Jones V. Bock: New Clarity Under the Prison Litigation Reform Act

On January 22, 2007, the Supreme Court decided the consolidated cases of Jones v. Bock , Williams v. Overton , and Walton v. Bouchard , all of which were Sixth Circuit cases. In a unanimous decision, the Supreme Court provided clarity to what constitutes exhaustion of prison grievance procedures under the Prison Litigation Reform Act of 1995 (PLRA). The Court\u27s decision also offers its view on the correct way to balance the burden between prisoner plaintiffs and the judiciary, which labors to process prisoner complaints. Broken into three discreet issues, the essential holding provides a small victory for prison litigants. First, it determined that a prisoner litigating under the PLRA does not have the burden to plead and demonstrate exhaustion in the complaint. Rather, the defendant must raise lack of exhaustion as an affirmative defense. Second, it addressed whether a prisoner\u27s initial administrative grievance must identify and name all the individuals charged in its complaint. This determination lowered the bar outlined by the Sixth Circuit. Finally, it reviewed whether the PLRA requires dismissal of an entire complaint when some, but not all of the claims asserted have been exhausted. Once again, this issue was decided in favor of prisoners\u27 rights

Mobile solidarities: The City of Sanctuary movement and the Strangers into Citizens campaign

Political and social concerns regarding the negative impact of migrants and asylum seekers on local communities have become widespread within the UK over recent years. What is often overlooked in such debates, however, is the growing significance of movements such as those associated with the City of Sanctuary network and the Strangers into Citizens campaign, which both grow out of and also contribute to the construction of solidaristic relations between migrants, refugees and more established local residents. This report, which summarises the findings of a project into such movements led by Dr Vicki Squire at the Open University, suggests that migrants and refugees do not necessarily encounter hostility from ‘host’ communities, nor do they necessarily form discrete groups that need to be integrated within the wider community. Rather, migrants and refugees often engage with more established residents within localised city spaces in terms that render problematic distinctions between citizens/noncitizens; between cultural, ethnic or national groups; and between different migrant categories. The mobile solidarities associated with such movements thus challenge assumptions regarding the hostility of ‘host’ communities, as well as assumptions regarding the ‘natural’ division of community groups – assumptions on which contemporary integration and cohesion policies are founded

Electromotive force due to magnetohydrodynamic fluctuations in sheared rotating turbulence

This article presents a calculation of the mean electromotive force arising from general small-scale magnetohydrodynamical turbulence, within the framework of the second-order correlation approximation. With the goal of improving understanding of the accretion disk dynamo, effects arising through small-scale magnetic fluctuations, velocity gradients, density and turbulence stratification, and rotation, are included. The primary result, which supplements numerical findings, is that an off-diagonal turbulent resistivity due to magnetic fluctuations can produce large-scale dynamo action -- the magnetic analogue of the "shear-current" effect. In addition, consideration of $\alpha$ effects in the stratified regions of disks gives the puzzling result that there is no strong prediction for a sign of $\alpha$, since the effects due to kinetic and magnetic fluctuations, as well as those due to shear and rotation, are each of opposing signs and tend to cancel each other

Coherent nonhelical shear dynamos driven by magnetic fluctuations at low Reynolds numbers

Nonhelical shear dynamos are studied with a particular focus on the possibility of coherent dynamo action. The primary results -- serving as a follow up to the results of Squire & Bhattacharjee [arXiv:1506.04109 (2015)] -- pertain to the "magnetic shear-current effect" as a viable mechanism to drive large-scale magnetic field generation. This effect raises the interesting possibility that the saturated state of the small-scale dynamo could drive large-scale dynamo action, and is likely to be important in the unstratified regions of accretion disk turbulence. In this paper, the effect is studied at low Reynolds numbers, removing the complications of small-scale dynamo excitation and aiding analysis by enabling the use of quasi-linear statistical simulation methods. In addition to the magnetically driven dynamo, new results on the kinematic nonhelical shear dynamo are presented. These illustrate the relationship between coherent and incoherent driving in such dynamos, demonstrating the importance of rotation in determining the relative dominance of each mechanism

Effects of the Santa Barbara, Calif., Oil Spill on the Apparent Abundance of Pelagic Fishery Resources

Many studies have been made of the effects of oil on marine invertebrates, plants (marine algae and phytoplankton), and vertebrates such as seabirds and marine mammals. An excellent review of these findings, which includes some references to fish and pathological effects of aromatic hydrocarbons, has been published by the Royal Society, London (Clark, 1982). That review dealt with the environmental effects of such major oil spills or releases such as those by the tankers Torry Canyon (119,000 t) on the south coast of England, Metula (50-56,000 t) in the Straits of Magellan, Argo Merchant (26,000 t) off Cape Cod, and the super tanker Amoco Cadiz (223,000 t) on the coast of northern Brittany. Those spills were studied to determine their effect on living resources. In contrast there are few references on the impact of oil spills on pelagic fishery resources