Lyrebirds filmed in Sherbrook forest by the study's co-auther Alex Maisey. Source: Dalziell et al. 2021
Only a team as offensively challenged could drive Curry to shoot this much. The game has never demanded more from Curry and we are the winners as a result.
Imagine 'The Real World' with social media influencers who already know each other.
The Biden Administration has brought new energy to the proposed wealth tax. This tax seems to have become more than a campaign promise of Senator Elizabeth Warren. In 2021, Senator Warren revived the legislation and reintroduced it as the S.510 Ultra- Millionaire Tax Act of 2021.
Santa Clara University behavioral-finance professor Meir Statman and his wife Navah Statman are giving $3 million for faculty excellence at SCU.
Broadstone Real Estate Access Fund ("BDREX" or the "Fund"), a closed-end interval fund, registered under the Investment Company Act of 1940, announced a liquidating distribution of $3.1593 per share for Class I and Class W. This represents a distribution of $16M or 34% of the Fund’s net asset value as of April 19, 2021. The distribution is payable on April 22, 2021 to shareholders of record as of April 19, 20211. BDREX is managed by Benefit Street Partners, L.L.C. ("BSP").
Quanterix Corporation (NASDAQ:QTRX), a company digitizing biomarker analysis to advance the science of precision health, today announced a webinar with leading industry experts to discuss neurological advancements related to the ultra-sensitive quantification of pTau181, pTau217, pTau231, and other neurological biomarkers. With several pharmaceutical companies making significant advances towards approval of Alzheimer's Disease therapies, this webinar discussion and live Q and A will further show the opportunity for blood plasma biomarkers combined with Simoa® technology to help advance Alzheimer’s clinical trials and diagnostics.
AM Best has affirmed the Financial Strength Rating (FSR) of A+ (Superior) and the Long-Term Issuer Credit Ratings (Long-Term ICRs) of "aa-" of Intact Insurance Company and the subsidiaries of Intact Financial Corporation (IFC). In addition, AM Best has affirmed the Long-Term ICR of "a-" and the Long-Term Issue Credit Ratings (Long-Term IRs) of the parent holding company, IFC [TSX: IFC]. In addition, AM Best has affirmed the Long-Term ICR of "a-" and the Long-Term IR of Intact U.S. Holdings, Inc. (Delaware). The outlook of these Credit Ratings (ratings) is stable. (Please see link below for a detailed list of the companies and Long-Term IRs.) All companies are domiciled in Ontario, Canada, unless otherwise specified.
(Bloomberg) -- Oil edged higher as gains on signs of strengthening demand in key economies offset concern around the rampant virus resurgence in countries such as India.West Texas Intermediate snapped a back-to-back streak of declines after flipping between modest gains on losses on Thursday. Gasoline demand is improving in the U.S., while jobless claims in the country have fallen to the lowest since the pandemic began. But casting a cloud over bright spots there, India -- the world’s third largest oil importer -- posted the world’s largest one-day jump in coronavirus cases.“Demand is not outstripping expectations at this point,” said Rob Haworth, senior investment strategist at U.S. Bank Wealth Management. “Until we get reopened and travel and activity really picks up again, that leaves the market in a betwixt and between spot.”It’s an increasingly complex global demand picture for the market to get a handle on. Japanese Prime minister Yoshihide Suga recommended placing Tokyo and other cities under a state of emergency months before the capital hosts the Olympics. But there is a much more optimistic outlook in the U.S. Refining margins have significantly improved with gasoline demand at 93% of pre-pandemic levels and diesel demand fully recovered, Valero Energy Corp. Chief Executive Officer Joe Gorder said in a conference call with analysts.“We’re pretty bullish on gasoline going forward,” Valero Chief Commercial Officer Gary Simmons said on the same call. “As people return to a normal-style life, we’re seeing that people are driving more and kind of avoiding mass transit for the summer season”Even as persistent Covid crises threaten demand, some countries are mapping out plans to open up. Among them, France will lift curbs on regional movement and reopen schools in the coming weeks, and Greece will ease most lockdown measures in May before welcoming back tourists.Outside the U.S., the U.K. is also showing signs of a robust demand recovery taking place. U.K. government data shows average road fuel sales last Friday topped pre-pandemic levels for the first time since September.On the supply side, the OPEC+ coalition is set to start returning more barrels to the market next month. Traders are also watching for a potential relaxation of American sanctions on Iran, though the U.S. has talked down the prospect of an imminent deal.“Oil markets are likely to be stuck in a holding pattern until next week’s OPEC+ supply decision is announced,” said Ryan Fitzmaurice, commodities strategist at Rabobank. It is likely for “more range-bound trade to take place until the market gets more clarity on both the supply and demand front as we approach the all-important summer driving season.”For more articles like this, please visit us at bloomberg.comSubscribe now to stay ahead with the most trusted business news source.©2021 Bloomberg L.P.
