A Legislative Path for Sports Betting in California: An Examination of Hotel Employees and the California Supreme Court’s Dueling Interpretations of the Constitutional Ban on ‘Casino-Style’ Gaming

This Article addresses a timely and important issue of constitutional law in California: namely, does the California Constitution’s prohibition against Nevada-and-New Jersey-style casinos expressed in Article IV, Section 19(e) prevent the California Legislature from authorizing sports betting through a statutory enactment? No prior judicial decision or law review article has directly addressed this issue, which has suddenly become relevant with the demise of the federal ban on state-authorized sports betting and increasing state efforts to legalize sports betting in recent years. In the aftermath of the 2018 U.S. Supreme Court decision striking down the Professional and Amateur Sports Protection Act on constitutional grounds, more than thirty states have enacted new laws authorizing sports betting. However, California—projected to be the largest market for sports betting in the United States by a considerable margin—is not among this group of first-mover states. While many states have been able to proceed expeditiously, passing sports betting statutes following several months of legislative deliberations, California’s expected ascendancy to the U.S. sports betting throne has been delayed due to the widely-held belief that an amendment to the state constitution—accomplished by way of a ballot measure or ballot initiative approved by voters during a statewide general election—is a prerequisite to the legalization of sports betting in California. This Article challenges that premise. Building off this author’s prior testimony before the California Senate and California Assembly Governmental Organization Committees, this Article examines the Legislature’s power to authorize sports wagering through the lens of the California Supreme Court’s decision in Hotel Employees & Restaurant Employees Int’l Union v. Davis, which, to date, is the only judicial decision to break down and interpret the individual component parts of section 19(e)’s declaration that the “[t]he Legislature has no power to authorize, and shall prohibit, casinos of the type currently operating in Nevada and New Jersey.” In Hotel Employees, the Supreme Court identified two possible ways to interpret that constitutional language—one which is tied to the specific gambling activities that were “unique to or particularly associated with” Nevada and New Jersey casinos in 1984, and the other more broadly referring to all categories of gambling that were banned in California at that time. This Article will examine these seemingly contradictory interpretations as part of a broader inquiry into whether section 19(e) applies to sports wagering. Dissecting the Supreme Court’s dual interpretations of section 19(e) in light of: (1) the facts of Hotel Employees and well-established principles of constitutional interpretation recognized by the California Supreme Court (including the substantial deference that must be shown to the legislative interpretation of a constitutional provision that is reasonably susceptible to two or more interpretations); (2) subsequent decisional law equating section 19(e) with a ban on “casino-style” gaming; and (3) the material differences between sports betting and casino-style gaming—both in terms of their essential characteristics and treatment under the law—this Article ultimately concludes that section 19(e)’s ban on casino-style gaming is not a barrier or obstacle to the legislative authorization of sports betting. This conclusion, which bucks the conventional wisdom but is deeply rooted in well-established principles of constitutional interpretation, should, in this author’s view, lead to a reassessment of the appropriate mechanism—as well as an acceleration of the timeline—for the legalization of mobile sports betting in California

Trichloroacetimidates as Alkylating Reagents in C-N Bond Formation and Synthesis of Aminosteroid and Quinoline Inhibitors of Src Homology 2 Domain-Containing Inositol Phosphatase (SHIP)

Trichloroacetimidates have frequently been used in the formation of glycosidic bonds and other ethers, which is especially useful for the introduction of ether protecting groups. Trichloroacetimidates have also been used as electrophiles in Friedel-Crafts alkylation reactions. The formation of C-N bonds has also been accomplished utilizing trichloroacetimidates. Most frequently C-N bond formation with trichloroacetimidates is associated with sigmatropic rearrangement of an allylic trichloroacetimidate to an allylic trichloroacetamide. This reaction can proceed thermally or through the use of Lewis acid or transition metal catalysts. Recently, the direct substitution of trichloroacetimidates using nitrogen nucleophiles has been accomplished utilizing transition metal catalysts, which indicates that trichloroacetimidates may be suitable alkylation partners for certain nitrogen nucleophiles. Trichloroacetimidates are now shown to be effective alkylating reagents for the monosubstitution of anilines using the Brønsted acid catalyst (±)-camphorsulfonic acid. The reaction is especially efficient for electron deficient anilines while electron rich anilines provided lower yields due to competing Friedel-Crafts reactions. A one-pot procedure for generating the trichloroacetimidate in situ followed by displacement with the aniline is also described, and the yields for this one-step process are similar to the two-step protocol. The displacement of a chiral imidate by 4-chloroaniline led to significant racemization which indicates that the reaction may proceed through a carbocation intermediate. The alkylation of sulfonamides with trichloroacetimidates under thermal conditions is also described. Primary and secondary trichloroacetimidates are found to be suitable electrophiles under these conditions, while tertiary trichloroacetimidates provide reduced yields. Aryl and alkyl sulfonamides with varying electronic properties were well tolerated under the reaction conditions. A bioactive analog of the analgesic ketoprofen is synthesized using the described methodology. Complete racemization of a chiral trichloroacetimidate is observed under these reaction conditions which is evidence that the reaction proceeds through an SN1 type mechanism. Pyrroloindoline trichloroacetimidates may react with amine nucleophiles in the presence of catalytic BF3ˑOEt2 to generate pyrroloindoline systems decorated with amines at the C3a position. The natural product kapakahine C is a complex heterocyclic compound containing a substituted pyrroloindoline-pyridoindoline core that may be accessed using this method. A route to the synthesis of the substituted pyridoindoline core of kapakahine C was investigated. Optimization of key reactions in this sequence, including a peptide coupling reaction and oxidative cyclization, was performed. Investigation into completing the synthesis of kapakahine C is ongoing. The inhibition of the SH2-containing inositol 5’-phosphatase (SHIP) can modulate the dephosphorylation of phosphoinositols. These molecules act as second messengers in a signal transduction cascade, with the placement of phosphorylation on the inositol acting to convey information in the transmission of signals from the cell membrane to the cell nucleus. The concentration of these phosphates has an effect on cellular function such as cell proliferation, survival, and differentiation. The synthesis of six aminosteroid SHIP inhibitors is described. Optimization of the key steps in the synthetic sequence was conducted. The synthesis of two quinoline based SHIP inhibitors, which were identified in a high-throughput screening conducted by the National Cancer Institute (NCI), was also completed. Studies were conducted to synthesize these molecules on multi-gram scale. The synthesized compounds were tested for inhibitory activity in a Malachite Green assay

