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Question: What is the main focus of the research paper?

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Context 1: Paper Info

Title: Nuclear Liquid-Gas Transition in the Strong Coupling Regime of Lattice QCD
Publish Date: 28 Mar 2023
Author List: J Kim (from Institute for Advanced Simulation (IAS-4), Forschungszentrum Jülich), P Pattanaik (from Fakultät für Physik, Bielefeld University), W Unger (from Fakultät für Physik, Bielefeld University)

Figure

FIG  1 Typical 2-dimension configuration at β = 1 0, at non-zero quark mass, temperature, chemical potential The black dots are monomers, the blue lines are dimers, the red arrows are baryon loop segments (or triplets g b + f b = ±3 if adjacent to a non-trivial plaquette), and the green squares are plaquette occupations ±1 The actual configurations are 3+1-dimensional 
FIG 2 Chiral susceptibility on a 2 4 volume for various quark masses, as a function of the bare anisotropy γ (with aT = γ 2 /2), analytic results from enumeration compared to numerical data from simulations via the worm algorithm 
FIG 3 Various observables in the µB-T plane on a 2 4 volume at amq = 0 1 The back-bending of the first order transition at temperatures below aT = 0 5 in all observables is an artifact of the small volume, and vanishes in the thermodynamic limit The temperature aT = 1/2 corresponds to the isotropic lattice here 
FIG  4  The chiral condensate (left) and the baryon density (right) for quark mass m = 1 5 as a function of the chemical potential and for various temperatures 
FIG  7  ∆f at amq = 0 2 as a function of chemical potential and β the on a 6 3 × 4 lattice
FIG  8  Baryon mass from ∆E as a function of the quark mass amq, and contributions from different dual variables: monomers, dimers and baryon segments 
FIG  9  Baryon density for volume 4 3 × 8 in the full µB − mq plane, illustrating the strong quark mass dependence of the onset to nuclear matter 
FIG  10 Baryonic observables on various volumes in the first order region amq = 1 5 Vertical bands indicate the mean and error of the nuclear transition 
FIG  12  Left: Extrapolation of the pseudo-critical values of µB for the various volumes into the thermodynamic limit Right: Critical baryon chemical potential for different quark masses The first order transition region is shown in blue, the crossover region is shown in red and the range for critical end point is marked in black 
FIG  17  Nuclear interaction scaled with baryon mass As the quark mass increases, it tends to zero 
FIG  18  Critical baryon chemical potential and baryon mass from different approaches 
Parameters for the Monte Carlo runs to determine the nuclear transition at strong coupling, with statistics after thermalization 

abstract

The nuclear liquid-gas transition from a gas of hadrons to a nuclear phase cannot be determined numerically from conventional lattice QCD due to the severe sign problem at large values of the baryon chemical potential  In the strong coupling regime of lattice QCD with staggered quarks, the dual formulation is suitable to address the nuclear liquid gas transition 
We determine this first order transition at low temperatures and as a function of the quark mass and the inverse gauge coupling β  We also determine the baryon mass and discuss the nuclear interactions as a function of the quark mass, and compare to mean field results  It is known from experiments that at low temperatures, there is a phase transition between dilute hadron gas and dense nuclear matter as the baryon chemical potential increases 
This transition is of first order and terminates at about T c = 16 MeV in a critical end point  The value of the chemical potential µ 1st B at zero temperature is given roughly by the baryon mass m B , where the difference of µ 1st B −m B is due to nuclear interactions  For a review on nuclear interactions see  
As the nuclear force between baryons to form nuclear matter is due to the residual strong interactions between quarks and gluons, it should be accurately described by QCD  We choose to study the nuclear transition and nuclear interaction via lattice QCD , with its Lagrangian being a function of the quark mass and the inverse gauge coupling 
In order to understand the nature of the transition, it is helpful to study its dependence on these parameters  However, at finite baryon density, lattice QCD has the infamous sign problem which does not allow us to perform direct Monte Carlo simulations on the lattice  Various methods have been proposed to overcome the numerical sign problem, but they are either limited to µ B /T 3 or can not yet address full QCD in 3+1 dimensions in the whole µ B − T plane , in particular the nuclear transition is out of reach 
An alternative method is to study lattice QCD via the strong coupling expansion  There are two established effective theories for lattice QCD based on this: (1) the 3-dim  effective theory for Wilson fermions in terms of Polyakov loops, arising from a joint strong coupling and hopping parameter expansion , the dual representation for staggered fermions in 3+1 dimensions, with dual degrees of freedom describing mesons and baryons 
Both effective theories have their limitations: is limited to rather heavy quarks (but is valid for large values of β) whereas ( ) is limited to the strong coupling regime β 1 (but is valid for any quark mass)  We study lattice QCD in the dual formulation, both at infinite bare gauge coupling, β = 0, and at leading order of the strong coupling expansion in the regime β < 1, which is far from the continuum limit 
But since strong coupling lattice QCD shares important features with QCD, such as confinement, and chiral symmetry breaking and its restoration at the chiral transition temperature, and a nuclear liquid gas transition, we may get insights into the mechanisms, in particular as the dual variables give more information in terms of its world lines, as compared to the usual fermion determinant that depends on the gauge variables 
To establish a region of overlap of both effective theories, we have chosen to perform the Monte Carlo simulations in the dual formulation extending to rather large quark masses  This paper is organized as follows: in the first part we explain the dual formulation in the strong coupling regime, in the second part we provide analytic results based on exact enumeration and mean field theory, in the third part we explain the setup of our Monte Carlo simulations and present result on the m q -and β-dependence of the nuclear transition 
Since the strong coupling regime does not have a well defined lattice spacing, we also determine the baryon mass am B to set the parameters of the grand-canonical partition function, aT and aµ B , in units of am B   We conclude by discussing the resulting nuclear interactions, and compare our findings with other results 

Staggered action of strong coupling QCD and its dual representation

In the strong coupling regime, the gauge integration is performed first, followed by the Grassmann integration to obtain a dual formulation  This was pioneered for the strong coupling limit in and has been extended by one of us to include gauge corrections   The sign problem is mild in the strong coupling limit and still under control for β < 1, where we can apply sign reweighting 
The dual degrees of freedom are color-singlet mesons and baryons, which are point-like in the strong coupling limit, and become extended about a lattice spacing by incorporating leading order gauge corrections  The partition function of lattice QCD is given by where DU is the Haar measure, U ∈ SU(3) are the gauge fields on the lattice links (x, μ) and { χx , χ x } are the unrooted staggered fermions at the lattice sites x 
The gauge action S G [U] is given by the Wilson plaquette action and the staggered fermion action S F [ χ, χ, U] is: where the gauge action depends on the inverse gauge coupling β = 2Nc g 2 and the fermion action depends on the quark chemical potential aµ q which favors quarks in the positive temporal direction, and the bare quark mass am q  
First we consider the strong coupling limit where the inverse gauge coupling β=0 and hence the gauge action S G [U] drops out from the partition function in this limit  The gauge integration is over terms depending only on the individual links (x, μ) so the partition function factorizes into a product of one-link integrals and we can write it as:
with z(x, μ) the one-link gauge integral that can be eval-uated from invariant integration, as discussed in , where we write the one-link integral in terms of new hadronic variables: Only terms of the form (M (x)M (y)) k x, μ (with k x,μ called dimers which count the number of meson hoppings) and B(y)B(x) and B(x)B(y) (called baryon links) are present in the solution of the one-link integral 
The sites x and y = x + μ are adjacent lattice sites  It remains to perform the Grassmann integral of the fermion fields χ, χ  This requires to expand the exponential containing the quark mass in Eq  (4) (left), which results in the terms (2am q M (x)) nx (with n x called monomers)  To obtain non-vanishing results, at every site, the 2N c Grassman variables χ x,i and χx,i have to appear exactly once, resulting in the Grassmann constraint (GC):
where n x is the number of monomers, k x,μ is the number of dimers and the baryons form self-avoiding loops x,μ , which due to the constraint cannot coexist with monomers or dimers  With this, we obtain an exact rewriting of the partition function Eq  ( ) for N c = 3, in terms of integer-valued dual degrees of freedom {n, k, }:
where the sum over valid configurations has to respect the constraint (GC)  The first term in the partition function is the contribution from dimers and the second term is the contribution from monomers  The weight factor w( ) for each baryon loop depends on the baryon chemical potential µ B = 3µ q and induces a sign factor σ( ) which depends on the geometry of :
Here, ω is the winding number of the loop   The total sign factor σ( ) ∈ {±1} is explicitly calculated for every configuration  We apply sign reweighting as the dual formulation has a mild sign problem: baryons are non-relativistic and usually have loop geometries that have a positive signs  The dual partition function of the strong coupling limit is simulated with the worm algorithm (see Section III A) and the sign problem is essentially solved in this limit 

