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Although the three-step framework governing partisan gerrymandering claims under the Equal Protection Clause is not in dispute chronic superficial gastritis diet generic 10 mg maxolon with mastercard, neither the Supreme Court nor the parties agree as to gastritis unspecified icd 9 code order maxolon 10 mg visa the standard of proof for each of those A gastritis uptodate buy maxolon 10mg with amex. The discriminatory purpose or intent requirement extends to Equal Protection challenges to redistricting plans, in particular, including partisan gerrymandering challenges. Rather, "an invidious discriminatory purpose may often be inferred from the totality of the relevant facts. In determining whether an "invidious discriminatory purpose was a motivating factor" behind the challenged action, evidence that the impact of the challenged action falls "more heavily" on one group than another "may provide an important starting point. Likewise, "[t]he historical background of the decision" may be probative of discriminatory intent, "particularly if it reveals a series of official actions taken for invidious purposes. In describing the intent requirement for Equal Protection claims in Arlington Heights, the Supreme Court held that a plaintiff generally 16 need not prove that a legislature took a challenged action with the "sole," "dominant," or "primary" purpose of discriminating against an identifiable group. The Court rejected such a heightened intent requirement because "[t]he search for legislative purpose is often elusive enough. As explained above, there are a number of purposes for which a state redistricting body permissibly may rely on political data or take into account partisan considerations. Accordingly, a plaintiff in a partisan gerrymandering case cannot satisfy the discriminatory intent requirement simply by proving that the redistricting body intended to rely on political data or to take into account partisan considerations. Rather, the plaintiff must show that the redistricting body intended to apply partisan classifications "in an invidious manner or in a way unrelated to any legitimate legislative objective. Additionally, "[t]he legislative or administrative history may be highly relevant, especially where there are contemporary statements by members of the decision-making body, minutes of its meetings, or reports. Although the discriminatory intent requirement and the types of evidence probative of such intent are well-established, it remains unclear what level of intent a plaintiff must prove to establish a partisan gerrymandering claim. For example, if a partisan purpose "predominated" over other legitimate redistricting criteria, then the 2016 Plan warrants strict scrutiny, Common Cause Plaintiffs maintain. If partisan advantage was only "a purpose" motivating the 2016 Plan, then, according to Common Cause Plaintiffs, the plan should be reviewed under the "sliding scale" standard of review set forth in Anderson v. By contrast, League Plaintiffs argue that Supreme Court precedent forecloses a "predominant" or "sole" intent standard in partisan gerrymandering cases. In Bandemer, the plurality opinion did not require that a plaintiff establish the mapmakers were solely or primarily motivated by invidious partisanship, but instead required proof of "intentional discrimination against an identifiable political group. And in Vieth, the plurality expressly rejected a "predominant" intent standard as judicially unmanageable. Second, the legislative process "[d]epart[ed] from the normal procedural sequence. Hofeller regarding the criteria he should follow in drawing the 2016 Plan before they had been appointed co-chairs of the Committee and before the Committee debated and adopted those criteria. Hofeller completed drawing the 2016 Plan before the Committee met and adopted the governing criteria. And notwithstanding that the Committee held public hearings and received public input, Dr. Hofeller never received, much less considered, any of that input in drawing the 2016 Plan. Third, the plain language of the "Partisan Advantage" criterion reflects an express legislative intent to discriminate-to favor voters who support Republican candidates and subordinate the interests of voters who support non-Republican candidates. The official explanation of the purpose behind that criterion by Representative Lewis-who co-chaired the Committee and, in that capacity, developed the Adopted Criteria and oversaw the drawing of the 2016 Plan- demonstrates as much. Representative Lewis explained that "to the extent [we] are going to use political data in drawing this map, it is to gain partisan advantage. And Representative Lewis "acknowledge[d] freely that this would be a political gerrymander," Id. To that end, a plaintiff satisfies the discriminatory purpose or intent requirement by introducing evidence establishing that the state redistricting body acted with an intent to "subordinate adherents of one political party and entrench a rival party in power. Several aspects of the 2016 redistricting process establish that the General Assembly sought to advance the interests of the Republican Party at the expense of the interests of non-Republican voters. First, Republicans had exclusive control over the drawing and enactment of the 2016 Plan. And with the exception of one small change to prevent the pairing of Democratic incumbents, Dr. Hofeller finished drawing the 2016 Plan before Democrats had an opportunity to participate in the legislative process. Additionally, all of the key votes -including the Committee votes adopting the Political Data and Partisan Advantage criteria and approving the 2016 Plan, and the House and Senate votes adopting the 2016 Plan-were decided on a party-line basis.