The leader emphasized that Brazil has accounted for less than 1 per cent of historic greenhouse gas emissions
The Internal Revenue Service is holding 29 million returns for manual processing — delaying refunds for many — because of pandemic-related law changes, processing errors, and fraud detection.
‘The question of vaccines and how to basically require them, and even from a logistical standing, frankly – all of that, we’re taking a look at’
Bevan French has marked his return to action with two tries in his first match of the season as Wigan Warriors beat Castleford 22-12 in a thrilling and tough encounter.Back in the side after missing the opening three weeks of the season, the Australian flyer immediately showed what Wigan had been missing as he went over for a try with three minutes left in the first half on Thursday.
Follow the latest updates on day of global environmental talks
On Thursday, Biden hosted an international climate summit with world leaders at which he pledged to cut U.S. carbon emissions by at least 50 percent by 2030 over 2005 levels.
Key players operating in the Air Quality Monitoring System market are Thermo Fisher Scientific, Emerson Electric, General Electric, Siemens AG, Teledyne Technologies, PerkinElmer, Inc., Agilent Technologies, Inc., Spectris plc., 3M Company, and Honeywell International Inc.Vancouver, British Columbia, April 22, 2021 (GLOBE NEWSWIRE) -- The global air quality monitoring system (AQMS) market size is expected to reach USD 6.78 Billion in 2028 and register a steady CAGR during the forecast period, according to latest analysis by Emergen Research. Some key factors attributed to steady market revenue growth are continuously technological developments and advancements in continuous air quality monitoring systems, rising adoption of green-building technologies and smart homes, various government initiatives supporting green initiatives, and rising public awareness regarding the importance of environment conservation. Claim Your FREE Sample Copy with Table of content@ https://www.emergenresearch.com/request-sample/631 Rapid advancements of technologies such as IoT systems, WSN, cloud computing, gas sensing, and other technologies are expected to drive market growth to a significant extent going ahead. Major players are currently focused on various research activities to develop satellite-based air quality monitoring systems. Satellite-based remote sensor technology measures the concentration level of pollutants in the atmosphere through interference in light emitted or reflected from earth. Growing importance of technical standardization of organizations on the implementation of advanced measuring principles such as ultraviolet fluorescence measuring principle is a key factor fueling revenue growth of the global market. Some Key Findings From the Report: Key players operating in the market are Thermo Fisher Scientific, Emerson Electric, General Electric, Siemens AG, Teledyne Technologies, PerkinElmer, Inc., Agilent Technologies, Inc., Spectris plc., 3M Company, and Honeywell International Inc.In April 2020, Kaiterra acquired ChemiSense. This acquisition helped Kaiterra to expand its global footprint and provide a range of air quality monitoring devices to existing and new customers.Continuous monitoring segment accounted for largest revenue share in the global market in 2020. This can be attributed to implementation of supportive government policies for effective air pollution monitoring and constant technological development in advanced continuous monitoring systems.North America accounted for a 31.6% revenue share in the global market in 2020. Rapid adoption of advanced technologies and presence of stringent government policies for effective pollution control and monitoring are major factors driving revenue growth of the market in this region. Check Our Prices@ https://www.emergenresearch.com/select-license/631 For the purpose of this report, Emergen Research has segmented the global air quality monitoring systems (AQMS) market based on product, sampling method, pollutant, end-use, and region: Product Outlook (Revenue, USD Billion; 2018–2028) Indoor Monitors FixedPortable Outdoor Monitors FixedPortableAQM