The Story of a Class: Uses of Narrative in Public Interest Class Actions Before Certification

When litigants in public interest class actions tell their stories, the narratives can advance the law and influence public debate. But before class members’ stories can vindicate civil rights on the merits, plaintiffs must overcome the hurdle of class certification. For decades, obtaining class certification under Federal Rule of Civil Procedure 23 was not a significant challenge for plaintiffs seeking to litigate as a class. But recent restrictive procedural developments—including heightened standards for class certification—threaten the powerful stories that can be told through public interest class actions. Missing in the critical analysis of class action jurisprudence is any discussion of how advocates can use narrative techniques to meet that heightened certification standard. Similarly, law and narrative scholarship has devoted little attention to the class action. This Article begins to fill that gap by engaging in a critical reading of two recent public interest class actions: one challenging family separations at the border, and one challenging the denial of abortion care to pregnant unaccompanied minors in immigration custody. The Article identifies narrative choices that ultimately enable class certification and further storytelling in public interest class actions. The Article argues that narrative theory can provide an important perspective on the debate over restrictive class action procedure and makes recommendations for courts and lawyers to pay greater attention to narrative in class action cases

Not the Same Old Story: Using Narrative Theory to Understand and Overcome the Plausibility Pleading Standard

First published in the Yale Journal of Law & the Humanities

Shocked Gas in IRAS F17207-0014: ISM Collisions and Outflows

We combine optical and near-infrared AO-assisted integral field observations of the merging ULIRG IRAS F17207-0014 from the Wide-Field Spectrograph (WiFeS) and Keck/OSIRIS. The optical emission line ratios [N II]/H$\alpha$, [S II]/H$\alpha$, and [O I]/H$\alpha$ reveal a mixing sequence of shocks present throughout the galaxy, with the strongest contributions coming from large radii (up to 100% at $\sim$5 kpc in some directions), suggesting galactic-scale winds. The near-infrared observations, which have approximately 30 times higher spatial resolution, show that two sorts of shocks are present in the vicinity of the merging nuclei: low-level shocks distributed throughout our field-of-view evidenced by an H$_{2}$/Br$\gamma$ line ratio of $\sim$0.6-4, and strong collimated shocks with a high H$_{2}$/Br$\gamma$ line ratio of $\sim$4-8, extending south from the two nuclear disks approximately 400 pc ($\sim$0.5 arcsec). Our data suggest that the diffuse shocks are caused by the collision of the interstellar media associated with the two progenitor galaxies and the strong shocks trace the base of a collimated outflow coming from the nucleus of one of the two disks.Comment: accepted to MNRA

The Ursinus Weekly, March 6, 1950

\u2751ers rate second place, capture trophy in contest • Sophs plan week-end of sophisticate decor • Senator to discuss many new issues facing law-makers • Helfferich ekes out heavyweight honor for second season • Scout frat sponsors heart disease drive with dorm workers • Bare, B. Keller win roles as adult duo in teen-age drama • Law students await Temple preliminary to April ICG parley • Vesper service ends emphasis week • Senators to launch soliciting campaign for Red Cross aid • Muench to conquer coed athlete ranks as minstrel emcee • Seniors to present Saurman\u27s musical • Southern exposure: Keller returns from the Mardi Gras • War brings German to Ursinus • Ursinus sage sees college past; hints at amazing future • Naturalists find Audubon • Specialists explain aspects of cancer from U.S. research • Druggists lose 75-47 as bears win fourth • Visitors sink coeds in tank meet 35-22 for fourth victory • Bearettes succumb 31-24 to undefeated Owl team • Leaders still pace intramural league; applications posted • Reilly leads Garnet five in 100-49 rout of bears • Cubs rally to beat Pharmacy juniors in 60-45 reversal • Belles knot contest at Southern College after yielding lead • Ursinus ties for fifth in MAC mat tourney • Bruin Quintet drops 58-51 court verdict in Jayvee skirmish • Bryn Mawr downs shuttlecock gals 5-0 • Tennis squad faces ten-match schedule • Juniors capitalize on campus freaks for initial 1951 Ruby budget activity • Thespians rehearse Gloria Mundi roles • Scout meeting to feature trip to Florida via slideshttps://digitalcommons.ursinus.edu/weekly/1586/thumbnail.jp