Identification and quantification of differences between models

A major goal of crop model inter-comparison is model improvement, and an important intermediate step toward that goal is understanding in some detail how models differ, and the consequences of those differences. This report is intended as a first attempt at describing possible techniques for relating differences between model outputs to specific aspects of the models

Standardised methods and protocols based on current best practices to conduct sensitivity analysis

The purpose of this report is to propose a general procedure for sensitivity analysis when used to evaluate system sensitivity to climate change, including uncertainty information. While sensitivity analysis has been largely used to evaluate how uncertainties in inputs or parameters propagate through the model and manifest themselves in uncertainties in model outputs, there is much less experience with sensitivity analysis as a tool for studying how sensitive a system is to changes in inputs. This report should help make clear the differences between these two uses of sensitivity analysis, and provide guidance as to the procedure for using sensitivity analysis for evaluating system sensitivity to climate change

Standardised methods and protocols based on current best practices to conduct sensitivity analysis

The purpose of this report is to propose a general procedure for sensitivity analysis when used to evaluate system sensitivity to climate change, including uncertainty information. While sensitivity analysis has been largely used to evaluate how uncertainties in inputs or parameters propagate through the model and manifest themselves in uncertainties in model outputs, there is much less experience with sensitivity analysis as a tool for studying how sensitive a system is to changes in inputs. This report should help make clear the differences between these two uses of sensitivity analysis, and provide guidance as to the procedure for using sensitivity analysis for evaluating system sensitivity to climate change

Information to support input data quality and model improvement

Data quality is a key factor in determining the quality of model estimates and hence a models’ overall utility. Good models run with poor quality explanatory variables and parameters will produce meaningless estimates. Many models are now well developed and have been shown to perform well where and when good quality data is available. Hence a major limitation now to further use of models in new locations and applications is likely to be the availability of good quality data. Improvements in the quality of data may be seen as the starting point of further model improvement, in that better data itself will lead to more accurate model estimates (i.e. through better calibration), and it will facilitate reduction of model residual error by enabling refinements to model equations. This report sets out why data quality is important as well as the basis for additional investment in improving data quality

Development of a common set of methods and protocols for assessing and communicating uncertainties

This reports sets out an outline approach to create definitions of uncertainty and how it might be classified. This is not a prescriptive approach rather it should be seen as a starting point from which further development can be made by consensus with CropM partners and across MACSUR Themes. We propose both a numerical quantification of uncertainty and text based classification scheme. The rational is to be able to both establish the terms and definitions in quantifying the impact of uncertainty on model estimates and have a scheme to enable identification of connectivity between types and sources of uncertainty. The aim is to establish a common set of terms and structure within which they operate that can be used to guide work within CropM.

Communication strategy, including design of tools for more effective communication of uncertainty

Communication is the key link between the generation of information by MACSUR about the uncertainty of climate change impacts on future food security and how information is used by decision makers. It is therefore important to make available the common tools for reporting uncertainty, with a discussion of the advantages or difficulties of each. That is the purpose of this report

The IUSM Scholarly Concentrations Program: Strategic Collaborative Education Across Schools and Departments

Presented as a poster at 2020 IUSM Education Day.A changing healthcare landscape calls for innovation and expansion of expertise in medical education. How does a medical school better prepare medical students to thrive in a changing profession? Through its Scholarly Concentrations Program, Indiana University School of Medicine is collaborating with non-physician experts from schools with expertise in topics that are medically relevant and of interest to medical students. Scholarly Concentrations are longitudinal experiences that enhance the medical education program through coursework and scholarly work. In addition to enhancing students’ education, it offers the opportunity to enhance campus reputation and develop research focus for students and faculty. Partnerships were created in both directions. IU School of Medicine sought out schools and departments with unique expertise on different medical campuses. Schools and departments also approached IU School of Medicine about its Scholarly Concentrations program as momentum built. These partnerships are creating mutual benefits for IUSM, partners, faculty and students. Benefits for partner organizations include mentoring opportunities, reputational enhancement, having an impact on healthcare system, and pathways to certificates and advanced degrees. For IUSM and its students, the partnerships enhance professional development through Scholarly Concentrations in areas of clinical, teaching, research, advocacy and administration