Setting Congress Up to Fail

In Shelby County v. Holder the Supreme Court invalidated key provisions of the Voting Rights Act of 1965 based on Congress’s failure to justify the formula used to determine which jurisdictions would be subject to the Act’s pre-clearance requirement of submitting all changes to voting procedures to the Justice Department for prior approval. This short essay explores one problematic feature of the Court’s analysis: its refusal to consider the legislative record as adequate because it was created to justify the coverage formula after the fact, rather than to facilitate deliberation on the coverage formula before a decision had been made. This reasoning essentially imports from administrative law a rule called the Chenery principle, and as this essay explains, it does so without justification. The differences between administrative and legislative decision making processes compel different treatment by the courts, and treating legislative records like administrative ones, in essence, asks of Congress something it is institutionally ill-equipped to perform. It sets Congress up to fail.

Spontaneous Abortions and Shift Work in a Cohort of Nurses in Norway

Background: An association between spontaneous abortions and shift work has been suggested, but present research results are conflicting. The aim of the study is to evaluate the relationship between spontaneous abortions among nurses, shift schedules, and nights worked. Methods: This is a longitudinal study where we identified 914 females from a cohort of nurses in Norway who had worked the same type of shift schedule 2008-2010; either permanent day shift, three-shift rotation or permanent night shift. Information on age, work and life-style factors, as well as spontaneous abortions during lifetime and the past three years (2008-2010) was obtained by annual questionnaires. Results: A higher prevalence of experienced spontaneous abortions before study start (2008) was found among nurses working permanent night shift compared to other nurses. In a linear regression analysis, a risk of 1.3 was found for experienced spontaneous abortions before study start among permanent night shift nurses, with day shift as reference, when adjusting for age, smoking, caffeine and job strain, but the finding was not statistical significant (95 per cent confidence interval 0.8-2.1). Permanent night shift workers had a risk of 1.5 experiencing spontaneous abortions in 2008-2010 compared to day shift nurses, although not statistical significant (95 per cent confidence interval 0.7-3.5). The number of night shifts the past three years was not associated with experiencing spontaneous abortions 2008-2010, but associated with a reduced risk of experiencing spontaneous abortions during lifetime. The results must be interpreted in the light of a possible selection bias; both selections into the occupation of nursing and into the different shift types of the more healthy persons may have occurred in this population. Conclusion: No significant increased risk of spontaneous abortion among permanent night shift nurses compared to day-time nurses was found in this study, and no association was found between spontaneous abortions and the number of worked night shifts.

B. Copies of three letters to Moody Noyes, 1800

It is unknown who made these manuscript copies of three letters from John Henry Tudor to Moody Noyes; they are not in Tudor's hand. The letters were written on September 23, 1800; November 7, 1800; and February 20, 1801. Noyes and Tudor were classmates at Harvard College, where both graduated in the class of 1800. The letters were written after they had graduated from Harvard, and in them Tudor recounts travels with his family around New England, including a stay in Saratoga and Ballston Springs, New York; his interest, shared by Moody, in entering into a store or other form of business, although he found "merchants in general [to be] a contemptible set of beings"; the maxims of the Duke de la Rochefoucauld; his hurt feelings at Moody's failure to answer his letters; and his imminent travels to Cuba with his brother, Frederic, made in hopes of restoring his health.

B. Copies of three letters to Moody Noyes, 1800

It is unknown who made these manuscript copies of three letters from John Henry Tudor to Moody Noyes; they are not in Tudor's hand. The letters were written on September 23, 1800; November 7, 1800; and February 20, 1801. Noyes and Tudor were classmates at Harvard College, where both graduated in the class of 1800. The letters were written after they had graduated from Harvard, and in them Tudor recounts travels with his family around New England, including a stay in Saratoga and Ballston Springs, New York; his interest, shared by Moody, in entering into a store or other form of business, although he found "merchants in general [to be] a contemptible set of beings"; the maxims of the Duke de la Rochefoucauld; his hurt feelings at Moody's failure to answer his letters; and his imminent travels to Cuba with his brother, Frederic, made in hopes of restoring his health.

Syria: An end to the hands-off policy. CEPS Commentary, 31 August 2015

After a year of focusing on the nuclear deal with Iran, international diplomacy is returning to consider resolution of the civil war in Syria, with each side now a little less firm in their positions as the situation on the ground deteriorates further. In this new CEPS Commentary Steven Blockmans sheds light on the highly complex and volatile environment in the Middle East, concluding that failure to seize the new diplomatic momentum to resolve this conflict will likely mean that Syria falls into the hands of IS.