StationsDust & Particulate Wearables Sampling Method Outlook (Revenue, USD Billion; 2018–2028) Continuous MonitoringPassive MonitoringIntermittent MonitoringManual MonitoringStack Monitoring Pollutant Outlook (Revenue, USD Billion; 2018-2028) Physical PollutantsChemical PollutantBiological Pollutants End-Use Outlook (Revenue, USD Billion; 2018–2028)$1$1$1 Residential and Commercial IndustryGovernment Agencies and Academic InstitutionsPetrochemical IndustryPower Generation PlantsPharmaceutical IndustrySmart City AuthorityOthers Click to access the Report Study, Read key highlights of the Report and Look at Projected Trends: https://www.emergenresearch.com/industry-report/air-quality-monitoring-system-market Regional Outlook (Revenue: USD Billion; 2018–2028) North America U.S.CanadaMexico Europe GermanyFranceU.K.BENELUXItalySpainRussiaRest of Europe Asia Pacific China JapanSouth KoreaIndiaRest of APAC Latin America BrazilRest of LATAM Middle East & Africa Saudi ArabiaUAESouth AfricaTurkeyRest of MEA Take a Look at our Related Reports: Structured Cabling Market By Solution (Service, Product, Software), By Cable Type (Category 6, Category 5E, Category 6A, Others), By End-Use (IT & Telecommunication, Residential & Commercial, Government & Education, Transportation, Industrial, Others) and By Region Powered Agriculture Equipment Market By Type (Combine Harvesters, Tractors, Soil Preparation & Cultivation Equipment), By Next generation equipment (Agricultural Unmanned Aerial Vehicles, Driverless Tractors, Electric Tractors), and By Region, Forecast to 2028 Next-Generation Biomanufacturing Market By Type (Continuous Upstream Biomanufacturing, Single-Use Upstream Biomanufacturing, Downstream Biomanufacturing), By Application (Monoclonal Antibodies, Hormones, Vaccines, Recombinant Proteins, Others), By End-Use (Biopharmaceutical Companies, Research Institutions, CMOs/CDMOs), By Region About Emergen Research Emergen Research is a market research and consulting company that provides syndicated research reports, customized research reports, and consulting services. Our solutions purely focus on your purpose to locate, target, and analyze consumer behavior shifts across demographics, across industries, and help clients make smarter business decisions. We offer market intelligence studies ensuring relevant and fact-based research across multiple industries, including Healthcare, Touch Points, Chemicals, Types, and Energy. We consistently update our research offerings to ensure our clients are aware of the latest trends existent in the market. Emergen Research has a strong base of experienced analysts from varied areas of expertise. Our industry experience and ability to develop a concrete solution to any research problems provides our clients with the ability to secure an edge over their respective competitors. Contact Us: Eric Lee Corporate Sales Specialist Emergen Research | Web: www.emergenresearch.com Direct Line: +1 (604) 757-9756 E-mail: sales@emergenresearch.com Facebook | LinkedIn | Twitter | Blogs Read Full Press Release@ https://www.emergenresearch.com/press-release/global-air-quality-monitoring-system-market
(Bloomberg) -- Mexico’s bill to increase government controls over the fuel market won congress approval in the latest blow to the country’s historic energy opening to private companies.With 65 lawmakers in favor, 47 opposed, and 6 abstaining, the senate on Thursday passed the proposal from President Andres Manuel Lopez Obrador to expand control over gasoline and diesel distribution, imports and marketing. It also allows the government to suspend permits from fuel-market operators based on national or energy security reasons, and it lets state-owned oil company Petroleos Mexicanos take over their facilities.The bill was approved in general terms with some articles reserved for further debate in congress, which the government’s party controls together with allies. It will go to Lopez Obrador, known as AMLO, to be signed into law once approved in a final vote.Since reaching power in late 2018, Lopez Obrador has fought against 2013-2014 energy reforms that ended almost eight decades of state monopoly and lured investments from Royal Dutch Shell