Municipal Reparations: Considerations and Constitutionality

Demands for racial justice are resounding, and in turn, various localities have considered issuing reparations to Black residents. Municipalities may be effective venues in the struggle for reparations, but they face a variety of questions when crafting legislation. This Note walks through key considerations using proposed and enacted reparations plans as examples. It then presents a hypothetical city resolution addressing Philadelphia’s discriminatory police practices. Next, it turns to a constitutional analysis of reparations policies under current Fourteenth Amendment jurisprudence, discussing both race-neutral and race-conscious plans. This Note argues that an antisubordination understanding of the Equal Protection Clause would better allow political branches to rectify vestiges of past discrimination and ongoing inequities through reparations plans such as the hypothetical Philadelphia City Council resolution. With these suggestions in mind, municipalities must boldly imagine and extend reparations to marginalized groups that have suffered harms. Similarly, the Court must reimagine its constitutional doctrine

Introduction: Two Perspectives on Sara Mayeux’s \u3cem\u3eFree Justice\u3c/em\u3e

A Review of Free Justice: A History of the Public Defender in Twentieth-Century America. By Sara Mayeux

To Participate and Elect: Section 2 of the Voting Rights Act at 40

This paper provides an overview of cases decided under Section 2 of the Voting Rights Act between September 1, 1982 and December 31, 2021. It updates our 2006 study documenting Section 2 litigation through 2005. Of note is the substantial decline in the number of Section 2 cases decided and diminished success for the plaintiffs who bring them. While recent litigation (including Brnovich and Merrill v. Milligan) suggests that Section 2 is likely to occupy, at best, a diminished role in future electoral disputes, this paper shows that Section 2’s reach had already declined significantly prior to recent disputes. It documents a steep drop in the number of Section 2 decisions involving vote dilution. So too, while plaintiffs bringing dilution claims found notable success in the first decade after Congress amended Section 2 in 1982, they have seen a steady decline in success ever since. Meanwhile, plaintiffs bringing Section 2 non-dilution claims—i.e., alternatively labelled “vote denial” or “time, place and manner” restrictions—have seen less success overall, and, as with dilution claims, a steady decline in success over time. The Report and underlying dataset can be found at www.voting.law.umich.ed

Cupriphication of gold to sensitize d10–d10 metal–metal bonds and near-unity phosphorescence quantum yields

Outer-shell s0/p0 orbital mixing with d10 orbitals and symmetry reductionuponcupriphicationofcyclic trinucleartrigonal-planargold(I) complexes are found to sensitize ground-state Cu(I)–Au(I) covalent bonds and near-unity phosphorescence quantum yields. Heterobimetallic Au4Cu2 {[Au4(μ-C2,N3-EtIm)4Cu2(μ-3,5-(CF3)2Pz)2], (4a)}, Au2Cu {[Au2(μ-C2,N3-BzIm)2Cu(μ-3,5-(CF3)2Pz)], (1) and [Au2(μ-C2, N3-MeIm)2Cu(μ-3,5-(CF3)2Pz)], (3a)}, AuCu2 {[Au(μ-C2,N3-MeIm)Cu2(μ3,5-(CF3)2Pz)2], (3b) and [Au(μ-C2,N3-EtIm)Cu2(μ-3,5-(CF3)2Pz)2], (4b)} and stacked Au3/Cu3 {[Au(μ-C2,N3-BzIm)]3[Cu(μ-3,5-(CF3)2Pz)]3, (2)} formuponreactingAu3 {[Au(μ-C2,N3-(N-R)Im)]3 ((N-R)Im = imidazolate; R =benzyl/methyl/ethyl =BzIm/MeIm/EtIm)} with Cu3 {[Cu(μ-3,5(CF3)2Pz)]3 (3,5-(CF3)2Pz = 3,5-bis(trifluoromethyl)pyrazolate)}. The crystal structures of 1 and 3a reveal stair-step infinite chains whereby adjacent dimer-of-trimer units are noncovalently packed via twoAu(I)⋯Cu(I)metallophilicinteractions,whereas 4a exhibitsa hexanuclear cluster structure wherein two monomer-of-trimer units are linked by a genuine d10–d10 polar-covalent bond with ligandunassisted Cu(I)–Au(I) distances of 2.8750(8) Å each—the shortest such an intermolecular distance ever reported between any two d10 centers so as to deem it a “metal–metal bond” vis-à-vis “metallophilic interaction.” Density-functional calculations estimate 35– 43kcal/molbindingenergy,akintotypicalM–Msingle-bondenergies. Congruently, FTIR spectra of4a showmultiple far-IR bands within 65– 200 cm−1, assignable to vCu-Au as validated by both the Harvey–Gray method of crystallographic-distance-to-force-constant correlation and dispersive density functional theory computations. Notably, the heterobimetallic complexes herein exhibit photophysical properties that are favorable to those for their homometallic congeners, due to threefold-to-twofold symmetry reduction, resulting in cuprophilicsensitizationinextinctioncoefficientandsolid-state photoluminescence quantum yields approaching unity (ΦPL = 0.90–0.97 vs. 0–0.83 for Au3 and Cu3 precursors), which bodes well for potential future utilization in inorganic and/or organic LED applications