Extension to finite β

The leading order gauge corrections O(β) to the strong coupling limit are obtained by expanding the Wilson gauge action Eq  ( ) before integrating out the gauge links  A formal expression is obtained by changing the order of integration (first gauge links, then Grassmann-valued fermions) within the QCD partition function:
With this the O (β) partition function is The challenge in computing Z (1) is to address the SU(N c ) integrals that receive contributions from the elementary plaquette U P   Link integration no longer factorizes, however the tr[U P ] can be decomposed before integration: Integrals of the type J ij with two open color indices -as compared to link integration at strong coupling -have been derived from generating functions
for either J = 0 or for G = U(N c )   The SU(3) result was discussed in , in terms of the dual variables, neglecting rotation and reflection symmetries, there are 19 distinct diagrams to be considered  The resulting partition function, valid to O(β), is with q P ∈ {0, ±1}, and the site weights w x → ŵx , bond weights w b → ŵb and baryon loop weights w → ŵ receive modifications compared to the strong coupling limit Eq  ( ) for sites and bonds adjacent to an excited plaquette q P = 1 
The weights are given in , and are rederived for any gauge group in   The configurations {n, k, , q p } must satisfy at each site x the constraint inherited from Grassmann integration: which is the modified version of Eq  ( ) with q x = 1 if located at the corner of an excited plaquette q p = 0, otherwise q x = 0 
A more general expression that we obtained via group theory and is valid to higher orders of the strong coupling expansion is discussed in terms of tensor networks   A typical 2-dimensional configuration that arises at β = 1 in the Monte Carlo simulations is given in Fig    Note that if a baryon loop enters a non-trivial plaquette, one quark is separated from the two other quarks, resulting in the baryon being extended object, rather being point-like in the strong coupling limit 
The O(β) partition function has been used in the chiral limit to study the full µ B − T plane via reweighting from the strong coupling ensemble  Whereas the second order chiral transition for small values of the aµ B decreased up to the tri-critical point, the first order nuclear transition was invariant: aµ 1st B 1 78(1) at zero temperature has no β-dependence 
For the ratio T (µ B = 0)/µ 1st B (T 0) we found the values 0 787 for β = 0 and 0 529 β = 1, which should be compared to T c / 0 165 for full QCD   However, since reweighting cannot be fully trusted across a first order boundary, direct simulations at nonzero β are necessary  The Monte Carlo technique to update plaquette variables is discussed in Section III A 
In this section, we provide analytic results from exact enumeration for small volumes, and mean field results based on the 1/d expansion, valid in the thermodynamic limit  The main purpose is to compare our Monte Carlo results to these analytic predictions 

Exact enumeration

To establish that our Monte Carlo simulations indeed sample the partition functions Eq  ( ) and Eq  ( ), we have obtained analytic results on a 2 4 volume at strong coupling, and at finite beta in two dimensions on a 4 × 4 volume, comparing O (β) and O β 2 truncations  Our strategy to obtain an exact enumeration of the partition function Z is to enumerate plaquette configurations first, then fixing the fermion fluxes which together with the gauge fluxes that are induced by the plaquettes form a singlet, a triplet or anti-triplet, i e  on a given bond b, g b + f b ∈ {−3, 0, 3}, and last we perform the monomerdimer enumeration on the available sites not saturated by fermions yet by a depth-first algorithm  
At strong coupling, with no plaquettes, g b = 0 and f b are baryonic fluxes  All observables that can be written in terms of derivatives of log(z), such as the baryon density, the chiral condensate, the energy density, and also the average sign, are shown in Fig 

Expectations from mean field theory

Another analytical method to study strong coupling lattice QCD is the mean field approach, where the partition function is expanded in 1 d (d is the spatial dimension) and then a Hubbard-Stratonovich transformation performed   After this procedure, the free energy is a function of temperature T , the chiral condensate σ and chemical potential µ B :
here E[m] is one-dimensional quark excitation energy which is a function of the quark mass m = am q   For N c = 3 and d = 3 we determined the minimum of the free energy with respect to the chiral condensate  This gives us the equilibrium chiral condensate as a function of (T, m, µ B )  The chiral condensate and the baryon density as a function of the baryon chemical potential in lattice units aµ B and for various temperatures at quark mass m = 1 5 is shown in Fig    We have determined the critical temperature to be aT c = 0 23 , which is characterized by an infinite slope of the chiral condensate 
For lower temperatures, there is a clear discontinuity of the chiral con-densate, separating the low density phase from the high density phase  For temperatures above and in the vicinity of aT c the chiral condensate and baryon density has no discontinuity but rapidly changes, corresponding to a crossover transition 
With this method, the phase diagram is plotted for different quark masses in Fig    The second order phase transition in the chiral limit is plotted in solid blue line, the dotted lines show the first order phase transition for different quark masses and the solid red line indicates the critical end point for the different quark masses 
Mean field theory also gives an expression for the pion mass am π and the baryon mass am B : The mean field baryon mass for N c = 3, d = 3 is also plotted in red in Fig    Whereas the baryon mass is around N c in the chiral limit (am B 3 12 for N c = 3), it approximately doubles at m = 3 5 (am B 6 28) which corresponds to the pion mass am π = 4 45, i e  m π /m B = 0 708 
Hence, at around bare mass m = 3 5, the valence quark mass of the baryon corresponds roughly to 1/3 of the chiral limit value of the baryon mass  The first Monte Carlo simulations that could extend in the µ B − T plane was the MDP algorithm , but it required the introduction of the worm algorithm to make substantial progress 
First studies of the worm algorithm applied to the strong coupling limit QCD (with gauge group U(3)) are , and for gauge group SU   Monte Carlo simulations to extend the worm to incorporate leading order corrections were first proposed in   We will shortly review the setup of or Monte Carlo strategy for the nuclear transition, with an emphasis on the challenges to address large quark masses 

Strong Coupling

Without any further resummation, there is a mild sign problem in the dual formulation of lattice QCD in the strong coupling limit  When the average sign σ is not too small (close to zero), it implies that most of the configurations have a positive weight thus allowing us to perform sign reweighting strategies 
In Fig  , ∆f is plotted as a function of the baryon chemical potential and the quark masses  It is seen that ∆f is close to zero for most cases except near the critical chemical potential and for small quark masses, but never exceeds 5 × 10 −4   Hence sign reweighting can be performed in the full parameter space 
The result that the sign problem becomes even milder when increasing the mass is related to the fact that larger critical chemical potentials result in a larger fraction of static baryons (spatial baryon hoppings become rare)  FIG    ∆F at strong coupling as a function of chemical potential and quark mass on a 6 3 × 8 
The sign problem becomes milder as the quark mass increases 

Finite β

All runs at finite β have been obtained for N τ = 4, which corresponds to a moderately low temperature aT = 0 25 compared to the value of the chiral transition aT 1 54  Those simulations were too expensive to attempt N τ = 8 runs, in particular as a higher statistics was required  The spatial volumes are 4 3 , 6 3 and 8 3  
For β values are from 0 0 to 1 0 with step size 0 1, and for am q values from 0 00 to 1 00 with step size 0 01  The values of aµ were chosen close to the nuclear transition, the scanning range is shifted to large values as am q increases  At small quark masses the scanning range is from aµ = 0 4 to 1 0 and for the large quark masses, it is from 0 6 to 1 2 with step size 0 01 
The statistics used for are 15 × 10 4 measurements and between measurement, 40 × N 3 s worm updates 

Residual sign problem

Although it is possible to resum the sign problem at strong coupling with a resummation of baryon and pion world lines, this is not possible when including gauge corrections  In order to compare both sign problems, we kept the original dual formulation to monitor the severity of the sign problem  This is done via the relation
between the average sign σ and the difference of the free energy density ∆f between the full ensemble f and of the sign-quenched ensemble f ||  

