps due the presence of an unknown absorber in the upper atmosphere. This result might be explained by the modestly enhanced activity level of WASP-4b's G7V host star, which could increase the amount of UV flux received by the planet, therefore reducing the abundance of the unknown stratospheric absorber in the planetary atmosphere as suggested in Knutson et al. (2010). We also find no evidence for an offset in the timing of the secondary eclipse and place a 2 sigma upper limit on |ecos(omega)| of 0.0024, which constrains the range of tidal heating models that could explain this planet's inflated radius.Comment: 8 pages, 7 figures (some in color), accepted for publication in Ap