Still Out of Step: The Sixth Circuit’s Adoption of a “But-For” Standard for ADA Plaintiffs in \u3cem\u3eLewis v. Humboldt Acquisition Corp.\u3c/em\u3e

On May 25, 2012, the U.S. Court of Appeals for the Sixth Circuit, sitting en banc, reversed seventeen years of precedent and joined its sister circuits by discarding the “sole cause” standard for proving discrimination under Title I of the Americans with Disabilities Act (ADA). By declining to adopt the “motivating factor” standard used in the majority of the other circuits, and instead adopting a “but-for” standard, the Sixth Circuit’s ADA jurisprudence continues to be an outlier. This Comment argues that the “but-for” standard imposes an unfair burden on vulnerable and disabled employees who are seeking relief from employers’ discriminatory treatment, and therefore fails to effectuate the congressional intent behind the ADA

Liver Parenchyma Perforation following Endoscopic Retrograde Cholangiopancreatography

Although endoscopic retrograde cholangiopancreatography (ERCP) is an effective modality for the diagnosis and treatment of biliary and pancreatic diseases, it is still related with several severe complications. We report on the case of a female patient who developed liver parenchyma perforation following ERCP. She underwent ERCP with sphincterotomy and extraction of a common bile duct stone. Shortly after ERCP, abdominal distension was identified. Abdominal computed tomography revealed intraabdominal air leakage and leakage of contrast dye penetrating the liver parenchyma into the space around the spleen. Since periampullary perforation related to sphincterotomy could not be denied, she was referred for immediate surgery. Obvious perforation could not be found at surgery. Cholecystectomy, insertion of a T tube into the common bile duct, placement of a duodenostomy tube and drainage of the retroperitoneum were performed. She did well postoperatively and was discharged home on postoperative day 28. In conclusion, as it is well recognized that perforation is one of the most serious complication related to ERCP, liver parenchyma perforation should be suspected as a cause

A data-based Financial Management Information System (FMIS) for Administrative Sciences Department

The Administrative Sciences (AS) Department of the Naval Postgraduate School (NPS) is placing an increasing emphasis on keeping departmental expenses at minimum levels requiring the AS Department to carefully monitor a large number of complex financial accounts. It becomes necessary to develop a Financial Management Information System that would result in improved management of financial assets, better use of clerical skills, and more detailed, accurate, and up-to-date reporting within the AS Department. Based on the requirement analysis and prototypes performed by previous work, this thesis develops and implements a personal computer-based Management Information System for the Management of the many funding accounts controlled by the Administrative Sciences Department. The central objective was to integrate accounting transactions performed in several different offices, currently using different software programs, into a single all-encompassing Management Information System. The system was written using dBASE IV and is currently operational.http://archive.org/details/adatabasedfinanc1094527584Lieutenant Commander, United States NavyLieutenant, United States NavyApproved for public release; distribution is unlimited

Endoscopic sphincterotomy - The basics

Endoscopic sphincterotomy refers to the incision of the terminal portion of the biliary or pancreatic ducts by a variety of techniques, depending on anatomic circumstances, goals and risks. Alternative methods include percutaneous transhepatic or surgical techniques. The initial Erlangen method - complete sphinccerotomy - carried an unavoidable risk of perforation and hemorrhage. Fractional incision or 'endoscopic papillotomy' - incision of the inferior sphincter - carries no risk of hemorrhage or perforation, done properly. Techniques of papillotomy including 'pull,' 'precut,' stent placement, infundibulotomy, percutaneous cholangiography, and internal spring wire are described, and general electrosurgical principles discussed