Factors influencing the experience of the terminal phase and the grieving process: the primary caregiver’s perspective

Theoretical framework: The experience of the terminal phase and death by patients and caregivers is influenced by multiple factors. This study aimed at understanding this experience from the primary caregiver’s perspective. Objectives: To describe the factors that, from the primary caregiver’s perspective, influenced the experience of disease in the terminal phase and mourning for the death of a close person; To understand the influence of nurses’ conduct on the experience of disease in the terminal phase and mourning for the death of a close person from the primary caregiver’s perspective. Methodology: Qualitative descriptive exploratory study. Results: The following factors were valued: To Assume the Caregiver’s Role, To allow for the end-of-life/terminal phase to take place at home/near the family and Process of Care. Regarding the nurses’ conduct, the knowledge, communication and relationship established by nurses were also valued. Conclusion: In addition to expanding the implementation of specific palliative care teams, the acquisition and development of basic skills in this area by most health care professionals is essential.

Epicardial Radiofrequency Ablation Failure During Ablation Procedures for Ventricular Arrhythmias: Reasons and Implications for Outcomes.

BACKGROUND Radiofrequency ablation (RFA) from the epicardial space for ventricular arrhythmias is limited or impossible in some cases. Reasons for epicardial ablation failure and the effect on outcome have not been systematically analyzed. METHODS AND RESULTS We assessed reasons for epicardial RFA failure relative to the anatomic target area and the type of heart disease and assessed the effect of failed epicardial RFA on outcome after ablation procedures for ventricular arrhythmias in a large single-center cohort. Epicardial access was attempted during 309 ablation procedures in 277 patients and was achieved in 291 procedures (94%). Unlimited ablation in an identified target region could be performed in 181 cases (59%), limited ablation was possible in 22 cases (7%), and epicardial ablation was deemed not feasible in 88 cases (28%). Reasons for failed or limited ablation were unsuccessful epicardial access (6%), failure to identify an epicardial target (15%), proximity to a coronary artery (13%), proximity to the phrenic nerve (6%), and complications (<1%). Epicardial RFA was impeded in the majority of cases targeting the left ventricular summit region. Acute complications occurred in 9%. The risk for acute ablation failure was 8.3× higher (4.5-15.0; P<0.001) after no or limited epicardial RFA compared with unlimited RFA, and patients with unlimited epicardial RFA had better recurrence-free survival rates (P<0.001). CONCLUSIONS Epicardial RFA for ventricular arrhythmias is often limited even when pericardial access is successful. Variability of success is dependent on the target area, and the presence of factors limiting ablation is associated with worse outcomes.

Long-term Responses of Mountain Ecosystems to Environmental Changes: Resilience, Adjustment, and Vulnerability

The steep environmental gradients of mountain ecosystems over short distances reflect large gradients of several climatic parameters and hence provide excellent possibilities for ecological research on the effects of environmental change. To gain a better understanding of the dynamics of abiotic and biotic parameters of mountain ecosystems, long-term records are required since permanent plots in mountain regions cover in the best case about 50 - 70 years. In order to extend investigations of ecological dynamics beyond these temporal limitations of permanent plots, paleoecological approaches can be used if the sampling resolution can be adapted to ecological research questions, e.g. a sample every 10 years. Paleoecological studies in mountain ecosystems can provide new ecological insights through the combination of different spatial and temporal scales. [f we thus improve our understanding of processes across both steep environmental gradients and different time scales, we may be able to better estimate ecosystem responses to current and future environmental change (Ammann et al. 1993; Lotter et al. 1997). The complexity of ecological interactions in mountain regions forces us to concentrate on a number of sub-systems - without losing sight of the wider context. Here, we summarize a few case studies on the effects of Holocene climate change and disturbance on the vegetation of the Western Alps. To categorize the main response modes of vegetation to climatic change and disturbance in the Alps we use three classes of ecological behaviour: "resilience", "adjustment", and "vulnerability", We assume a resilient (or elastic) behaviour if vegetation is able to recover to its former state, regaining important ecosystem characteristics, such as floristic composition, biodiversity, species abundances, and biomass (e.g. Küttel 1990; Aber and Melillo 199 1). Conversely, vegetation displacements may occur in response to climatic change and/or disturbance. In some cases, this may culminate in irreversible large-scale processes such as species and/or community extinctions. Such drastic developments indicate high ecosystem vulnerability (or inelasticity or instability, for detailed definitions see Küttel 1990; Aber and Melillo 199 1) to climatic change and/or disturbance. In this sense, the "vulnerability" (or instability) of an ecosystem is expressed by the degree of failure to recover to the original state before disturbance and/or climatic change. Between these two extremes (resilience vs. vulnerability), ecosystem adjustments to climatic change and/or disturbance may occur, including the appearance of new and/or the disappearance of old species. The term "adjustment" is hence used to indicate the response of vegetational communities, which adapted to new environmental conditions without losing their main character. For forest ecosystems, we assume vegetational adjustments (rather than vulnerability) if the dominant (or co-dominant) tree species are not outnumbered or replaced by formerly unimportant plant species or new invaders. Adaptation as a genetic process is not discussed here and will require additional pbylogeographical studies (that incorporate the analysis of ancient DNA) in order to fully understand the distributions of ecotypes.