Plc, Chevron Corp. and a number of other companies. The changes in fuel market rules are the latest move by the nationalist president to roll back those reforms, and restore Pemex and power utility Comision Federal de Electricidad to their former glory.Just on Wednesday, the lower house passed another bill that removes an article from the nation’s oil law compelling regulator CRE to issue so-called asymmetric regulations to privilege private companies in sales of fuels from Pemex refineries. The proposal is now heading to the senate.More: Mexico’s AMLO Pounces on Texas Freeze to Push Nationalist AgendaCostly SupportMexico’s costly support of loss-making state firms drains public resources for essential spending, while private sector underinvestment threatens to slow the country’s growth, the U.S. Treasury Department said in its semiannual report to Congress.The fuel-market legislation is expected to be held up in courts, like a similar bill to prioritize CFE in the power market that was passed last month. On Thursday, Mexico’s antitrust regulator said it filed a constitutional challenge before the country’s supreme court over the law, arguing that parts of it violate constitutional protections for competitive electricity markets by privileging the state-run power utility.Onexpo, the national fuel retailers’ association, said in a statement last week that fuel permit holders are studying legal options to defend their interests.Once a monopoly, Pemex’s share of the gasoline and diesel market has fallen since the reform of the sector, but private players have less than a 30% market share. Pemex expects its gasoline sales won’t fully recover to pre-pandemic levels this year as lockdown measures hurt demand and competitors win market share.The company is also struggling with long-term oil production declines and the highest debt level of any major oil producer.For more articles like this, please visit us at bloomberg.comSubscribe now to stay ahead with the most trusted business news source.©2021 Bloomberg L.P.
Key players operating in the Antibody Services market are GE Healthcare, Thermo Fisher Scientific, Inc., Sartorius AG, Merck KGaA, Pall Corporation, Sigma-Aldrich Corporation, Eppendorf AG, Cellab GmbH, INTEGRA Biosciences AG, and FiberCell Systems Inc.Vancouver, British Columbia, April 22, 2021 (GLOBE NEWSWIRE) -- The global antibody services market size is expected to reach USD 3.30 Billion in 2028 and register a steady CAGR during the forecast period, according to latest analysis by Emergen Research. Rising approval rate of therapeutic antibodies by government bodies, rising investment in biotechnology and pharmaceutical research, and surge in demand for protein therapeutics are some major factors boosting market revenue growth. Antibodies are immunoglobulin glycoproteins generated by plasma cells in reaction to foreign antigenic molecules. The basic function of antibodies is to keep hold of specifically to these foreign antigens to impair them from destruction by the immune system, thereby safeguarding the host from any kind of infection. Antibody service includes various types and stages of antibody production, beginning from peptide designing, synthesis, and pairing of carrier protein with animal immunization, titer analysis, and antibody purification. Antibody development process begins with injection of antigen into the body of a laboratory animal, enabling their immune system to create a higher number of antibodies. Claim Your FREE Sample Copy with Table of content@ https://www.emergenresearch.com/request-sample/632 Most commonly utilized antibodies are IgG and IgM class antibodies. Antibodies are usually used in diagnostics applications such as pregnancy tests and detection of bacteria and different kinds of viruses in blood. Some Key Findings From the Report: Key players operating in the market are GE Healthcare, Thermo Fisher Scientific, Inc., Sartorius AG, Merck KGaA, Pall Corporation, Sigma-Aldrich Corporation, Eppendorf AG, Cellab GmbH, INTEGRA Biosciences AG, and FiberCell Systems Inc. In January 2019, GenScript launched a new purification system, AmMag SA. This system simplified the process of protein and antibody purification and