Nuclear interactions

We have found that aµ 1st B is very different from the baryon mass  This must be due to strong attractive interactions of nucleons  In contrast to continuum physics, in the strong coupling limit there is no pion exchange due to the Grassmann constraint  Instead, nucleons are point like and hard core repulsive 
However, the pion bath, which is modified by the presence of static baryons, results in an attractive interaction  In , this has been analyzed in the chiral limit using the snake algorithm, and it has been found that the attractive force is of entropic origin  Here, we do not quantify the nuclear interaction via the nuclear potential, but via the difference between critical baryon chemical potential and baryon mass, in units baryon mass, as shown in Fig  , given the am B as measured in Section III C 
This compares better to the 3dim  effective theory  The nuclear interaction is maximal and more than 40% in the chiral limit, which is related to pions being massless: the modification of the pion bath is maximal  We clearly find that the nuclear interaction decreases drastically and almost linearly until it almost approaches zero at about am q = 2 0, corresponding to a pion mass am π = 3 36, see Section II B  The large error bars for larger quark masses, that are due to the subtraction of almost same magnitudes, makes it difficult to extract a non-zero nuclear interaction at the largest quark masses 
In this work, we have determined the baryon mass and the nuclear transition via Monte Carlo: the worm algorithm based on the dual formulation, at finite β equipped with additional updates  All those numerical results and various analytic expressions are summarized in Fig    We find that as the quark mass becomes large, spatial mesons hoppings (i e 
spatial dimers) become rare, which makes this 3+1-dimensional system closer to 1dim  QCD   Also, both the baryon mass and the baryon chemical potential obtained in our dual representation, i e  for staggered fermions, approaches the baryon mass of the 3-dim  effective theory which is based on Wilson fermions 
Another comparison that summarizes the validity of the mean field approach discussed in Section II B is shown in Fig    It is evident that mean field theory has strong deviations for small quark masses, but this discrepancy becomes smaller for larger quark masses  The extension of the study of the nuclear transition to finite inverse gauge coupling β is summarized in Fig  , which shows the β-dependence of aµ c B for various quark masses 
For all quark masses ranging from am q = 0 to am q = 1 0, there is only a very weak β-dependence, confirming the expectation from mean field theory   This works was restricted to isotropic lattices ξ = a/a t = 1, i e  we performed simulations at fixed temperature  Non-isotropic lattices are necessary to vary the temperature at fixed values of β 
This requires to include two bare anisotropies, γ for the fermionic action and γ G for the gauge action  Finite β has only been studied by us in the chiral limit   Clearly, it is interesting to study the location of the nuclear critical point also including higher order gauge corrections and at finite quark mass 
Simulations including O(β 2 ) are under preparation 
Context 2: South Dakota v  Wayfair, Inc  - Harvard Law Review
Fourth Circuit Invalidates Maryland Statute Regulating Price Gouging in the Sale of Generic Drugs 
South Dakota Supreme Court Holds Unconstitutional State Law Requiring Internet Retailers Without In-State Physical Presence to Remit Sales Tax 
Judicial junk, the Court has long thought, is easier to scrap when the erroneous precedent cannot be fixed by Congress, as in constitutional cases 1× 1  See Burnet v  Coronado Oil & Gas Co , 285 U S  393, 405–10 (1932) (Brandeis, J , dissenting); Lee Epstein, William M  Landes & Adam Liptak, The Decision to Depart (or Not) from Constitutional Precedent: An Empirical Study of the Roberts Court, 90 N Y U  L  Rev  1115, 1116 (2015) (“[Justice Brandeis’s] dissenting opinion       now has the status of black letter law ”)  On the flip side, whenever a bad precedent can be corrected by Congress, stare decisis applies with “special force ”2× 2  See Patterson v  McLean Credit Union, 491 U S  164, 172–73 (1989)  The Court, following Justice Brandeis, usually articulates the rule as distinguishing between “constitutional” and “statutory” precedents  See, e g , id  But the distinction is occasionally said to be between “constitutional” and “nonconstitutional cases ” See, e g , Glidden Co  v  Zdanok, 370 U S  530, 543 (1962) (plurality opinion)  Nomenclature aside, the Court has — until now — adhered to Justice Brandeis’s key insight that the important factor is whether or not the mistake may be legislatively corrected  Last Term, in South Dakota v  Wayfair, Inc ,3× 3  138 S  Ct  2080 (2018)  the Court tinkered with this thinking in overruling an outdated dormant commerce clause precedent  Dormant commerce clause decisions technically produce constitutional holdings, but Congress may override them at will 4× 4  See Prudential Ins  Co  v  Benjamin, 328 U S  408, 421–27 (1946)  Under the usual logic of stare decisis, it should take special force to dislodge such precedents  But Wayfair applied the weakened stare decisis of constitutional cases, asserting that the Court must “address a false constitutional premise         whether or not Congress can or will act ”5× 5  Wayfair, 138 S  Ct  at 2096–97 
Emerging from Wayfair is an odd and ominous development in stare decisis doctrine  Odd, because it turns on a formal classification instead of on Congress’s practical ability to fix the problem  Ominous, because the Court’s logic leads far past the dormant commerce clause  Wayfair grants only feeble stare decisis to precedents that set a “constitutional default rule,”6× 6  Id  at 2096 (“While       Congress has the authority to change the physical presence rule, Congress cannot change the constitutional default rule ”)  meaning constitutional decisions that allow for legislative adjustment or override  This new stare decisis analysis makes other precedents setting constitutional default rules more vulnerable — including, perhaps, mainstays of criminal procedure like Miranda v  Arizona7× 7  384 U S  436 (1966)  and Mapp v  Ohio 8× 8  367 U S  643 (1961) 
Since its 1967 decision in National Bellas Hess, Inc  v  Department of Revenue,9× 9  386 U S  753 (1967)  the Court has held that, under the “dormant” or “negative” implication of the Commerce Clause,10× 10  The dormant or negative commerce clause is a judicial derivation from the Commerce Clause “prohibiting States from discriminating against or imposing excessive burdens on interstate commerce without congressional approval,” which “strikes at one of the chief evils that led to the adoption of the Constitution, namely, state tariffs and other laws that burdened interstate commerce ” Comptroller of the Treasury of Md  v  Wynne, 135 S  Ct  1787, 1794 (2015)  states may not compel remote sellers with no physical presence in the state to collect and remit sales taxes 11× 11  See Bellas Hess, 386 U S  at 759–60  In Quill Corp  v  North Dakota,12× 12  504 U S  298 (1992)  the Court refused to overrule the “bright-line, physical-presence requirement” of Bellas Hess, leaning heavily on stare decisis 13× 13  Id  at 317–18  Three Justices joined a concurrence explaining that their decision rested solely “on the basis of stare decisis ” Id  at 320 (Scalia, J , concurring in part and concurring in the judgment)  So the physical presence test remained the law of the land while the internet conquered the earth  Justice Kennedy had joined the Quill majority and Justice Scalia’s concurring opinion emphasizing stare decisis, but by 2015 he had second thoughts  Writing separately in Direct Marketing Ass’n v  Brohl,14× 14  135 S  Ct  1124 (2015)  Justice Kennedy acknowledged that “[t]he Internet has caused far-reaching systemic and structural changes in the economy” and therefore “Quill now harms States to a degree far greater than could have been anticipated earlier ”15× 15  Id  at 1135 (Kennedy, J , concurring)  He concluded with the wish that “[t]he legal system should find an appropriate case for this Court to reexamine Quill and Bellas Hess ”16× 16  Id 
Seldom has a concurring opinion signed by a lone Justice prompted a state to officially declare an emergency  Yet in 2016, in response to Justice Kennedy’s overture, the South Dakota legislature passed a law, S B  106, “to provide for the collection of sales taxes from certain remote sellers       and to declare an emergency ”17× 17  2016 S D  Sess  Laws ch  70 pmbl  217 (codified at S D  Codified Laws § 10-64 (2017))  It required every remote seller to collect and remit sales tax if the seller’s business in South Dakota comprised either a “gross revenue” greater than $100,000 or at least 200 “separate transactions” within one calendar year 18× 18  Id  § 1  Significantly, the law did not apply retroactively 19× 19  Id  § 5  The “emergency” declaration was necessary to give the law immediate effect, for the purpose of “permitting the most expeditious possible review of the constitutionality of this law” by the U S  Supreme Court 20× 20  Id  § 8(8)  As Justice Alito put it, the “South Dakota law [was] obviously a test case ”21× 21  Transcript of Oral Argument at 27, Wayfair, 138 S  Ct  2080 (No  17-494), https://www supremecourt gov/oral_arguments/argument_transcripts/2017/17-494_7lho pdf [https://perma cc/8HYH-VU8N] 
