Does Free Exercise Mean Free State Funding? In \u3ci\u3eDavey v. Locke\u3c/i\u3e, the Ninth Circuit Undervalued Washington\u27s Vision of Religious Liberty

In Davey v. Locke, a panel of the United States Court of Appeals for the Ninth Circuit ruled that Washington violated the Free Exercise Clause by refusing to allow a scholarship recipient to use state funds to pursue a theology degree. The court held that the state\u27s scholarship requirements facially discriminated against religion, and that the state\u27s interest in not violating its constitution did not serve as a compelling reason for the discrimination. In so holding, the Davey court ignored Ninth Circuit precedent and embraced a theory of the Religion Clauses at odds with United States Supreme Court jurisprudence. Furthermore, as explained in the dissent, the scholarship requirements are analogous to permissible limitations placed on other government funding programs. Based on U.S. Supreme Court precedent in other conditional funding cases, Davey should be overturned

Hydroelectric power, mercury, energetics, and stress: Biological and toxicological implications for fish and fisheries

Hydroelectric power is a critical component of the global energy budget and its capacity is projected to increase by 73% over the next 20 years, with much of this new capacity installed in the developing world. It is therefore important that we understand the impacts of these developments and how they might affect human and ecological health. Mercury accumulation in fish in reservoirs after dam construction is a well-researched and established phenomenon. While increased mercury concentrations have also been observed in fish downstream of dams , less is known about the dynamics of mercury in downstream sites, meaning there is unassessed historical risk to downstream wildlife, fisheries, and consumers. Further, hydropeaking that leads to fish strandings may represent a contemporary environmental stressor to downstream fishes. This could exacerbate mercury exposure in downstream fish by reallocating their energy from growth to addressing the stressor, resulting in higher mercury concentrations due to decreased growth dilution. This thesis explores the potential relationships between mercury and energy stores in fish up and downstream of a hydroelectric dam to determine historical relationships of fish mercury between these locations, and whether ongoing dam operations may exacerbate mercury concentrations in downstream fish. It also introduces a novel stress challenge protocol using a common minnow species in order to assess potential chronic environmental stress. Using historical records of commercial fishes from a reservoir and downstream fishery, I found rates of mercury decline were similar in fish populations within both sites since the 1970s. Yet where differences were noted, mercury consistently took longer to decline from downstream populations; mercury concentrations were also greater in fish immediately downstream of the dam relative to those from farther downstream despite minimal mercury concentrations (1-5 ng/L) in the water column. Higher mercury concentrations were also found downstream of the dam in a common minnow species (spottail shiner; “shiner”: Notropis hudsonius), and the same populations showed reduced energy stores relative to upstream fish in both August and September of 2014. Despite this connection, I noted minimal effects on fish condition, and there were no direct predictive relationships between fish mercury concentrations, energy stores, and condition. A newly developed acute stress challenge protocol also provided mixed evidence for the effects of hydropeaking on shiner stress responses. Glycogen concentrations were slightly higher iii in downstream fish from a site of concern in October compared with September, though minimal differences were found across time points, months or sites. Where patterns were observed, concentrations were highest within the first five minutes of capture and ultimately reached basal levels after 15 minutes. Minimal differences were noted in triglyceride concentrations across site, month, or time point. Cortisol secretion was successfully induced by the stress challenge as measured by whole-body cortisol concentrations, and the two upstream sites showed nearly identical patterns of cortisol concentration increase over time across months, with concentrations peaking ≈45-minutes post-challenge at both sites in both months. Minimal differences were noted across time points and sites within months, though cortisol concentrations in fish at a downstream site of concern were slightly elevated compared to upstream sites in September, and dropped significantly from September to October of 2015. While it is not possible to draw definitive conclusions about hydropeaking as a stressor based solely on these data, these results suggest that mercury concentrations may take longer to decline in fish populations downstream of dams, and that ongoing dam activities may be imparting direct or indirect effects on downstream fish that exacerbate long-term mercury concentrations. Finally, these results suggest that cortisol concentrations in shiner in response to an acute stressor may be successfully developed as a biomarker of chronic environmental stress

Electrosynthesis in extended channel length microfluidic cells

In recent papers, laboratory microfluidic electrolysis cells with extended channel lengths (0.7–2 m) and narrow interelectrode gap (<0.5 mm) have been introduced; these cells permit high conversions at a flow rate consistent with the synthesis of products at a rate of multigrams/hour. Such microflow electrolysis cells must be operated with appropriate control parameters if good performance is to be achieved; thus, this paper emphasizes the correct selection of cell current, flow rate, and counter electrode chemistry. It is also shown that, within the limitations, the cells can be used for a number of electrosyntheses in the synthetic laborator