It is also reasonable that gastritis hernia generic maxolon 10 mg, in agreement with findings of neuropsychology (see Chapters 4 and 5) gastritis diet food recipes purchase generic maxolon line, the prefrontal cortex and its elements take part in the representation in memory and the execution of complex plans of behavior gastritis symptoms nih buy maxolon 10mg fast delivery. Averbeck and Lee (2007) provide another recent example of the cellular representation of behavioral sequences in the prefrontal cortex. It is also evident that regions of the prefrontal cortex originate substantial controlling outputs to hypothalamic and limbic structures that modulate emotional behavior, instincts, and drives. It is erroneous, however, as Damasio (1994) has persuasively argued, to dissociate the function of these prefrontal regions from those of lateral prefrontal cortex; both are anatomically intertwined. It is equally erroneous to dissociate cognitive functions, especially executive functions, from the powerful role of those internal inputs and drives. Indeed, those inputs and drives are to some degree determinant of any decision and course of action, however exclusively cognitive those may appear. Since the latter part of the nineteenth century (Schiff, 1875; Munk, 1882), it has been known that by faradizing certain areas of the frontal cortical surface it is possible to induce a variety of visceral changes. This is a transitional area that may be considered limbic by virtue of its development, architecture, and connections, yet also prefrontal by virtue of its relationships with the mediodorsal nucleus of the thalamus. The most prominent effects of stimulating the orbitofrontal cortex have been noted in the cardiovascular system, and include changes in blood pressure, heart rate, cardiac dynamics, and skin temperature (Bailey and Sweet, 1940; Livingston et al. The size of each circle is proportional to the number of category-selective cells recorded at each location. Note that the cell is most active in preparation for sequences of the "paired" category, regardless of component movements. Effects on respiration (Smith, 1938; Bailey and Sweet, 1940; Kaada, 1951), epinephrine release (Euler and Folkow, 1958), and plasma cortisol (Hall and Marr, 1975) have also been observed. This is in accord with the conclusion, derived from studies of visceral afferents to the cortex, that the posterior orbital area constitutes the cortical representation of the vagus (Bailey and Bremer, 1938; Dell and Olson, 1951; Encabo and Ruarte, 1967). As noted above, stimulation of that area can induce sleep (Kaada, 1951; Clemente and Sterman, 1967; Alnaes et al. In rodents, judging from the effects of lesions and stimulation, both the medial and the lateral prefrontal cortex appear to be involved in autonomic control (for review, see Neafsey, 1990). Especially remarkable, though not yet precisely defined, seems to be the role of medial cortex in the regulation of the visceral and humoral concomitants of stress and defense (Thierry et al. Whereas in the rat the medial cortex is obviously involved in the efferent ("motor") aspects of visceral function, the lateral and orbital cortices appear to be the substrates of visceral representation. A particular aspect of visceral representation is visceral pain, which is transmitted via the spinothalamic tract and, through the nucleus submedius of the thalamus, to the orbital prefrontal cortex (Craig et al. Perhaps the severance of this pathway is the reason for the efficacy of prefrontal lobotomy in the treatment of intractable pain (Falconer, 1948; Freeman and Watts, 1948). Conversely, as part of the reward structures yielding self-stimulation (Routtenberg, 1971; Goeders et al. The endocrine and autonomic effects that result from stimulating orbital prefrontal cortex are most probably mediated by the efferent fibers from this cortex to the hypothalamus, the amygdala, and other limbic structures (see Chapter 2) involved in visceral function and emotion (Le Doux, 1993). Furthermore, the prefrontal outflow to the hypothalamus plays a role in the inhibitory control of instinctual and emotional behaviors that are accompanied by endocrine and autonomic changes. This, as we see next, has been substantiated electrophysiologically with regard to both feeding behavior and aggressive behavior. As mentioned in Chapters 4 and 5, lesions of the orbital prefrontal cortex, in animals and in humans, frequently induce hyperphagia. This phenomenon can be inferred to result from the disinhibitory release of hypothalamic centers mediating feeding behavior, especially the lateral hypothalamic area and the ventromedial nucleus, which are known to be involved in satiety and regulation of eating (Hetherington and Ranson, 1940; Brobeck et al. Excessive eating would be the consequence of liberating those centers from prefrontal control. In accord with this interpretation, electrical orbitofrontal stimulation in the cat has been shown to inhibit eating behavior (Siegel and Wang, 1974). Furthermore, inhibitory prefrontal projections to the lateral hypothalamus (Kita, 1978) and to the ventromedial nucleus (Ohta and Oomura, 1979a) have been electrically demonstrated. It is reasonable to conclude that these parts of the hypothalamus, which are known to be sensitive to glucose levels in the blood (Oomura et al. Somewhat parallel phenomena and mechanisms have been revealed experimentally with respect to aggression. They seem to vary considerably from species to species and in relation to the extent and location of the lesion: in carnivores large prefrontal lesions tend to increase aggressive behavior, but in monkeys this is not the case, except possibly as a result of dorsolateral lesions, and then only because (as noted in Chapter 4) such lesions induce cognitive deficits indirectly conducive to aggressive acts. In the cat and the rat, orbitofrontal lesions lower the threshold for attack behavior, either spontaneous or induced by stimulation of the lateral hypothalamus (Sato, 1971; Sato et al.