Expeditiously, a group of remote sellers challenged the law  After being sued by South Dakota for refusing to register for the newly required sales tax license, Wayfair, Inc , Overstock com, Inc , and Newegg, Inc  moved for summary judgment in South Dakota circuit court on the grounds that S B  106 was unconstitutional under Quill and Bellas Hess — a point South Dakota conceded, indicating that it was seeking review by the U S  Supreme Court to overturn Quill 22× 22  State v  Wayfair Inc , 2017 SD 56, ¶¶ 9–11, 901 N W 2d 754, 759–60  Accordingly, the South Dakota circuit court granted the motion for summary judgment and South Dakota appealed to the state’s highest court 23× 23  Id  ¶ 12, 901 N W 2d at 760  The South Dakota Supreme Court unanimously affirmed, recognizing that South Dakota’s “arguments on the merits” may be “persuasive” but “Quill remains the controlling precedent ”24× 24  Id  ¶ 18, 901 N W 2d at 761  See generally Recent Case, State v  Wayfair Inc , 2017 SD 56, 901 N W 2d 754 (S D  2017), 131 Harv  L  Rev  2089 (2018) 
The U S  Supreme Court vacated and remanded 25× 25  Wayfair, 138 S  Ct  at 2100  Writing for the Court one last time, Justice Kennedy26× 26  Justices Thomas, Ginsburg, Alito, and Gorsuch joined Justice Kennedy’s opinion  pilloried Quill’s physical presence rule as “arbitrary, formalistic,” “anachronistic,” and “unfair and unjust” to both states and brick-and-mortar retailers 27× 27  Wayfair, 138 S  Ct  at 2092, 2095  After all, the rationale of Quill was that remote sellers lacked a sufficiently “substantial nexus” with the state to justify imposing a duty of tax collection 28× 28  Quill Corp  v  North Dakota, 504 U S  298, 311 (1992) (quoting Complete Auto Transit, Inc  v  Brady, 430 U S  274, 279 (1977))  This was wrong even in the mail-order catalog days of 1967 and 1992, but “the Internet revolution has made [Quill’s] earlier error all the more egregious and harmful ”29× 29  Wayfair, 138 S  Ct  at 2097; see also id  at 2092  The rule deprived the states of billions of dollars, since they could not force remote sellers to collect the tax and consumers hardly ever paid it on their own 30× 30  Id  at 2088 (“[C]onsumer compliance rates are notoriously low ”)  Quill “serve[d] as a judicially created tax shelter” for remote retailers who do a great deal of business online 31× 31  Id  at 2094 
Satisfied that Bellas Hess and Quill were wrongly decided, the Court then jumped the hurdle of stare decisis  The Quill Court had feared upsetting reliance interests 32× 32  Quill, 504 U S  at 317 (“Bellas Hess       has engendered substantial reliance and has become part of the basic framework of a sizable industry ”)  Wayfair shrugged off this concern, noting that “stare decisis accommodates only ‘legitimate reliance interest[s]’”; by contrast, reliance on the physical presence rule was largely due to consumers evading their use-tax obligations 33× 33  Wayfair, 138 S  Ct  at 2098 (alteration in original) (quoting United States v  Ross, 456 U S  798, 824 (1982))  Quill had also appealed to Congress’s ultimate authority over interstate commerce as a reason to abide by a precedent, even if wrongly decided 34× 34  See Quill, 504 U S  at 318–19; id  at 320 (Scalia, J , concurring in part and concurring in the judgment) (“Congress       can change the rule of Bellas Hess by simply saying so ”)  But Wayfair denied that Congress’s ability to change the law was a proper consideration:
While it can be conceded that Congress has the authority to change the physical presence rule, Congress cannot change the constitutional default rule  It is inconsistent with the Court’s proper role to ask Congress to address a false constitutional premise of this Court’s own creation  Courts have acted as the front line of review in this limited sphere; and hence it is important that their principles be accurate and logical, whether or not Congress can or will act in response 35× 35  Wayfair, 138 S  Ct  at 2096–97 
Having dispensed with the physical presence rule, the Court remanded the case to the South Dakota courts to determine in the first instance “whether some other principle in the Court’s Commerce Clause doctrine might invalidate the Act ”36× 36  Id  at 2099  But the Court listed “several features [of South Dakota law] that appear[ed] designed to prevent discrimination against or undue burdens upon interstate commerce ” Id 
Justices Thomas and Gorsuch each filed concurring opinions  Justice Thomas wistfully likened himself to Justice White — who voted for Bellas Hess but against Quill a quarter-century later — and confessed that he “should have joined [Justice White’s dissenting] opinion ”37× 37  Id  at 2100 (Thomas, J , concurring)  Justice Thomas added that the “Court’s entire negative Commerce Clause jurisprudence” is wrong and should be abandoned 38× 38  Id  Justice Gorsuch also wrote separately to express skepticism of the Court’s dormant commerce clause jurisprudence, raising “questions for another day” of whether the doctrine “can be squared with the text of the Commerce Clause, justified by stare decisis, or defended as misbranded products of federalism or antidiscrimination imperatives flowing from Article IV’s Privileges and Immunities Clause ”39× 39  Id  at 2100–01 (Gorsuch, J , concurring) 
Chief Justice Roberts dissented 40× 40  Justices Breyer, Sotomayor, and Kagan joined the Chief Justice’s dissent  Surprisingly, the dissenting Justices “agree[d] that Bellas Hess was wrongly decided, for many of the reasons given by the Court ”41× 41  Wayfair, 138 S  Ct  at 2101 (Roberts, C J , dissenting)  The dispute between the majority and the dissent turned entirely on the principles and application of stare decisis  Chief Justice Roberts argued that whether or how to reverse Quill should be left to Congress, which “has the flexibility to address these questions in a wide variety of ways” and “can focus directly on current policy concerns rather than past legal mistakes ”42× 42  Id  at 2104  He also pointed to the “baffling” burdens of compliance with the idiosyncratic tax codes of “[o]ver 10,000 jurisdictions,” particularly for small businesses, and doubted that new “software” — the majority’s proposed solution to this mess43× 43  Id  at 2098 (majority opinion) (“Eventually, software that is available at a reasonable cost may make it easier for small businesses to cope with these problems ”)  — would soon solve the problem 44× 44  Id  at 2103–04 (Roberts, C J , dissenting)  In Bellas Hess, the Court reasoned that the dormant commerce clause protects interstate business from being “entangle[d]       in a virtual welter of complicated obligations to local jurisdictions ” Nat’l Bellas Hess, Inc  v  Dep’t of Revenue, 386 U S  753, 759–60 (1967)  The dissent replied that the Court “vastly underestimate[d] the skill of contemporary man and his machines ” Id  at 766 (Fortas, J , dissenting)  The dispute in Wayfair over whether software is up to the task effectively reprised the old debate from Bellas Hess, only this time couched as part of the stare decisis inquiry’s concern for reliance interests rather than as a matter of dormant commerce clause doctrine  While Wayfair acknowledged that “[c]omplex state tax systems could have the effect of discriminating against interstate commerce,” 138 S  Ct  at 2099, the Court remarked that “[t]he physical presence rule is a poor proxy” for an inquiry into any actual burdens imposed on interstate commerce, id  at 2093 
Chief Justice Roberts emphasized that a “heightened form of stare decisis”45× 45  Wayfair, 138 S  Ct  at 2102 (Roberts, C J , dissenting)  applies when “Congress       can, if it wishes, override this Court’s decisions with contrary legislation ”46× 46  Id  at 2101 (first citing Michigan v  Bay Mills Indian Cmty , 134 S  Ct  2024, 2036 (2014) (tribal sovereign immunity); then citing Kimble v  Marvel Entm’t, LLC, 135 S  Ct  2401, 2409 (2015) (statutory interpretation); and then citing Halliburton Co  v  Erica P  John Fund, Inc , 134 S  Ct  2398, 2411 (2014) (judicially created doctrine implementing a judicially created cause of action))  In Quill, the Chief Justice noted, the Court had taken to heart that “Congress may be better qualified” and “has the ultimate power to resolve” the question47× 47  Id  at 2102 (quoting Quill Corp  v  North Dakota, 504 U S  279, 318 (1992))  while Justice Scalia had “recogniz[ed] that stare decisis has ‘special force’ in the dormant Commerce Clause context due to Congress’s ‘final say over regulation of interstate commerce ’”48× 48  Id  (quoting Quill, 504 U S  at 320 (Scalia, J , concurring in part and concurring in the judgment))  Moreover, “[i]f stare decisis applied with special force in Quill, it should be an even greater impediment” afterward since Quill effectively “tossed [the ball] into Congress’s court ”49× 49  Id  (alteration in original) (quoting Kimble, 135 S  Ct  at 2409); cf  Bay Mills, 134 S  Ct  at 2039 n 12 (“When we inform Congress that it has primary responsibility over a sphere of law, and invite Congress to consider a specific issue within that sphere, we cannot deem irrelevant how Congress responds ”)  Because the Court invited Congress to act and then “suddenly chang[ed] the ground rules, the Court may have waylaid Congress’s consideration of the issue ”50× 50  Wayfair, 138 S  Ct  at 2102–03 (Roberts, C J , dissenting) 
In Wayfair, the Court applied the flimsier form of stare decisis to a precedent that could have been overruled by Congress  It did so in the context of a dormant commerce clause case, but Wayfair’s logic extends to all constitutional default rules — that is, constitutional decisions that Congress remains free to change  Not only does Wayfair deviate from the Court’s decades-old stare decisis analysis, it also imperils other precedents that set constitutional default rules 
The Court’s reasoning in Wayfair departs from its prior stare decisis analysis  In 1932, Justice Brandeis posited that stare decisis must bend “in cases involving the Federal Constitution, where correction through legislative action is practically impossible ”51× 51  Burnet v  Coronado Oil & Gas Co , 285 U



