In this piece, I tackle a current subject of popular controversywhether growing multilingualism in the United
Species native to ecotones are often overlooked in restoration efforts despite the increasing rarity of ecotone habitat. In fragmented, fire-suppressed landscapes, true ecotone may no longer exist. Restoration biologists interested in reintroducing ecotone species must decide whether to plant them in historic ecotones maintained by manual thinning or whether to opt for discrete restoration areas that are easier to maintain. We investigated these two alternatives with Lantana canescens, a rare tropical shrub native to the ecotone between pine and hardwood forests of Miami-Dade County, Florida, U.S.A. Our shortterm findings show that after 15 and 18 months, survival of transplants was 69% in a restored site and 65% and 84% in two historic ecotone sites. The restored site had significantly higher photosynthetically active radiation (PAR) (75%) than the historic ecotones (25-39%). Correspondingly, 267 seedlings have recruited at the restored site, whereas only 8 have emerged at both historic ecotone sites. Seedling establishment was associated with higher PAR at the restored site. We found that overall population sustainability was higher at the restored site where there is the additional benefit of less maintenance. Our work suggests that, by reducing succession, a discrete restoration area can approach the historic conditions of hardwood/pine forest ecotone more closely than degraded historic ecotones themselves. We present a viable solution for conserving rare ecotone species when their natural habitat and the processes that maintained it no longer exist.
Congress's plenary power to regulate immigration sharply limits the judiciary's involvement in immigration regulation. Since the plenary power doctrine was first formulated, the Supreme Court has emphasized that immigration represents an issue best left to the political branches. The resulting extended focus by scholars on the implications of this distribution of power between courts and the political branches has obscured a second important separation-of-powers issue: the question of how immigration authority is distributed between the political branches themselves. The Court's immigration jurisprudence has shed little light on this question, often treating the political branches as something of a singular entity. Surprisingly little scholarly commentary has addressed the inter-relationship between the two branches or attempted to discern whether consistent power-sharing patterns have emerged over time.In this Article, we explore how the allocation of power between the political branches to screen immigrants has been understood both as a matter of constitutional history and as a matter of actual practice, with a view to better understanding the structure of American immigration law. We present a long-overlooked constitutional history according to which the executive has claimed inherent authority to screen and admit immigrants, But we demonstrate how this use of authority has been slowly domesticated by the rise of the administrative state and its associated jurisprudence, with the consequence that most executive policymaking in the immigration arena proceeds today through delegated authority. But this delegation has not always operated in obvious ways. We show that the explosion of a detailed, rule-bound immigration code has had the counterintuitive consequence of delegating tremendous authority to the President to decide the most basic questions about which types of noncitizens, and how many, should reside in the United States. But this delegation has been asymmetric: the President has considerable authority to screen immigrants at the back end of the system through its enforcement decisions, but little control over screening at the front end, before immigrants enter the United States. We argue that this asymmetric delegation has pathological consequences in certain circumstances, and we suggest two possible solutions: either formally delegating to the President the power to adjust the quotas and admissions criteria at the heart of immigration law, or seriously restricting the prosecutorial discretion of the President in the immigration arena.
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