Alien Tort Statute: A Discussion and Analysis of the History, Evolution, and Future

The Alien Tort Statute is a short, thirty-two word section of the United States Code enacted in 1789 as part of the Judiciary Act. The Alien Tort Statute, or ATS, has an uncertain and controversial beginning and remains controversial in current jurisprudence. The ATS reads as follows: “The district courts shall have original jurisdiction of any civil action by an alien for a tort only, committed in violation of the law of nations or a treaty of the United States. It is my intent for this thesis to be an academic discussion of the mysterious history, intent, and court cases that have evolved the ATS; and the way in which the evolution took place. Having lain dormant for almost two decades, it is important to understand how the ATS was finally utilized and how this affected the statutes ability to become a tool for human rights persecution abroad; until the decision in Kiobel v. Royal Dutch Petroleum. Examining the language of two opinions by the District Court of the Second Circuit and the Supreme Court in Kiobel we will be able to understand, but reject, the arguments of both these courts

Sympathovagal effects of spinal anesthesia assessed by heart rate variability analysis

Heart rate variations (HRV) result from moment-to-moment changes in sympathetic and parasympathetic activity in response to many conditions. These two neural inputs to the heart can be identified by analyzing power spectra of HRV for frequency components at the vasomotor (low-frequency [LF]) and the respiratory (high-frequency [HF]) rhythms. HRV analysis has been used successfully in humans to noninvasively evaluate the autonomic responses to specific maneuvers and drugs, as well as responses to more chronic preexisting pathologic conditions. The effects of an isolated "acute" withdrawal of sympathetic activity in humans, however, have not as yet been evaluated using an autoregressive (AR) technique. We examined HRV using this technique in a group of patients receiving subarachnoid block for abdominal surgery. The sensory levels achieved were within the range of those reported to interrupt sympathetic outflow to the heart. Electrocardiograms were recorded and subjected to AR analysis. AR analysis of HRV after spinal anesthesia revealed significant decreases in both dominant frequency components (LF and HF) that occur between 0.03 Hz and 0.5 Hz. These reductions coincided with blockade of cardiac sympathetic outflow after cephalad spread of the spinal block. The power spectra were almost abolished in patients with sensory blocks reaching T1-2. The decreases in amplitude of the LF and HF components, therefore, act as markers of diminished sympathetic and parasympathetic activity to the heart, while the ratio of LF:HF indicated that sympathovagal balance was predominantly maintained during most of the block.(ABSTRACT TRUNCATED AT 250 WORDS