ground_truth: Nuclear liquid-gas transition in lattice QCD.

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What did Justice Kennedy argue about Quill in Direct Marketing Ass'n v. Brohl?

Read the following text and answer briefly.

Context 2: S  393, 406–07 (1932) (Brandeis, J , dissenting)  The Court has long since adopted his argument,52× 52  See, e g , Smith v  Allwright, 321 U S  649, 665 (1944)  as well as its corollary — that stare decisis commands “special force in the area of statutory interpretation” where “Congress remains free to alter what [the Court has] done ”53× 53  Patterson v  McLean Credit Union, 491 U S  164, 172–73 (1989)  For normative evaluations of heightened stare decisis for statutory precedents, see generally Einer Elhauge, Statutory Default Rules: How to Interpret Unclear Legislation 211–23 (2008); and William N  Eskridge, Jr , Overruling Statutory Precedents, 76 Geo  L J  1361, 1364–1409 (1988)  Justice Brandeis’s logic demands that dormant commerce clause cases, where Congress is free to act, be granted the weightier stare decisis 54× 54  Scholars have noted the curious fact that Justice Brandeis included many dormant commerce clause cases as examples of overruled constitutional precedents  See, e g , Earl M  Maltz, Commentary, Some Thoughts on the Death of Stare Decisis in Constitutional Law, 1980 Wis  L  Rev  467, 468–469, 469 n 11  One explanation for this is that Justice Brandeis sought the authority of Chief Justice Taney’s dictum that the Court’s “opinion upon the construction of the Constitution is always open to discussion” — which referred to the dormant commerce clause  See Burnet, 285 U S  at 408 n 3 (Brandeis, J , dissenting) (quoting The Passenger Cases, 48 U S  (7 How ) 283, 470 (1849) (Taney, C J , dissenting))  In Chief Justice Taney’s time, it was thought that Congress could not override the Court’s dormant commerce clause decisions, see Cooley v  Bd  of Wardens, 53 U S  (12 How ) 299, 321 (1852), so the context of Chief Justice Taney’s dictum does not conflict with Justice Brandeis’s theory of stare decisis  The Court applied this reasoning in Quill, as Chief Justice Roberts underscored 55× 55  Wayfair, 138 S  Ct  at 2102 (Roberts, C J , dissenting) 
Yet the Wayfair majority refused to consider Congress’s authority to legislate as a relevant factor for stare decisis 56× 56  Even Justice Kennedy’s earlier opinion in Direct Marketing contemplated judicially overruling Quill, conspicuously neglecting a possible legislative solution  See supra p  278  The Court even insisted that to do so “is inconsistent with the Court’s proper role,” since Quill embodied “a false constitutional premise of th[e] Court’s own creation ”57× 57  Wayfair, 138 S  Ct  at 2096 (emphasis added)  This refusal breaks from the practical Brandeisian wisdom that has guided the Court’s treatment of precedent for the better part of a century  The point is not that stare decisis should have ultimately propped up Bellas Hess yet again, as Wayfair’s dissenting Justices maintained  After all, a realistic approach that is alert to each branch’s institutional capacities might have led to the conclusion that Congress was actually ill-equipped to overrule Quill  In this vein, the Court could have sensibly pointed out that Congress is unlikely to stick its neck out with a tax hike (or a look-alike) from which only the states would benefit 58× 58  For two practical arguments to this effect, see Brian Galle, Essay, Kill Quill, Keep the Dormant Commerce Clause: History’s Lessons on Congressional Control of State Taxation, 70 Stan  L  Rev  Online 158, 160–62 (2018), https://review law stanford edu/wp-content/uploads/sites/3/2018/03/70-Stan -L -Rev -Online-158-Galle pdf [https://perma cc/22YP-P4V5]; Edward A  Zelinsky, The Political Process Argument for Overruling Quill, 82 Brook  L  Rev  1177, 1191–92 (2017)  Indeed, South Dakota advanced such practical arguments in its brief 59× 59  See Petitioner’s Brief at 54, Wayfair, 138 S  Ct  2080 (No  17-494) (“Congress has little incentive to act here because it would be (or appear to be) authorizing new or greater tax collections from its constituents, while receiving none of the revenue in return ”)  More generally, the Court might have discussed the limits of the states’ influence in the federal system as a reason not to wait for congressional intervention, a topic it has debated on other occasions 60× 60  See Richard H  Pildes, Institutional Formalism and Realism in Constitutional and Public Law, 2013 Sup  Ct  Rev  1, 30–32; see also Galle, supra note 58, at 159 (“Congress is not a trustworthy guardian of state fiscal power, making continuing judicial involvement a more appealing prospect ”)  Or it could have argued that new facts on the ground — namely, the blast of e-commerce that hit like a comet after Quill — overpowered stare decisis of any force, special or plain 61× 61  Two recent studies of stare decisis highlighted the physical presence rule as exemplifying a precedent that may reasonably be overruled due to changed facts  See Bryan A  Garner et al , The Law of Judicial Precedent 364–65 (2016); Randy J  Kozel, Settled Versus Right: A Theory of Precedent 112–13 (2017)  It should be noted that the authors of The Law of Judicial Precedent classify the physical presence rule as a constitutional precedent for stare decisis purposes, thus anticipating the Court’s misstep in Wayfair  Garner et al , supra, at 354–65  Because even statutory precedents may sometimes be overruled,62× 62  See Patterson v  McLean Credit Union, 491 U S  164, 173–74 (1989) (discussing justifications for overruling statutory precedents)  Contra Lawrence C  Marshall, “Let Congress Do It”: The Case for an Absolute Rule of Statutory Stare Decisis, 88 Mich  L  Rev  177 (1989)  the Court could have killed Quill without first planting its constitutional kiss of death 63× 63  Cf  Thomas R  Lee, Stare Decisis in Historical Perspective: From the Founding Era to the Rehnquist Court, 52 Vand  L  Rev  647, 704 (1999) (“Justice Brandeis’       memorable prose has since become a mandatory part of the burial rite for any constitutional precedent ”) 
The Court resisted such arguments  Instead, Wayfair reasoned that Congress’s total ability to correct an erroneous decision counts for nothing when the Court gets the Constitution wrong  That such a theory sprouts from a case like Wayfair, which repudiated a “formalistic distinction,”64× 64  Wayfair, 138 S  Ct  at 2092  is ironic  Wayfair’s stare decisis analysis resorts to the formalism of making constitutional a “magic” word65× 65  See Transcript of Oral Argument, supra note 21, at 12  rather than asking whether Congress can step in 
Moreover, the Court’s new thinking on stare decisis threatens other constitutional default rules  Wayfair now stands for the proposition that a “constitutional default rule” — a term the Court apparently lifted from South Dakota’s reply brief on the merits66× 66  Reply Brief at 22, Wayfair, 138 S  Ct  2080 (No  17-494) (“Congress is polarized, which makes it critical       to get the constitutional default rule right ”)  — gets only weakened stare decisis  To appreciate why this holding matters, it is worth exploring the concept and scope of constitutional default rules  Contract theory describes default rules as legal rules that the parties may “contract around ”67× 67  See, e g , Ian Ayres & Robert Gertner, Filling Gaps in Incomplete Contracts: An Economic Theory of Default Rules, 99 Yale L J  87, 87 (1989)  Although “constitutional default rule” could be read broadly to include a variety of actors and contracting mechanisms,68× 68  See John Ferejohn & Barry Friedman, Toward a Political Theory of Constitutional Default Rules, 33 Fla  St  U  L  Rev  825, 826 (2006) (“When we speak of default rules in constitutional law, we typically are talking about specifications of ways the government can act (or modify its behavior) to get around a constitutional prohibition ”)  the Court’s use of the term for purposes of stare decisis may be narrowly defined as judicial precedents of constitutional law that “are ultimately subject to congressional control ”69× 69  Gillian E  Metzger, Congress, Article IV, and Interstate Relations, 120 Harv  L  Rev  1468, 1525 (2007) (describing judicially enforceable “constitutional default rules imposing obligations on the states in the name of union [that] are ultimately subject to congressional control”)  The dormant commerce clause is a paradigmatic constitutional default rule because what the Court does today Congress may undo tomorrow  Justice Scalia declared this fact “[t]he clearest sign that the negative Commerce Clause is a judicial fraud,” for “[h]ow could congressional consent lift a constitutional prohibition?”70× 70  Comptroller of the Treasury of Md  v  Wynne, 135 S  Ct  1787, 1808 (2015) (Scalia, J , dissenting)  But that’s what a constitutional default rule is  The Court has allowed Congress to overturn its dormant commerce clause cases since 1891 71× 71  See In re Rahrer, 140 U S  545, 560–62 (1891) 
Dormant commerce clause cases are not the only constitutional default rules  Professor Laurence Tribe’s treatise identifies two others 72× 72  1 Laurence H  Tribe, American Constitutional Law § 6-35 (3d ed  2000)  And in a groundbreaking article, Professor Henry Monaghan revealed “a substructure of substantive, procedural, and remedial rules” forming “a constitutional common law subject to amendment, modification, or even reversal by Congress ”73× 73  Henry P  Monaghan, The Supreme Court, 1974 Term — Foreword: Constitutional Common Law, 89 Harv  L  Rev  1, 2–3 (1975); see also Susan R  Klein, Identifying and (Re)Formulating Prophylactic Rules, Safe Harbors, and Incidental Rights in Constitutional Criminal Procedure, 99 Mich  L  Rev  1030 (2001) (further developing Monaghan’s theory in criminal procedure context)  What follows is a list of six lines of cases beyond the dormant commerce clause that may be fairly described as constitutional default rules  The first two are drawn from Tribe’s treatise while the next four are found in Monaghan’s article:
(1) State Taxation of Federal Instrumentalities: States may not tax instrumentalities of the federal government74× 74  McCulloch v  Maryland, 17 U S  (4 Wheat ) 316, 436 (1819)  — unless Congress consents 75× 75  See, e g , Helvering v  Gerhardt, 304 U S  405, 411 n 1 (1938) (“Congress may curtail an immunity which might otherwise be implied or enlarge it beyond the point where, Congress being silent, the Court would set its limits ” (citations omitted))  One court has described such judicial decisions as setting a “constitutional default rule ” United States v  Delaware, 958 F 2d 555, 560 n 9 (3d Cir  1992) (“[W]e must decide the constitutional default rule for this type of tax, fully aware that Congress could decide at any time to reverse our decision statutorily ”)  (2) Article I, Section 10 Cases: Article I, Section 10 provides that certain prohibitions on the states may be waived by Congress 76× 76  See U S  Const  art  I, § 10, cls  2–3  The Court has taken note of this when considering whether to overrule, for instance, an Import-Export Clause precedent 77× 77  See Hooven & Allison Co  v  Evatt, 324 U S  652, 668 (1945) (“In view of the fact that the Constitution gives Congress authority to consent to state taxation of imports and hence to lay down its own test for determining when the immunity ends, we see no convincing practical reason for abandoning the test which has been applied for more than a century        ”), overruled on other grounds by Limbach v  Hooven & Allison Co , 466 U S  353 (1984)  In Michelin Tire Corp  v  Wages, 423 U S  276 (1976), the Court left open the question whether “Congress may authorize, under the Import-Export Clause, an exaction that it could not directly impose under the Tax Clause ” Id  at 301 n 13  Metzger, however, argues that the Import-Export Clause is free of other clauses’ limits on congressional power  See Metzger, supra note 69, at 1500 & n 120  (3) Bivens Cases: In Bivens v  Six Unknown Named Agents of Federal Bureau of Narcotics,78× 78  403 U S  388 (1971)  the Court held that a violation of the Fourth Amendment gives rise to a right to sue for damages 79× 79  Id  at 397  But the Court has also held that “[s]uch a cause of action may be defeated       when       Congress has provided an alternative remedy which it explicitly declared to be a substitute for recovery directly under the Constitution and viewed as equally effective ”80× 80  Carlson v  Green, 446 U S  14, 18–19 (1980)  (4) Miranda Cases: The Miranda Court famously “encourage[d]” Congress and the states to explore alternative “procedures which are at least as effective in apprising accused persons of their right of silence and in assuring a continuous opportunity to exercise it ”81× 81  Miranda v  Arizona, 384 U S  436, 467 (1966)  In Dickerson v  United States, 530 U S  428 (2000), the Court struck down a congressional attempt to effectively abolish Miranda, holding that “Miranda announced a constitutional rule that Congress may not supersede legislatively ” Id  at 444  But Dickerson also stood by Miranda’s “invitation for legislative action” to replace Miranda with an adequate substitute  Id  at 440; see also Michael C  Dorf & Barry Friedman, Shared Constitutional Interpretation, 2000 Sup  Ct  Rev  61 (discussing legislative alternatives to Miranda)  (5) The Police Lineup Case: In United States v  Wade,82× 82  388 U S  218 (1967)  the Court created an exclusionary rule for evidence obtained from a police lineup in violation of the Sixth Amendment right to counsel but acknowledged that it could be replaced by “[l]egislative or other regulations       which eliminate the risks of abuse ”83× 83  Id  at 239  (6) The Exclusionary Rule Cases: Mapp v  Ohio made the Fourth Amendment “exclusionary rule” binding on the states,84× 84  367 U S  643, 655 (1961)  yet Congress is thought to have the power to replace it 85× 85  See Bivens v  Six Unknown Named Agents of Fed  Bureau of Narcotics, 403 U S  388, 422–24 (1971) (Burger, C J , dissenting) (inviting Congress to replace the Fourth Amendment exclusionary rule); Harold J  Krent, How to Move Beyond the Exclusionary Rule: Structuring Judicial Response to Legislative Reform Efforts, 26 Pepp  L  Rev  855, 864–71 (1999) 
All of the above are arguably constitutional default rules set by the Court that remain, to one degree or another, open to congressional revision  The list could be longer or shorter, depending on which default rules the Court will view as constitutional86× 86  A shorter list could be produced by whittling away at the constitutional status of the cases identified by Monaghan  While the Court has held that Miranda is a constitutional decision, Dickerson, 530 U S  at 444, some of the other cases may be viewed as nonconstitutional  See, e g , Collins v  Virginia, 138 S  Ct  1663, 1675–80 (2018) (Thomas, J , concurring) (arguing that Mapp is “nonconstitutional,” id  at 1678 n 5); Richard H  Fallon, Jr  et al , Hart and Wechsler’s The Federal Courts and the Federal System 775–77 (7th ed  2015) (discussing whether Bivens is constitutionally required)  Conversely, a longer list might include any constitutional right that can be waived by a party  See, e g , Daniel A  Farber, Another View of the Quagmire: Unconstitutional Conditions and Contract Theory, 33 Fla  St  U  L  Rev  913, 918 (2006) (describing the Eleventh Amendment as “just a contractual default rule that the states are free to barter away”)  Such a list might also include various constitutionally inspired judicial presumptions  See, e g , Jack Goldsmith & John F  Manning, The President’s Completion Power, 115 Yale L J  2280, 2299 (2006) (describing the Chevron presumption of delegated interpretive power to administrative agencies as “a constitutionally inspired default rule”); Nicholas Quinn Rosenkranz, Federal Rules of Statutory Interpretation, 115 Harv  L  Rev  2085, 2097–98 (2002) (describing clear statement rules as “constitutional default rules” reversible by Congress)  Many other decisions could likely be characterized as constitutional default rules; the list above is only an initial stab  and on how it will answer open questions about congressional authority over certain constitutional provisions 87× 87  See, e g , Thomas v  Wash  Gas Light Co , 448 U S  261, 272 n 18 (1980) (plurality opinion) (leaving unresolved whether Congress may limit constitutional full faith and credit obligations); White v  Mass  Council of Constr  Emp’rs, Inc , 460 U S  204, 215 n 1 (1983) (Blackmun, J , concurring in part and dissenting in part) (leaving unresolved “whether Congress may authorize       what otherwise would be a violation” of the Privileges and Immunities Clause); 1 Tribe, supra note 72, § 6-35, at 1243–44 (arguing that Congress cannot override judicial constructions of the Privileges and Immunities Clause); Metzger, supra note 69, at 1486–89 (arguing the opposite)  But the takeaway is clear: weaker stare decisis for constitutional default rules  Pre-Wayfair, one would have thought that stare decisis applies with special force to such precedents, given congressional power to set them straight  Not anymore  Why? Because it is improper to “ask Congress to address a false constitutional premise of th[e] Court’s own creation ”88× 88  Wayfair, 138 S  Ct  at 2096  The Latin for Wayfair’s doctrine is not stare decisis, which should reflect a realistic, working relationship between the legislative and judicial branches  It is mea culpa 
In its zeal to update the Constitution for “the Cyber Age,”89× 89  Id  at 2097  the Court deleted Congress from stare decisis doctrine in constitutional cases  The Court had better options  It could have left Quill on Congress’s doorstep, as the dissent argued  Or it could have justified overruling Quill notwithstanding the special force of stare decisis  Instead, the Court reasoned that it doesn’t matter whether Congress is willing and able to do the job: a constitutional mess calls for a judicial clean-up crew  For constitutional default rules — a category of decisions embracing the dormant commerce clause and sweeping far beyond — Wayfair’s new theory of stare decisis makes the Court’s precedents less sticky and Congress less relevant 
Context 3: consumption influences mercury: Topics by WorldWideScience org
Sample records for consumption influences mercury
Epidemiologic confirmation that fruit consumption influences mercury exposure in riparian communities in the Brazilian Amazon
Sousa Passos, Carlos Jose; Mergler, Donna; Fillion, Myriam; Lemire, Melanie; Mertens, Frederic; Guimaraes, Jean Remy Davee; Philibert, Aline
Since deforestation has recently been associated with increased mercury load in the Amazon, the problem of mercury exposure is now much more widespread than initially thought  A previous exploratory study suggested that fruit consumption may reduce mercury exposure  The objectives of the study were to determine the effects of fruit consumption on the relation between fish consumption and bioindicators of mercury (Hg) exposure in Amazonian fish-eating communities  A cross-sectional dietary survey based on a 7-day recall of fish and fruit consumption frequency was conducted within 13 riparian communities from the Tapajos River, Brazilian Amazon  Hair samples were collected from 449 persons, and blood samples were collected from a subset of 225, for total and inorganic mercury determination by atomic absorption spectrometry  On average, participants consumed 6 6 fish meals/week and ate 11 fruits/week  The average blood Hg (BHg) was 57 1Â±36 3 Î¼g/L (median: 55 1 Î¼g/L), and the average hair-Hg (HHg) was 16 8Â±10 3 Î¼g/g (median: 15 7 Î¼g/g)  There was a positive relation between fish consumption and BHg (r=0 48; P 2 =36 0%) and HHg levels (fish: Î²=1 2, P 2 =21 0%)  ANCOVA models showed that for the same number of fish meals, persons consuming fruits more frequently had significantly lower blood and HHg concentrations  For low fruit consumers, each fish meal contributed 9 8 Î¼g/L Hg increase in blood compared to only 3 3 Î¼g/L Hg increase for the high fruit consumers  In conclusion, fruit consumption may provide a protective effect for Hg exposure in Amazonian riparians  Prevention strategies that seek to maintain fish consumption while reducing Hg exposure in fish-eating communities should be pursued