reduces processing time.Monoclonal segment is expected to register a faster revenue CAGR as compared to other application segments throughout the forecast period. Commercialization of a large number of antibody-based products and growing investment in monoclonal antibody research are some key factors driving revenue growth of this segment.North America accounted for a 30.1% revenue share in the global market in 2020. Robust presence of biotech and pharmaceutical companies, rapid development in healthcare and research infrastructure, and constant focus on drug discovery services are major factors driving revenue growth of the market in this region. Check Our Prices@ https://www.emergenresearch.com/select-license/632 For the purpose of this report, Emergen Research has segmented the global antibody services market based on service, type, end-use, and region: Service Outlook (Revenue, USD Billion; 2018–2028) Antibody DevelopmentAntibody Production & PurificationAntibody Fragmentation & Labeling Type Outlook (Revenue, USD Billion; 2018–2028) MonoclonalPolyclonal End-Use Outlook (Revenue, USD Billion; 2018–2028) BioScience CompaniesBioScience Research InstitutionsHospitalsOther Click to access the Report Study, Read key highlights of the Report and Look at Projected Trends: https://www.emergenresearch.com/industry-report/antibody-services-market Regional Outlook (Revenue: USD Billion; 2018–2028) North America U.S.CanadaMexico Europe GermanyFranceU.K.BENELUXItalySpainSwitzerlandRussiaRest of Europe Asia Pacific China JapanSouth KoreaIndiaRest of APAC Latin America BrazilRest of LATAM Middle East & Africa Saudi ArabiaUAESouth AfricaTurkeyRest of MEA Take a Look at our Related Reports: Topical Drug Delivery Market By Product Form (Semi-Solid, Solid Formulations, Transdermal Products, and Liquid Formulations), By Route (Dermal, Ophthalmic, Nasal, Others), By End-Use (Hospitals, Home Healthcare, Clinics, Diagnostic Centers, Burn Center), and By Regions Medical Smart Textiles Market By Technology (Textile Sensors, Wearable Technology), By Application (Surgery, Bio-Monitoring, Therapy, and Wellness), By End-use (Hospitals and Clinics, Medical Academic and Research Center), and By Region Operating Room Management Solutions Market By Solution Type (Data management and communication solutions, Operating room supply management solutions, Anesthesia information management solutions, Operating room scheduling solutions, Performance management solutions), By Mode of Deployment (Ob-premises, Cloud-based), By End-Use (Hospitals, Ambulatory surgical centers), and By Region About Emergen Research Emergen Research is a market research and consulting company that provides syndicated research reports, customized research reports, and consulting services. Our solutions purely focus on your purpose to locate, target, and analyze consumer behavior shifts across demographics, across industries, and help clients make smarter business decisions. We offer market intelligence studies ensuring relevant and fact-based research across multiple industries, including Healthcare, Touch Points, Chemicals, Types, and Energy. We consistently update our research offerings to ensure our clients are aware of the latest trends existent in the market. Emergen Research has a strong base of experienced analysts from varied areas of expertise. Our industry experience and ability to develop a concrete solution to any research problems provides our clients with the ability to secure an edge over their respective competitors. Contact Us: Eric Lee Corporate Sales Specialist Emergen Research | Web: www.emergenresearch.com Direct Line: +1 (604) 757-9756 E-mail: sales@emergenresearch.com Facebook | LinkedIn | Twitter | Blogs Read Full Press Release@ https://www.emergenresearch.com/press-release/global-antibody-services-market
London's High Court has paved the way for a case that could force its judges to take a view on who invented bitcoin, the world's biggest cryptocurrency which last week soared to all-time highs.The court has allowed Craig Wright, an Australian computer scientist who alleges he created bitcoin, to serve a copyright infringement lawsuit against the operator and publisher of the bitcoin.