Originally meaning homesickness gastritis diet ���� buy generic maxolon 10 mg line, but in the twentieth cen 44 Glossary mry its meaning has expanded to gastritis symptoms come and go buy maxolon 10mg visa include a special kind of memory involving periodic mental states gastritis symptoms lightheadedness cheap maxolon 10 mg otc, usually the result of discontinuities in life experience. Not just sentimental memories, nor mere looking back in time, but in the words of Fred Davis (Yearning for Yesterday:A Sociotogy of Nostalgia), "nostalgia thrives on the subjective apprehen sion of transition. Davis discusses gender differences, saying that men are more likely to experience nostalgic sequences than are women, because of the dis tinct discontinuities in their lives. Comparable to table talk, conversation, and similar informal, unpremeditated comments often recalled in biography. A record or announcement of a death or deaths, usually pub lished in a newspaper or current journal or magazine. Obituaries may vary considerably in length, from hardly more than lists to several hundred words, usually depending on the fame of the deceased. Longer than most obituaries, memorials are made by institutional colleagues, nowadays less eulogistic than formerly, but in general friendly in tone. What is presented to consciousness as opposed to conscious ness itself the purely objective, as opposed to subjective, biography Glossary 45 treats its subject so as to exhibit the actual facts, the external events, not colored by the feelings or opinions of the writer. Although objec tivity, or detachment, is a desirable quality in a biography, in an extreme form it may interfere with the interpretative function of the work and result in a mere compilation of factual data. All biographi cal works, even the longest and most detailed, are the result of selec tion and the process of selection is itself a subjective matter. The par allel between objective and subjective is similar to that between inductive and deductive. The use of the sense of smell is rare in novels, poetry, and most nonfiction, but in lives of autobiographers the sense of smell is espe cially related to reminiscences of childhood and youth, perhaps in part because odors are apt to revive in the imagination scenes and places of the past. Among poets Shakespeare and Keats are especial ly odor-conscious, and biographers of such figures need to be aware of such a characteristic. Although the meaning of the term is evident from the two words, it generally now refers to the tape recording of reminiscences about which the narrator can speak with firsthand knowledge. Since the Second World War there have been remarkable advances in oral history and the accumulation of tapes in such major collections as that at Columbia University, where the work of Allan Nevins in the 1940s led to a great hoard of unpublished recollections, a tremendous memory bank of Americana. Starr in their book on the Columbia Oral History Collection (1973) say that "Biographies make up the largest category of books drawing upon Oral History at Columbia. In over four hundred pages, made up entirely of quota tions, a central character and her surrounding family and associates are clearly revealed. From otology, the science of the ear; the term is used by Jacques Derrida (The Ear of the Other: Otobiography, Transference, Transtation, 1985) in his discussion of the ear as a perceiving organ in relation to autobiography and interpretation. Brief life, often fictional though written in biographical form, published cheaply in paper covers; popular in Elizabethan times, continued in great numbers until they were supplanted by the developing journalism of the late seventeenth and early eighteenth centuries. Formal or elaborate encomium or eulogy; in biography, writing devoted to high praise of its subject. The panoramic method in life-writing is one that gives the background, the overall view of the age in which the subject lives; this method is especially characteristic of historical biography and was practiced to an extreme by Philip Guedalla, where pages of often irrelevant background material were presented. Imitation of style or subject matter for purposes of ridicule; an unusual form in life-writing, essentially the same as mock biography. Biography or autobiography that emphasizes negative elements in a life: failure, unhappiness, the tragic, and especially ill ness. Hawkins, Reconstructing Illness: Studies in Pathography, 1993: "personal accounts of struggles with chronic, pro gressive illness and. Another derogatory term used to characterize lives that sensationalize or diminish a person, in generally short and scandalous accounts, under such titles as Jackie Oh! The mask is more characteristic of literary forms other than biography and autobiography, but someone like Henry Adams, in using the third person in the Education of Henry Adams, was in a way using a persona to avoid subjectivity, or to gain objec tivity. Autobiographical essays, or informal short reflections on various aspects of personal experience, were especially popular in the nineteenth century; however, the essay [essar] was invented by Montaigne in 1580 and his influence on writing extends down through the centuries, especially as a result of the strongly autobio graphical element and the skeptical view of his contemporaries in his Essais. In modern literary criticism, particularly in the open ing years of the so-called "New Criticism," one of the major contro versies was that between C. The six articles published in Essays and Studies (1934, 1935, 1936) have been collected in the Personal Heresy:A Controversy by Oxford University Press (1 939; 1965 in paper). Although this discussion has to do with the critical reading of poetry, it is of importance to the biographer of literary figures, par ticularly in relation to his use of poems, novels, etc. The most obvious danger is the use of fictional material as though it were biographical fact, or the use of poetry written in the first person as though it were straight autobiography.