Influence of mercury bioaccessibility on exposure assessment associated with consumption of cooked predatory fish in Spain 
Torres-Escribano, Silvia; Ruiz, Antonio; Barrios, Laura; VÃ©lez, Dinoraz; Montoro, Rosa
Predatory fish tend to accumulate high levels of mercury (Hg)  Food safety assessment of these fish has been carried out on the raw product  However, the evaluation of the risk from Hg concentrations in raw fish might be modified if cooking and bioaccessibility (the contaminant fraction that solubilises from its matrix during gastrointestinal digestion and becomes available for intestinal absorption) were taken into account  Data on Hg bioaccessibility in raw predatory fish sold in Spain are scarce and no research on Hg bioaccessibility in cooked fish is available  The aim of the present study was to evaluate Hg bioaccessibility in various kinds of cooked predatory fish sold in Spain to estimate their health risk  Both Hg and bioaccessible Hg concentrations were analysed in raw and cooked fish (swordfish, tope shark, bonito and tuna)  There were no changes in Hg concentrations during cooking  However, Hg bioaccessibility decreased significantly after cooking (42 Â± 26% in raw fish and 26 Â± 16% in cooked fish), thus reducing in swordfish and tope shark the Hg concentration to which the human organism would be exposed  In future, cooking and bioaccessibility should be considered in risk assessment of Hg concentrations in predatory fish  Copyright Â© 2011 Society of Chemical Industry 
Intake of mercury through fish consumption
Sarmani, S B ; Kiprawi, A Z ; Ismail, R B ; Hassan, R B ; Wood, A K ; Rahman, S A 
Fish has been known as a source of non-occupational mercury exposure to fish consuming population groups, and this is shown by the high hair mercury levels  In this study, hair samples collected from fishermen and their families, and commercial marine fishes were analyzed for mercury and methylmercury by neutron activation and gas chromatography  The results showed a correlation between hair mercury levels and fish consumption patterns  The levels of mercury found in this study were similar to those reported by other workers for fish consuming population groups worldwide  (author)
Fish consumption limit for mercury compounds
Abbas Esmaili-Sari
Full Text Available Background and objectives: Methyl mercury can carry out harmful effects on the reproductive, respiratory, and nervous system of human  Moreover, mercury is known as the most toxic heavy metal in nature  Fish and seafood consumption is the major MeHg exposure route for human  The present study tries to cover researches which have been conducted on mercury levels in 21 species of fish from Persian Gulf, Caspian Sea and Anzali Wetland during the past 6 years, and in addition to stating mercury level, it provides recommendations about the restriction of monthly fish consumption for each species separately  Material and methods: Fish samples were transferred to the laboratory and stored in refrigerator under -20oC until they were dissected  Afterwards, the muscle tissues were separated and dried  The dried samples were ground and changed into a homogenous powder and then the mercury concentration rate has been determined by advanced mercury analyzer, model 254  Results: In general, mercury contamination in fishes caught from Anzali Wetland was much more than fishes from Caspian Sea  Also, from among all studied fishes, oriental sole (Euryglossa orientalis, caught from Persian Gulf, allocated the most mercury level to itself with the rate of 5 61ml per kg , therefore, it exercises a severe consumption restriction for pregnant women and vulnerable groups  Conclusion: Based on the calculations, about 50% of fishes, mostly with short food chain, can be easily consumed during the year  However, with regard to Oriental sole (Euryglossa orientalis and shark (Carcharhinus dussumieri, caught from Persian Gulf, special consideration should be taken in their consumption  On the other hand, careful planning should be made for the high rate of fish consumption among fishing community 
Hair Mercury Concentrations and Fish Consumption Patterns in Florida Residents
Adam M  Schaefer
Full Text Available Mercury exposure through the consumption of fish and shellfish represents a significant public health concern in the United States  Recent research has demonstrated higher seafood consumption and subsequent increased risk of methylmercury exposure among subpopulations living in coastal areas  The identification of high concentrations of total mercury in blood and skin among resident Atlantic bottlenose dolphins (Tursiops truncatus in the Indian River Lagoon (IRL, a coastal estuary in Florida, alerted us to a potential public health hazard in the contiguous human population  Therefore, we analyzed hair mercury concentrations of residents living along the IRL and ascertained their sources and patterns of seafood consumption  The total mean mercury concentration for 135 residents was 1 53 Â± 1 89 Âµg/g  The concentration of hair mercury among males (2 02 Â± 2 38 Âµg/g was significantly higher than that for females (0 96 Â± 0 74 Âµg/g (p < 0 01  Log transformed hair mercury concentration was significantly associated with the frequency of total seafood consumption (p < 0 01  Individuals who reported consuming seafood once a day or more were 3 71 (95% CI 0 84â€“16 38 times more likely to have a total hair mercury concentration over 1 0 Âµg/g, which corresponds approximately to the U S  EPA reference dose, compared to those who consumed seafood once a week or less  Hair mercury concentration was also significantly higher among individuals who obtained all or most of their seafood from local recreational sources (p < 0 01  The elevated human mercury concentrations mirror the elevated concentrations observed in resident dolphins in the same geographical region  The current study is one of the first to apply the concept of a sentinel animal to a contiguous human population 
Fish consumption and bioindicators of inorganic mercury exposure
Sousa Passos, Carlos Jose; Mergler, Donna; Lemire, Melanie; Fillion, Myriam; Guimaraes, Jean Remy Davee
Background: The direct and close relationship between fish consumption and blood and hair mercury (Hg) levels is well known, but the influence of fish consumption on inorganic mercury in blood (B-IHg) and in urine (U-Hg) is unclear  Objective: Examine the relationship between fish consumption, total, inorganic and organic blood Hg levels and urinary Hg concentration  Methods: A cross-sectional study was carried out on 171 persons from 7 riparian communities on the Tapajos River (Brazilian Amazon), with no history of inorganic Hg exposure from occupation or dental amalgams  During the rising water season in 2004, participants responded to a dietary survey, based on a seven-day recall of fish and fruit consumption frequency, and socio-demographic information was recorded  Blood and urine samples were collected  Total, organic and inorganic Hg in blood as well as U-Hg were determined by Atomic Absorption Spectrometry  Results: On average, participants consumed 7 4 fish meals/week and 8 8 fruits/week  Blood total Hg averaged 38 6 Â± 21 7 Î¼g/L, and the average percentage of B-IHg was 13 8%  Average organic Hg (MeHg) was 33 6 Â± 19 4 Î¼g/L, B-IHg was 5 0 Â± 2 6 Î¼g/L, while average U-Hg was 7 5 Â± 6 9 Î¼g/L, with 19 9% of participants presenting U-Hg levels above 10 Î¼g/L  B-IHg was highly significantly related to the number of meals of carnivorous fish, but no relation was observed with non-carnivorous fish; it was negatively related to fruit consumption, increased with age, was higher among those who were born in the Tapajos region, and varied with community  U-Hg was also significantly related to carnivorous but not non-carnivorous fish consumption, showed a tendency towards a negative relation with fruit consumption, was higher among men compared to women and higher among those born in the region  U-Hg was strongly related to I-Hg, blood methyl Hg (B-MeHg) and blood total Hg (B-THg)  The Odds Ratio (OR) for U-Hg above 10 Î¼g/L for those who ate > 4 carnivorous fish
Methyl mercury exposure in Swedish women with high fish consumption
Bjoernberg, Karolin Ask [Division of Metals and Health, Institute of Environmental Medicine, Karolinska Institutet, Box 210, SE-171 77, Stockholm (Sweden); Vahter, Marie [Division of Metals and Health, Institute of Environmental Medicine, Karolinska Institutet, Box 210, SE-171 77, Stockholm (Sweden); Grawe, Kierstin Petersson [Toxicology Division, National Food Administration, Box 622, SE-751 26 Uppsala (Sweden); Berglund, Marika [Division of Metals and Health, Institute of Environmental Medicine, Karolinska Institutet, Box 210, SE-171 77, Stockholm (Sweden)]  E-mail: Marika Berglund@imm ki se
We studied the exposure to methyl mercury (MeHg) in 127 Swedish women of childbearing age with high consumption of various types of fish, using total mercury (T-Hg) in hair and MeHg in blood as biomarkers  Fish consumption was assessed using a food frequency questionnaire (FFQ), including detailed information about consumption of different fish species, reflecting average intake during 1 year  We also determined inorganic mercury (I-Hg) in blood, and selenium (Se) in serum  The average total fish consumption, as reported in the food frequency questionnaire, was approximately 4 times/week (range 1 6-19 times/week)  Fish species potentially high in MeHg, included in the Swedish dietary advisories, was consumed by 79% of the women  About 10% consumed such species more than once a week, i e , more than what is recommended  Other fish species potentially high in MeHg, not included in the Swedish dietary advisories, was consumed by 54% of the women  Eleven percent never consumed fish species potentially high in MeHg  T-Hg in hair (median 0 70 mg/kg; range 0 08-6 6 mg/kg) was associated with MeHg in blood (median 1 7 {mu}g/L; range 0 30-14 {mu}g/L; r {sub s}=0 78; p<0 001)  Hair T-Hg, blood MeHg and serum Se (median 70 {mu}g/L; range 46-154 {mu}g/L) increased with increasing total fish consumption (r {sub s}=0 32; p<0 001, r {sub s}=0 37; p<0