Evaluation of California's safety belt law change to primary enforcement. Final report.

National Highway Traffic Safety Administration, Washington, D.C.

Aircraft accident report : crash during approach to landing, Circuit City Stores, Inc., Cessna Citation 560, N500AT, Pueblo, Colorado, February 16, 2005 /

On February 16, 2005, about 0913 mountain standard time, a Cessna Citation 560, N500AT, operated by Martinair, Inc., for Circuit City Stores, Inc., crashed about 4 nautical miles east of Pueblo Memorial Airport, Pueblo, Colorado, while on an instrument landing system approach to runway 26R. The two pilots and six passengers on board were killed, and the airplane was destroyed by impact forces and postcrash fire. The flight was operating under the provisions of 14 Code of Federal Regulations Part 91 on an instrument flight rules flight plan. Instrument meteorological conditions prevailed at the time of the accident. The National Transportation Safety Board determines that the probable cause of this accident was the flight crew's failure to effectively monitor and maintain airspeed and comply with procedures for deice boot activation on the approach, which caused an aerodynamic stall from which they did not recover. Contributing to the accident was the Federal Aviation Administration's failure to establish adequate certification requirements for flight into icing conditions, which led to the inadequate stall warning margin provided by the airplane's stall warning system.

Memorials to U.S. Senate.

Binder's title.

Threatening Messages in Climate Change Communication

Thesis (Ph.D.)--University of Washington, 2016-06

Methods to Control for Bias in Observational Studies

Thesis (Master's)--University of Washington, 2016-06

Not being what you claim to be: impostors as sources of group threat

We examine the notion of impostors within groups, defined in this paper as people who make public claims to an identity while disguising their failure to fulfil key criteria for group membership. In Experiment 1, vegetarians showed heightened levels of negative affect toward vegetarians who ate meat occasionally compared to an authentic vegetarian. In contrast, non-vegetarians saw the impostor to be marginally more likeable than the authentic vegetarian. In Experiments 2 and 3, participants evaluated only a vegetarian who ate meat. Evaluations of the target were influenced by group attachment, such that participants who identified strongly as vegetarians downgraded the target more strongly and experienced more negative affect than did moderate identifiers and non-vegetarians. Participants were also sensitive to the size of the gulf between the target's claims for identity and their behaviour. Thus, targets who made public claims to being a vegetarian but ate meat were evaluated more negatively than were people who kept their claims for identity private (Experiment 2). Similarly, targets who tried to keep their deviant behaviour secret were evaluated more negatively than were people who openly admitted their deviant behaviour (Experiment 3). The reasons why impostors might threaten the integrity of group identities are discussed. Copyright (C) 2003 John Wiley Sons, Ltd.

Differences in ethical attitudes between registered nurses and medical students

In this study we compared the ethical attitudes of a group of experienced, predominantly female, registered nurses (n = 67) with those of a group of final year, mixed sex, medical students (n = 125). The purpose was to determine the basis of differences in attitudes that could lead to ethical disagreements between these two groups when they came to work together. A questionnaire developed to explore ethical attitudes was administered and the responses of the two groups were compared using t-tests. Because of the preponderance of females among the nurses an analysis of variance of the gender-adjusted scores for each group was also carried out. On comparing the responses, the nurses differed significantly from the medical students in a number of ethical domains. A potential source of conflict between these two groups is that the nurses were inclined to adopt the perspective of patients but the medical students identified with their profession. When corrected for the effects of gender, the differences persisted, indicating that it was discipline that determined the differences. We recommend that students of nursing and medicine receive ethics education together, and that more open dialogue between doctors and nurses with respect to their different ethical viewpoints is needed in the work setting. This article will be of interest to educators of students of medicine and nursing, as well as to doctors and nurses who are eager to improve their professional relations and thereby improve patient care.