Expression of a Constitutively Active Nitrate Reductase Variant in Tobacco Reduces Tobacco-Specific Nitrosamine Accumulation in Cured Leaves and Cigarette Smoke

Burley tobaccos (Nicotiana tabacum) display a nitrogen-use-deficiency phenotype that is associated with the accumulation of high levels of nitrate within the leaf, a trait correlated with production of a class of compounds referred to as tobacco-specific nitrosamines (TSNAs). Two TSNA species, 4-(methylnitrosamino)-1-(3-pyridyl)-1-butanone (NNK) and N-nitrosonornicotine (NNN), have been shown to be strong carcinogens in numerous animal studies. We investigated the potential of molecular genetic strategies to lower nitrate levels in burley tobaccos by overexpressing genes encoding key enzymes of the nitrogen-assimilation pathway. Of the various constructs tested, only the expression of a constitutively active nitrate reductase (NR) dramatically decreased free nitrate levels in the leaves. Field-grown tobacco plants expressing this NR variant exhibited greatly reduced levels of TSNAs in both cured leaves and mainstream smoke of cigarettes made from these materials. Decreasing leaf nitrate levels via expression of a constitutively active NR enzyme represents an exceptionally promising means for reducing the production of NNN and NNK, two of the most well-documented animal carcinogens found in tobacco products

Multiple Chronic Conditions and Limitations in Activities of Daily Living in a Community-Based Sample of Older Adults in New York City, 2009

Introduction Nationally, 60% to 75% of older adults have multiple (2 or more) chronic conditions (MCCs), and the burden is even higher among low-income, racial/ethnic minority populations. MCCs limit activities of daily living (ADLs), yet this association is not well characterized outside of clinical populations. We examined the association of MCCs with ADLs in a racially/ethnically diverse population of low-income older adults living in New York City public housing. Methods A representative sample of 1,036 New York City Housing Authority residents aged 65 or older completed a telephone survey in June 2009. We examined the association of up to 5 chronic conditions with basic ADL (BADL) limitations, adjusting for potential confounders by using logistic regression. Results Of respondents, 28.7% had at least 1 BADL limitation; 92.9% had at least 1 chronic condition, and 79.0% had MCCs. We observed a graded association between at least 1 BADL limitation and number of chronic conditions (using 0 or 1 condition as the reference group): adjusted odds ratio (AOR) for 3 conditions was 2.2 (95% confidence interval [CI], 1.3–3.9); AOR for 4 conditions, 4.3 (95% CI, 2.5–7.6); and AOR for 5 conditions, 9.2 (95% CI, 4.3–19.5). Conclusion Prevalence of BADL limitations is high among low-income older adults and increases with number of chronic conditions. Initiating prevention of additional conditions and treating disease constellations earlier to decrease BADL limitations may improve aging outcomes in this population

Variegate porphyria in South Africa, 1688 - 1996 - new developments in an old disease

Variegate porphyria, an autosomal dominant inherited trait resulting in decreased activity of protoporphyrinogen oxidase, the penuttimate haem biosynthetic enzyme, is characterised clinically by photosensitive skin disease and a propensity to acute neurovisceral crises. The disease has an exceptionally high frequency in South Africa,owing to a founder effect. The specific mutation in the protoporphynnogen oxidase gene sequence which represents this founder gene has been identified. Genetic diagnosis is therefore now possible in families in whom the gene defect is known. However, the exact nature and degree of activity of the porphyria can only be determined by detailed quantitative biochemical analysis of excreted porphyrins. The relative contributions of the acute attack and the skin disease to the total disease burden of patients with variegate porphyria is not static, and in South Africa there have been significant changes over the past 25 years, with fewer patients presenting with acute attacks, leaving a greater proportion to present with skin disease or to remain asymptomatic with the diagnosis being made in the laboratory. The most common precipitating cause of the acute attack of VP is administration of porphyrinogenic drugs. Specific suppression of haem synthesis with intravenous haem arginate is the most useful treatment of a moderate or severe acute attack. Although cutaneous lesions are limited to the sun-exposed areas, management of the skin disease of VP remains inadequate