Key players operating in the Blood-Brain Barrier market are Allon Therapeutics, Inc., Angiochem Inc., Armagen Technologies, Inc., Bristol-Myers Squibb, BiOasis Technologies, Inc., Sanofi Genzyme, CarThera, Cephalon Inc., Nanomerics, and F. Hoffman La-Roche AG.Vancouver, British Columbia, April 22, 2021 (GLOBE NEWSWIRE) -- The global blood-brain barrier market size is expected to reach USD 7.40 Billion in 2028 and register a steady CAGR during the forecast period, according to latest analysis by Emergen Research. Growing awareness regarding neurological disorders, increasing healthcare expenditure, advancements in medical technology, and increasing investment in blood-brain barrier technology development are some key factors driving market revenue growth. Blood-brain barrier plays an essential role in protecting the brain from harmful compounds and blood-borne disorders. It blocks the flow of compounds from circulatory systems to the Cerebrospinal Fluid (CSF) or brain by exchanging particular components controlled by BBB or blood CSF barrier. This makes treatment for brain disorders complex due to the specialized uptake of drugs by the blood-brain barrier. Claim Your FREE Sample Copy with Table of content@ https://www.emergenresearch.com/request-sample/633 Recent advancements in drug delivery techniques enable drugs to be transferred directly to cerebrospinal fluids. There are several approaches to create a passage for delivering drugs to the brain such as passive diffusion and bispecific antibody RMT approach, Trojan horse approach, and increasing permeability. In Trojan horse approach, the drug is merged to a molecule that is able to cross the blood-brain barrier through a transporter protein. Some Key Findings From the Report: Key players operating in the market are Allon Therapeutics, Inc., Angiochem Inc., Armagen Technologies, Inc., Bristol-Myers Squibb, BiOasis Technologies, Inc., Sanofi Genzyme, CarThera, Cephalon Inc., Nanomerics, and F. Hoffman La-Roche AG.In Feb 2021, Denali Therapeutics completed a phase 1 trial of a broad portfolio of product candidates that are engineered to cross the blood-brain barrier for neurodegenerative diseases.Increasing permeability segment is expected to register a faster revenue CAGR as compared to other technology segments throughout the forecast period. This can be attributed to rising focus on research activities for treatment of many neurological and central nervous system disorders.North America accounted for a 32.3% revenue share in the global market in 2020. Major prevalence of Hunter’s Syndrome and Alzheimer's Disease, and growing adoption of advanced techniques for treating acute neurological disorders are major factors driving revenue growth of the market in this region. Check Our Prices@ https://www.emergenresearch.com/select-license/633 For the purpose of this report, Emergen Research has segmented the global blood-brain barrier (BBB) market based on application, technology, end-use, and by region: Application Outlook (Revenue, USD Billion; 2018–2028) Alzheimer’s DiseaseEpilepsyParkinson’s DiseaseMultiple SclerosisHunter’s SyndromeBrain Cancer Technology Outlook (Revenue, USD Billion; 2018–2028) Bispecific Antibody RMT ApproachTrojan Horse ApproachIncreasing PermeabilityPassive DiffusionOthers End-Use Outlook (Revenue, USD Billion; 2018–2028) HospitalsSurgical centersResearch Institutes Others Click to access the Report Study, Read key highlights of the Report and Look at Projected Trends: https://www.emergenresearch.com/industry-report/blood-brain-barrier-market Regional Outlook (Revenue: USD Billion; 2018–2028) North America U.S.CanadaMexico Europe GermanyFranceU.K.BENELUXItalySpainSwitzerlandRussiaRest of Europe Asia Pacific China JapanSouth KoreaIndiaRest of APAC Latin America BrazilRest of LATAM Middle East & Africa Saudi ArabiaUAESouth AfricaTurkeyRest of MEA Take a Look at our Related Reports: Topical Drug Delivery Market By Product Form (Semi-Solid, Solid Formulations, Transdermal Products, and Liquid Formulations), By Route (Dermal, Ophthalmic, Nasal, Others), By End-Use (Hospitals, Home Healthcare, Clinics, Diagnostic Centers, Burn Center), and By Regions Medical Smart Textiles Market By Technology (Textile Sensors, Wearable Technology), By Application (Surgery, Bio-Monitoring, Therapy, and Wellness), By End-use (Hospitals and Clinics, Medical Academic and Research Center), and By Region Operating Room Management Solutions Market By Solution Type (Data management and communication solutions, Operating room supply management solutions, Anesthesia information management solutions, Operating room scheduling solutions, Performance management solutions), By Mode of Deployment (Ob-premises, Cloud-based), By End-Use (Hospitals, Ambulatory surgical centers), and By Region About Emergen Research Emergen Research is a market research and consulting company that provides syndicated