Its cells have the longest leadtimes before actions gastritis garlic generic 10mg maxolon otc, presumably intervening before cells in the other cortices in the preparation of those actions chronic gastritis operation cheap 10mg maxolon mastercard. From the prefrontal cortex on down gastritis znacenje generic maxolon 10mg on-line, it appears that the organization and preparation of action gets to progressively more concrete detail as it proceeds to premotor cortex and, ultimately, to the precentral motor strip, where the "microgenesis of the action" (Brown, 1987) ultimately takes place. Rules Actions are prepared and executed in response to present or recent stimuli, with or without the assistance of working memory to mediate cross-temporal contingencies between the stimuli and the actions. In addition, however, an action is prepared and executed in accord with a set of rules that the individual has learned beforehand or has recently been instructed to follow. These rules specify what exactly the subject must do with the available stimuli or cues for optimal results, that is, for the attainment of maximum reward value. In the tests of rule effects on behavior or on frontal physiology, a rule is ordinarily symbolized by a stimulus or verbal command preceding a test trial or set of trials and instructing the subject as to how to get set for and handle subsequent stimuli. Insofar as the rules have a temporal term, however (that is, insofar as the applicable rule at a given time depends on a certain pre-trial cue and is only applicable at that time to that trial or group of trials), it can be considered part of working memory and probable subject to the same mechanisms that maintain and discard working memory. Thus the rule can be viewed as an overlay of working memory, a layer of "conditional" working memory interacting with the particular sensory stimulus that serves as the memorandum or discriminandum for the trial. Furthermore, insofar as the rules have been previously learned or are made of material that the subject can associate with other material of previous experience, the rules are part of long-term memory. They belong to the category of abstract executive memories or networks that lie in the higher levels of the frontal executive hierarchy. As will be argued later in this volume (Chapter 8), rules, like plans, programs, and schemas of sequential action, as well as the contents of working-memory, are made of executive networks that differ structurally, in synaptic makeup and hierarchical rank, and functionally, in degree of activation at any given time. Thus, the physiological evidence for the prospective coding of rules in frontal cortex can be reasonably interpreted as evidence for the representation of executive memory in that cortex. Naturally, it is also evidence for the role that that memory and its networks play in the preparation of action. It appears that the expression "prospective coding" was first used by Rainer et al. They described prefrontal cells that, during the delay, anticipated and discriminated the second, expected stimulus. These observations attest to the integrative capacity of prefrontal cells, although the use of the term "coding" may be somewhat misleading, because the coding is not done by single cells but by cell populations. Typically in rule-shifting tasks, the behavioral implication of sensory stimuli, and thus the motor response to them, changes with the anteceding or concomitant presence of another stimulus, which has been called the conditional or contextual cue. A later study (Wallis and Miller, 2003a) shows rule activity in both prefrontal and premotor cortex, with a greater involvement of the latter than the former in the motor response, as predicted by the top-down hierarchical organization of action in the frontal lobe. Reward Value Above, in the discussion of cellular activity in delay tasks, we noted the presence of neurons, notably in orbital cortex, that responded to the reward that the animal received at the end of the trial. Now we know, thanks to research carried out in many labs since the last edition of this book, that "reward cells" not just respond to available reward but may anticipate it, in other words prospectively code that reward, 262 50 40 Firing rate (Hz) 30 20 10 0 0 50 40 Firing rate (Hz) 30 20 10 0 Sample 500 1000 1500 Sample Sample object 1 Delay 6. Under the "match" rule, the monkey is supposed to retain the sample stimulus during the delay for matching to a second stimulus. Under the "non-match" rule, the animal is supposed to chose the stimulus not matching the sample. Bottom: Activity of a cell before and after four different sample stimuli under the two rules. Thus, for example, in a delay task the cells may already encode the nature of the expected reward during the delay period. Neurons that anticipate reward or "motivational context" by activated discharge can be found in dorsolateral as well as orbitomedial areas of the prefrontal cortex of the monkey in a variety of behavioral paradigms (Watanabe, 1996; Leon and Shadlen, 1999; Amador et al. By their frequency of discharge, rewardanticipating cells encode not only the quantity but also the quality of the expected reward (Tremblay and Schultz, 1999, 2000; Wallis and Miller, 2003b; Roesch and Olson, 2004, 2005). Records begin in the middle of the first delay and terminate at the choice saccade. Unit A shows higher firing if the chosen picture predicts four drops, versus eight or two.

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