The First Universal Suffrage Election, at County (Gewog) Level, in Bhutan

Following a Royal Edict to adopt universal suffrage in election for local government institutions, maiden elections were held in 199 gewogs (counties) in Bhutan in 2002 to elect their chief executives. This paper gives an account of this first time event in a country where most villagers had never seen secret ballots and poll booths. It synthesizes detailed data, mostly qualitative, collected soon after the election was over, and assesses aspects of electoral participation that His Majesty the King of Bhutan has introduced steadily to deepen democracy. Beginning with a glance at the territorial organization of the Bhutanese state within which the counties are embedded, the paper compares the electoral results with the relevant election rules.

2.1 Boone County Courthouse, Columbia, Missouri

July 10, 1936 was an extremely warm day in central Missouri when Lloyd Gaines, accompanied by his attorneys, arrived at the Boone County Courthouse in Columbia, Missouri to begin deliberations in the historic Gaines v Canada case.

2.4 Judge W. M. Dinwiddie Boone County, Missouri, 13th Circuit Court

Two weeks later, Judge Dinwiddie issued his decision in favor of Canada and the University. Houston was expecting this and appealed to the Missouri Supreme Court.

2. 6 Memorial for Lloyd Gaines, St. Peter's Cemetery, Normandy, St. Louis County, Missouri

What happened to Gaines? There are many ideas ranging from being murdered or lynched, being bribed to run away, or disappearing on his own to get away from the pressure of celebrity. That final possibility was brought about by Dr. Greene, who claimed that a man who sounded like Gaines had phoned him while in Mexico and wished to meet. The man never showed up. A recent theory is one of where Lloyd was kidnapped by opponents of the Gaines court decision who took him to Jefferson City and lynched him in McClung Park. All of these theories are speculation and the fact remains that Lloyd Gaines’ whereabouts are a mystery to this day.

Screening for chlamydial infections and the risk of ectopic pregnancy in a county in Sweden: ecological analysis

Objectives: To analyse trends in rates of genital chlamydial infection and ectopic pregnancy between 1985 and 1995 in a county in Sweden.

A few autoreactive cells in an autoimmune infiltrate control a vast population of nonspecific cells: a tale of smart bombs and the infantry.

Inflammatory infiltrates in tissue-specific autoimmune disease comprise a collection of T cells with specificity for an antigen in the target organ. These specific cells recruit a population of nonspecific T cells and macrophages. The rare tissue-specific T cells in the infiltrate have the capacity to regulate both the influx and the efflux of cells from the tissue. Administration of an altered peptide ligand for the specific T cell which triggers autoimmunity can lead to the regression of the entire inflammatory ensemble in a few hours. Interleukin 4 is a critical cytokine involved in the regression of the inflammatory infiltrate.

The Future Direction of Delaware Law (Including a Brief Exegesis on Fee Shifting Bylaws)

Delaware sets the governance standards for most public companies. The ability to attract corporations could not be explained solely by the existence of a favorable statutory regime. Delaware was not invariably the first or the only state to implement management friendly provisions. Given the interpretive gaps in the statute and the critical importance of the common law in the governance process, courts played an outsized role in setting legal standards. The management friendly nature of the Delaware courts contributed significantly to the state’s attraction to public corporations. A current example of a management friendly trend in the case law had seen the recent decisions setting out the board’s authority to adopt bylaws under Section 109 of the Delaware General Corporation Law (DGCL), particularly those involving the shifting of fees in litigation against the corporation or its directors. The DGCL allows bylaws that address “the business of the corporation, the conduct of its affairs, and its rights or powers or the rights or powers of its stockholders, directors, officers or employees.” The broad parameters are, however, subject to limits. Bylaws cannot be inconsistent with the certificate of incorporation or “the law.” Law includes the common law. The Delaware courts have used the limitations imposed by “the law” to severely restrict the reach of shareholder inspired bylaws. The courts have not used the same principles to impose similar restraints on bylaws adopted by the board of directors. This can be seen with respect to bylaws that restrict or even eliminate the right of shareholders to bring actions against management and the corporation. In ATP Tour, Inc. v. Deutscher Tennis Bund the court approved a fee shifting bylaw that had littl relationship to the internal affairs of the corporation. The decision upheld the bylaw as facially valid.The decision ignored a number of obvious legal infirmities. Among other things, the decision did not adequately address the requirement in Section 109(b) that bylaws be consistent with “the law.” The decision obliquely acknowledged that the provisions would “by their nature, deter litigation” but otherwise made no effort to assess the impact of this deterrence on shareholders causes of action. The provision in fact had the practical effect of restricting, if not eliminating, litigation rights granted by the DGCL and the common law. Perhaps most significantly, however, the bylaws significantly limited common law rights of shareholders to bring actions against the corporation and the board. Given the high dismissal rates for these actions, fee shifting bylaws imposed a meaningful risk of liability on plaintiffs. Moreover, because judgments in derivative suits were paid to the corporation, shareholders serving as plaintiffs confronted the risk of liability without any offsetting direct benefit. By preventing suits in this area, the bylaw effectively insulated the behavior of boards from legal challenge. The ATP decision was poorly reasoned and overstepped acceptable boundaries. The management friendly decision threatened the preeminent role of Delaware in the development of corporate law. The decision raised the specter of federal intervention and the potential for meaningful competition from the states. Because the opinion examined the bylaw in the context of non-stock companies, the reasoning may remain applicable only to those entities and never make the leap to for-profit stock corporations. Nonetheless, the analysis reflects a management friendly approach that does not adequately take into account the impact of the provision on the rights of shareholders.

Staying in the Delaware Corporate Governance Lane: Fee Shifting Bylaws and a Legislative Reaffirmation of the Rules of the Road

The Delaware legislature has taken steps towards the adoption of amendments to the Delaware General Corporation Law (DGCL) that would prohibit fee shifting provisions in the articles and bylaws. The language in the legislative proposal, however, addresses fee shifting provisions only in the context of "internal corporate claims." Some have raised concerns that this language would allow for fee shifting provisions that applied to other types of actions, including at least some cases brought under the securities laws. This piece suggests that in fact the Delaware General Corporation Law already prohibits the adoption of bylaws and certificate provisions that apply to causes of action unrelated to internal corporate claims. As a result, there was no reason for the Delaware legislature to expressly bar fee shifting provisions in these types of actions.