research reports, customized research reports, and consulting services. Our solutions purely focus on your purpose to locate, target, and analyze consumer behavior shifts across demographics, across industries, and help clients make smarter business decisions. We offer market intelligence studies ensuring relevant and fact-based research across multiple industries, including Healthcare, Touch Points, Chemicals, Types, and Energy. We consistently update our research offerings to ensure our clients are aware of the latest trends existent in the market. Emergen Research has a strong base of experienced analysts from varied areas of expertise. Our industry experience and ability to develop a concrete solution to any research problems provides our clients with the ability to secure an edge over their respective competitors. Contact Us: Eric Lee Corporate Sales Specialist Emergen Research | Web: www.emergenresearch.com Direct Line: +1 (604) 757-9756 E-mail: sales@emergenresearch.com Facebook | LinkedIn | Twitter | Blogs Read Full Press Release@ https://www.emergenresearch.com/press-release/global-blood-brain-barrier-market
Willie Earl Carr, et al. v. Andrew M. Saul, Commissioner of Social Security; John J. Davis, et al. v. SaulWashington, D.C., April 22, 2021 (GLOBE NEWSWIRE) -- Today, the U.S. Supreme Court unanimously held that the lower courts erred in imposing an issue-exhaustion requirement on Social Security disability claimants. In Carr v. Saul, claimants challenged a judge-made version of the administrative exhaustion rule, a requirement that litigants at an administrative hearing must raise any legal arguments in support of their claim at each step of the administrative process or forfeit those arguments on appeal. The New Civil Liberties Alliance and the Cato Institute filed a joint amicus brief arguing that imposing issue exhaustion requirements is inappropriate when the issue does not depend on an agency’s discretion, expertise, or fact-finding. In the Social Security system, claimants dissatisfied with initial determinations on their applications for disability benefits can request further review from a Social Security administrative law judge (ALJ), and then from the Appeals Council. After that, claimants proceed to the district court. In Sims v. Apfel, the Supreme Court held that Social Security claimants need not raise particular issues before the Appeals Council to preserve those issues for judicial review. But Sims left open whether an issue-exhaustion rule might apply to proceedings before ALJs. In Justice Sotomayor’s opinion for the Court, the judgments of the Eighth and Tenth Circuit Courts of Appeal were reversed under the reasoning that petitioners could not have developed their Appointments Clause challenges in the Social Security Administration (SSA) ALJ proceedings given that: (1) the proceedings were non-adversarial; and (2)(a) the structural constitutional claims at issue were ill-suited for agency adjudication because they fell outside the agency’s expertise; and (b) raising them would have been futile since the SSA ALJ could not have granted the claimants their requested relief. Carr is one of several cases that arose in the aftermath of the Supreme Court’s 2018 decision in Lucia v. SEC, which held that the ALJs working for the Securities & Exchange Commission (SEC) were “Officers of the United States” who had not been appointed in a manner required by the Appointments Clause of the Constitution. NCLA’s amicus briefs in Lucia and now Carr aim to ensure that agency adjudicators must afford people their constitutionally guaranteed rights. The Court’s decision in Carr makes certain that Article III courts will serve as a constitutional backstop and step in to enforce the Constitution when agencies can’t or won’t. NCLA released the following statement: “Just as NCLA argued in its amicus brief, the Court recognized today that it makes little sense to penalize litigants for failing to articulate constitutional challenges before ALJs who lack the expertise and authority to resolve such claims. This decision helps ensure that Article III judges will fulfill their constitutional duty to resolve structural challenges to agency adjudications when the agency can’t or won’t do so.”— Jared McClain, Litigation Counsel, NCLA For more information visit the case page here. ABOUT NCLA NCLA is a nonpartisan, nonprofit civil rights group founded by prominent legal scholar Philip Hamburger to protect constitutional freedoms from violations by the Administrative State. NCLA’s public-interest litigation and other pro bono advocacy strive to tame the unlawful power of state and federal agencies and to foster a new civil liberties movement that will help restore Americans’ fundamental rights. ### CONTACT: Judy Pino New Civil Liberties Alliance 202-869-5218 judy.pino@ncla.legal
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