ground_truth: Quill harmed states more than anticipated due to the Internet.

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What was the conclusion of the study?

Read the following text and answer briefly.

Context 3: 001 and r {sub s}=0 35; p=0 002, respectively)  I-Hg in blood (median 0 24 {mu}g/L; range 0 01-1 6 {mu}g/L) increased with increasing number of dental amalgam fillings  We found no statistical significant associations between the various mercury species measured and the Se concentration in serum  Hair mercury levels exceeded the levels corresponding to the EPA reference dose (RfD) of 0 1 {mu}g MeHg/kg b w  per day in 20% of the women  Thus, there seems to be no margin of safety for neurodevelopmental effects in fetus, for women with high fish consumption unless they decrease their intake of certain fish species 
Bjoernberg, Karolin Ask; Vahter, Marie; Grawe, Kierstin Petersson; Berglund, Marika
We studied the exposure to methyl mercury (MeHg) in 127 Swedish women of childbearing age with high consumption of various types of fish, using total mercury (T-Hg) in hair and MeHg in blood as biomarkers  Fish consumption was assessed using a food frequency questionnaire (FFQ), including detailed information about consumption of different fish species, reflecting average intake during 1 year  We also determined inorganic mercury (I-Hg) in blood, and selenium (Se) in serum  The average total fish consumption, as reported in the food frequency questionnaire, was approximately 4 times/week (range 1 6-19 times/week)  Fish species potentially high in MeHg, included in the Swedish dietary advisories, was consumed by 79% of the women  About 10% consumed such species more than once a week, i e , more than what is recommended  Other fish species potentially high in MeHg, not included in the Swedish dietary advisories, was consumed by 54% of the women  Eleven percent never consumed fish species potentially high in MeHg  T-Hg in hair (median 0 70 mg/kg; range 0 08-6 6 mg/kg) was associated with MeHg in blood (median 1 7 Î¼g/L; range 0 30-14 Î¼g/L; r s =0 78; p s =0 32; p s =0 37; p s =0 35; p=0 002, respectively)  I-Hg in blood (median 0 24 Î¼g/L; range 0 01-1 6 Î¼g/L) increased with increasing number of dental amalgam fillings  We found no statistical significant associations between the various mercury species measured and the Se concentration in serum  Hair mercury levels exceeded the levels corresponding to the EPA reference dose (RfD) of 0 1 Î¼g MeHg/kg b w  per day in 20% of the women  Thus, there seems to be no margin of safety for neurodevelopmental effects in fetus, for women with high fish consumption unless they decrease their intake of certain fish species
Fish Consumption and Mercury Exposure among Louisiana Recreational Anglers
Lincoln, Rebecca A; Shine, James P; Chesney, Edward J
Background: Methylmercury (MeHg) exposure assessments among average fish consumers in the U S  may underestimate exposures among U S  subpopulations with high intakes of regionally specific fish  Objectives: We examined relationships between fish consumption, estimated mercury (Hg) intake      , and measured Hg exposure among one such potentially highly-exposed group, recreational anglers in Louisiana USA  Methods: We surveyed 534 anglers in 2006 using interviews at boat launches and fishing tournaments combined with an internet-based survey method  Hair samples from 402 of these anglers were       collected and analyzed for total Hg  Questionnaires provided information on species-specific fish consumption over 3 months prior to the survey  Results: Anglers' median hair-Hg concentration was 0 81 Âµg/g (n=398; range: 0 02-10 7 Âµg/g), with 40% of participants above 1 Âµg/g, the level that approximately   
Umbilical cord blood and placental mercury, selenium and selenoprotein expression in relation to maternal fish consumption
Gilman, Christy L ; Soon, Reni; Sauvage, Lynnae; Ralston, Nicholas V C ; Berry, Marla J 
Seafood is an important source of nutrients for fetal neurodevelopment  Most individuals are exposed to the toxic element mercury through seafood  Due to the neurotoxic effects of mercury, United States government agencies recommend no more than 340 g (12 oz) per week of seafood consumption during pregnancy  However, recent studies have shown that selenium, also abundant in seafood, can have protective effects against mercury toxicity  In this study, we analyzed mercury and selenium levels an   
Factors that negatively influence consumption of traditionally    
Factors that negatively influence consumption of traditionally fermented milk     in various countries of sub-Saharan Africa and a number of health benefits to human     influence consumption of Mursik, a traditionally fermented milk product fromÂ    
Mercury exposure as a function of fish consumption in two Asian communities in coastal Virginia, USA 
Xu, Xiaoyu; Newman, Michael C
Fish consumption and associated mercury exposure were explored for two Asian-dominated church communities in coastal Virginia and compared with that of two non-Asian church communities  Seafood-consumption rates for the Chinese (36 9Â g/person/day) and Vietnamese (52 7Â g/person/day) church communities were greater than the general United States fish-consumption rate (12 8Â g/person/day)  Correspondingly, hair mercury concentrations for people from the Chinese (0 52Â Âµg/g) and the Vietnamese church (1 46Â Âµg/g) were greater than the overall level for United States women (0 20Â Âµg/g) but lower than the published World Health Organization exposure threshold (14Â Âµg/g)  A conventional regression model indicated a positive relationship between seafood consumption rates and hair mercury concentrations suggesting the importance of mercury exposure through seafood consumption  The annual-average daily methylmercury intake rate for the studied communities calculated by Monte Carlo simulations followed the sequence: Vietnamese communityÂ >Â Chinese communityÂ >Â non-Asian communities  Regardless, their daily methylmercury intake rates were all lower than the United States Environmental Protection Agency reference dose of 0 1Â Âµg/kg body weight-day  In conclusion, fish-consumption patterns differed among communities, which resulted in different levels of mercury exposure  The greater seafood and mercury ingestion rates of studied Asian groups compared with non-Asian groups suggest the need for specific seafood consumption advice for ethnic communities in the United States  Otherwise the health benefits from fish consumption could be perceived as trivial compared with the ill-defined risk of mercury exposure 
Feather growth influences blood mercury level of young songbirds 
Condon, Anne M; Cristol, Daniel A
Dynamics of mercury in feathers and blood of free-living songbirds is poorly understood  Nestling eastern bluebirds (Sialia sialis) living along the mercury-contaminated South River (Virginia, USA) had blood mercury levels an order of magnitude lower than their parents (nestling: 0 09 +/- 0 06 mg/kg [mean +/- standard deviation], n = 156; adult: 1 21 +/- 0 57 mg/kg, n = 86)  To test whether this low blood mercury was the result of mercury sequestration in rapidly growing feathers, we repeatedly sampled free-living juveniles throughout the period of feather growth and molt  Mean blood mercury concentrations increased to 0 52 +/- 0 36 mg/kg (n = 44) after the completion of feather growth  Some individuals had reached adult blood mercury levels within three months of leaving the nest, but levels dropped to 0 20 +/- 0 09 mg/kg (n = 11) once the autumn molt had begun  Most studies of mercury contamination in juvenile birds have focused on recently hatched young with thousands of rapidly growing feathers  However, the highest risk period for mercury intoxication in young birds may be during the vulnerable period after fledging, when feathers no longer serve as a buffer against dietary mercury  We found that nestling blood mercury levels were not indicative of the extent of contamination because a large portion of the ingested mercury ended up in feathers  The present study demonstrates unequivocally that in songbirds blood mercury level is influenced strongly by the growth and molt of feathers 
High mercury seafood consumption associated with fatigue at specialty medical clinics on Long Island, NY
Shivam Kothari
Full Text Available We investigated the association between seafood consumption and symptoms related to potential mercury toxicity in patients presenting to specialty medical clinics at Stony Brook Medical Center on Long Island, New York  We surveyed 118 patients from Aprilâ€“August 2012 about their seafood consumption patterns, specifically how frequently they were eating each type of fish, to assess mercury exposure  We also asked about symptoms associated with mercury toxicity including depression, fatigue, balance difficulties, or tingling around the mouth  Of the 118 adults surveyed, 14 consumed high mercury seafood (tuna steak, marlin, swordfish, or shark at least weekly  This group was more likely to suffer from fatigue than other patients (pÂ =Â 0 02  Logistic regression confirmed this association of fatigue with frequent high mercury fish consumption in both unadjusted analysis (ORÂ =Â 5 53; 95% CI: 1 40â€“21 90 and analysis adjusted for age, race, sex, income, and clinic type (ORÂ =Â 7 89; 95% CI: 1 63â€“38 15  No associations were observed between fish intake and depression, balance difficulties, or tingling around the mouth  Findings suggest that fatigue may be associated with eating high mercury fish but sample size is small  Larg



ground_truth: The conclusion was that fruit consumption may provide a protective effect for mercury exposure in Amazonian riparians.