PI5P4Kα supports prostate cancer metabolism and exposes a survival vulnerability during androgen receptor inhibition.

Phosphatidylinositol (PI)regulating enzymes are frequently altered in cancer and have become a focus for drug development. Here, we explore the phosphatidylinositol-5-phosphate 4-kinases (PI5P4K), a family of lipid kinases that regulate pools of intracellular PI, and demonstrate that the PI5P4Kα isoform influences androgen receptor (AR) signaling, which supports prostate cancer (PCa) cell survival. The regulation of PI becomes increasingly important in the setting of metabolic stress adaptation of PCa during androgen deprivation (AD), as we show that AD influences PI abundance and enhances intracellular pools of PI-4,5-P2. We suggest that this PI5P4Kα-AR relationship is mitigated through mTORC1 dysregulation and show that PI5P4Kα colocalizes to the lysosome, the intracellular site of mTORC1 complex activation. Notably, this relationship becomes prominent in mouse prostate tissue following surgical castration. Finally, multiple PCa cell models demonstrate marked survival vulnerability following stable PI5P4Kα inhibition. These results nominate PI5P4Kα as a target to disrupt PCa metabolic adaptation to castrate resistance

Individual participant data meta analysis to compare EPDS accuracy to detect major depression with and without the self-harm item

Item 10 of the Edinburgh Postnatal Depression Scale (EPDS) is intended to assess thoughts of intentional self-harm but may also elicit concerns about accidental self-harm. It does not specifically address suicide ideation but, nonetheless, is sometimes used as an indicator of suicidality. The 9-item version of the EPDS (EPDS-9), which omits item 10, is sometimes used in research due to concern about positive endorsements of item 10 and necessary follow-up. We assessed the equivalence of total score correlations and screening accuracy to detect major depression using the EPDS-9 versus full EPDS among pregnant and postpartum women. We searched Medline, Medline In-Process and Other Non-Indexed Citations, PsycINFO, and Web of Science from database inception to October 3, 2018 for studies that administered the EPDS and conducted diagnostic classification for major depression based on a validated semi-structured or fully structured interview among women aged 18 or older during pregnancy or within 12 months of giving birth. We conducted an individual participant data meta-analysis. We calculated Pearson correlations with 95% prediction interval (PI) between EPDS-9 and full EPDS total scores using a random effects model. Bivariate random-effects models were fitted to assess screening accuracy. Equivalence tests were done by comparing the confidence intervals (CIs) around the pooled sensitivity and specificity differences to the equivalence margin of δ = 0.05. Individual participant data were obtained from 41 eligible studies (10,906 participants, 1407 major depression cases). The correlation between EPDS-9 and full EPDS scores was 0.998 (95% PI 0.991, 0.999). For sensitivity, the EPDS-9 and full EPDS were equivalent for cut-offs 7-12 (difference range - 0.02, 0.01) and the equivalence was indeterminate for cut-offs 13-15 (all differences - 0.04). For specificity, the EPDS-9 and full EPDS were equivalent for all cut-offs (difference range 0.00, 0.01). The EPDS-9 performs similarly to the full EPDS and can be used when there are concerns about the implications of administering EPDS item 10.This study was funded by the Canadian Institutes of Health Research (CIHR, KRS-140994). Dr. Qiu was supported by a scholarship from the China Scholarship Council. Drs. Wu and Levis were supported by Fonds de recherche du Québec—Santé (FRQ-S) Postdoctoral Training Fellowships. Dr. Benedetti was supported by a Fonds de recherche du Québec – Santé (FRQS) researcher salary award. Dr. Thombs was supported by a Tier 1 Canada Research Chair. Ms. Rice was supported by a Vanier Canada Graduate Scholarship. The primary study by Alvarado et al. was supported by the Ministry of Health of Chile. The primary study by Barnes et al. was supported by a grant from the Health Foundation (1665/608). The primary study by Beck et al. was supported by the Patrick and Catherine Weldon Donaghue Medical Research Foundation and the University of Connecticut Research Foundation. The primary study by Helle et al. was supported by the Werner Otto Foundation, the Kroschke Foundation, and the Feindt Foundation. The primary study by Figueira et al. was supported by the Brazilian Ministry of Health and by the National Counsel of Technological and Scientific Development (CNPq) (Grant no.403433/2004-5). The primary study by Couto et al. was supported by the National Counsel of Technological and Scientific Development (CNPq) (Grant no. 444254/2014-5) and the Minas Gerais State Research Foundation (FAPEMIG) (Grant no. APQ-01954-14). The primary study by Chorwe-Sungani et al. was supported by the University of Malawi through grant QZA-0484 NORHED 2013. The primary study by de Figueiredo et al. was supported by Fundação de Amparo à Pesquisa do Estado de São Paulo. The primary study by Tissot et al. was supported by the Swiss National Science Foundation (grant 32003B 125493). The primary study by Fernandes et al. was supported by grants from the Child: Care Health and Development Trust and the Department of Psychiatry, University of Oxford, Oxford, UK, and by the Ashok Ranganathan Bursary from Exeter College, University of Oxford. Dr. Fernandes is supported by a University of Southampton National Institute for Health Research (NIHR) academic clinical fellowship in Paediatrics. The primary study by van Heyningen et al. was supported by the Medical Research Council of South Africa (fund no. 415865), Cordaid Netherlands (Project 103/10002 G Sub 7) and the Truworths Community Foundation Trust, South Africa. Dr. van Heyningen was supported by the National Research Foundation of South Africa and the Harry Crossley Foundation. VHYTHE001/1232209. The primary study by Tendais et al. was supported under the project POCI/SAU-ESP/56397/2004 by the Operational Program Science and Innovation 2010 (POCI 2010) of the Community Support Board III and by the European Community Fund FEDER. The primary study by Fisher et al. was supported by a grant under the Invest to Grow Scheme from the Australian Government Department of Families, Housing, Community Services and Indigenous Affairs. The primary study by Green et al. was supported by a grant from the Duke Global Health Institute (453-0751). The primary study by Howard et al. was supported by the National Institute for Health Research (NIHR) under its Programme Grants for Applied Research Programme (Grant Reference Numbers RP-PG-1210-12002 and RP-DG-1108-10012) and by the South London Clinical Research Network. The views expressed are those of the authors and not necessarily those of the NHS, the NIHR or the Department of Health and Social Care. The primary study by Kettunen et al. was supported with an Annual EVO Financing (Special government subsidies from the Ministry of Health and Welfare, Finland) by North Karelia Central Hospital and Päijät-Häme Central Hospital. The primary study by Phillips et al. was supported by a scholarship from the National Health and Medical and Research Council (NHMRC). The primary study by Roomruangwong et al. was supported by the Ratchadaphiseksomphot Endowment Fund 2013 of Chulalongkorn University (CU-56-457-HR). The primary study by Martínez et al. was supported by Iniciativa Científica Milenio, Chile, process # IS130005 and by Fondo Nacional de Desarrollo Científico y Tecnológico, Chile, process # 1130230. The primary study by Nakić Radoš et al. was supported by the Croatian Ministry of Science, Education, and Sports (134-0000000-2421). The primary study by Usuda et al. was supported by Grant-in-Aid for Young Scientists (A) from the Japan Society for the Promotion of Science (primary investigator: Daisuke Nishi, MD, PhD), and by an Intramural Research Grant for Neurological and Psychiatric Disorders from the National Center of Neurology and Psychiatry, Japan. The primary study by Pawlby et al. was supported by a Medical Research Council UK Project Grant (number G89292999N). The primary study by Rochat et al. was supported by grants from the University of Oxford (HQ5035), the Tuixen Foundation (9940), the Wellcome Trust (082384/Z/07/Z and 071571), and the American Psychological Association. Dr. Rochat receives salary support from a Wellcome Trust Intermediate Fellowship (211374/Z/18/Z). The primary study by Rowe et al. was supported by the diamond Consortium, beyondblue Victorian Centre of Excellence in Depression and Related Disorders. The primary study by Comasco et al. was supported by funds from the Swedish Research Council (VR: 521-2013-2339, VR:523-2014-2342), the Swedish Council for Working Life and Social Research (FAS: 2011-0627), the Marta Lundqvist Foundation (2013, 2014), and the Swedish Society of Medicine (SLS-331991). The primary study by Smith-Nielsen et al. was supported by a grant from the charitable foundation Tryg Foundation (Grant ID no 107616). The primary study by Prenoveau et al. was supported by The Wellcome Trust (grant number 071571). The primary study by Stewart et al. was supported by Professor Francis Creed’s Journal of Psychosomatic Research Editorship fund (BA00457) administered through University of Manchester. The primary study by Su et al. was supported by grants from the Department of Health (DOH94F044 and DOH95F022) and the China Medical University and Hospital (CMU94-105, DMR-92-92 and DMR94-46). The primary study by Tandon et al. was funded by the Thomas Wilson Sanitarium. The primary study by Tran et al. was supported by the Myer Foundation who funded the study under its Beyond Australia scheme. Dr. Tran was supported by an early career fellowship from the Australian National Health and Medical Research Council. The primary study by Vega-Dienstmaier et al. was supported by Tejada Family Foundation, Inc, and Peruvian-American Endowment, Inc. The primary study by Yonkers et al. was supported by a National Institute of Child Health and Human Development grant (5 R01HD045735). No other authors reported funding for primary studies or for their work on this study

Constraints on the χ_(c1) versus χ_(c2) polarizations in proton-proton collisions at √s = 8 TeV

The polarizations of promptly produced χ_(c1) and χ_(c2) mesons are studied using data collected by the CMS experiment at the LHC, in proton-proton collisions at √s=8  TeV. The χ_c states are reconstructed via their radiative decays χ_c → J/ψγ, with the photons being measured through conversions to e⁺e⁻, which allows the two states to be well resolved. The polarizations are measured in the helicity frame, through the analysis of the χ_(c2) to χ_(c1) yield ratio as a function of the polar or azimuthal angle of the positive muon emitted in the J/ψ → μ⁺μ⁻ decay, in three bins of J/ψ transverse momentum. While no differences are seen between the two states in terms of azimuthal decay angle distributions, they are observed to have significantly different polar anisotropies. The measurement favors a scenario where at least one of the two states is strongly polarized along the helicity quantization axis, in agreement with nonrelativistic quantum chromodynamics predictions. This is the first measurement of significantly polarized quarkonia produced at high transverse momentum