N-Heterocyclic Carbene-mediated microfluidic oxidative electrosynthesis of amides from aldehydes

A flow process for N-Heterocyclic Carbene (NHC)-mediated anodic oxidative amidation of aldehydes is described, employing an undivided microfluidic electrolysis cell to oxidize Breslow intermediates. After electrochemical oxidation, the reaction of the intermediate N-acylated thiazolium cation with primary amines is completed by passage through a heating cell to achieve high conversion in a single pass. The flow mixing regimen circumvented the issue of competing imine formation between the aldehyde and amine substrates, which otherwise prevented formation of the desired product. High yields (71–99%), productivities (up to 2.6 g h–1), and current efficiencies (65–91%) were realized for 19 amides

2022 Safety Belt Usage Survey in Kentucky

Each year Kentucky Transportation Center researchers conduct a safety belt usage survey to estimate Kentucky’s statewide safety belt usage rate. In 2022, the safety belt usage rate in Kentucky was 86.72 percent, which represents a 3.06 decline over 2021. Safety belt usage peaked in 2018 at 89.99 percent. Declines in safety belt usage rate over the past couple years may be attributable in part to changes in driver behaviors and traffic dynamics following the COVID-19 pandemic. If Kentucky wants to increase safety belt usage rates, the state may need ramp up enforcement of safety belt laws or bolster educational outreach in targeted areas

Understanding the Dimensions Human Capital – Organizational Implications and Application

In recent decades, there has been an increasing number of studies which converge on the point, that investments in HC contribute positively to a company’s bottom-line. This has given rise to HC Management as a key strategic focus of organizations seeking to achieve and maintain competitive advantage. Arguably, HC Metrics is now considered just as important as financial returns; with the value of the human capital increasing the more the organizations builds up its stock and flow of knowledge. There are a host of theorists which identify the concept and context of HC with varying degrees of relatedness and overlap regarding its key components. Undeniably, there is some amount of discensus around the relationship between Human Capital and Intellectual Capital, as well as contending issues about whether Social Capital is a part of, competing with or complementing HC. Therefore, this study seeks to distil the essence from the debate to determine what are the most critical dimensional elements of HC, that drive and improve organisational value

Structure of the internal boundary layer over a patch of pinnid bivalves (Atrina zelandica) in an estuary

Measurements of tidal-current boundary-layer flow over an experimental 2-m by 2-m patch of pinnid bivalves (Atrina zelandica) in a northern New Zealand estuary are presented. Previous work demonstrated a link between mesoscale (order 100 m) patchiness of the benthic biota and time-averaged boundary-layer dynamics. The aim in this new experiment was to describe the three-dimensional structure of turbulence at the patch scale (order 1 m). Flow over three densities of Atrina was investigated: 340 individuals per 4 m2, 50 individuals per 4 m2 and zero individuals. An internal boundary layer (IBL) grows downstream from the leading edge of the patch at the base of the ambient boundary layer. One meter in from the leading edge, the top of the IBL was ~ 12 cm above the bed for the high-density patch and ~ 6 cm for the low-density patch. Flow in the IBL was three-dimensional in that vertical and transverse mean velocities were nonzero, secondary Reynolds stresses were nonzero and comparable with the primary stress, and velocity spectra deviated from scaling relationships for two-dimensional flow. Thus, the observed IBL was still in its infancy, i.e., it consisted of a roughness sublayer only as the distance from the leading edge of the patch was not enough for development of a second, overlying logarithmic layer. In summary, the IBL that envelops the Atrina patch is a region of lower mean longitudinal velocities but more energetic turbulence relative to the ambient boundary layer. The former translates into shelter, which some organisms might take advantage of, and the latter translates into increased vertical exchange across the top of the IBL, which might enhance fluxes of nutrients, colonists and suspended sediments, and might have implications for deposition and resuspension of organically rich biodeposits. The results extend our knowledge of turbulence over patches of suspension feeders at the 1-m scale and therefore provide information needed to improve depiction of flow in models of suspension-feeder-flow interactions

「環太平洋の言語」日本班

初巻は別書誌『消滅に瀕した方言アクセントの緊急調査研究