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The standard civil procedure lesson on choice of law in federal courts begins with Erie Railroad Co. v. Tompkins, where Justice Brandeis famously declared \"federal general common law\" unconstitutional. Erie ended the ninety-six year reign of Swift v. Tyson, which had held that federal courts could ignore state decisional law in cases of \"general commercial law.\" For Justice Brandeis, Swift relied on the \"fallacy\" that the \"federal courts have the power to use their judgment as to what the rules of common law are; and that in the federal courts 'the parties are entitled to an independent judgment on matters of general law.'\" Justice Holmes, on whom Justice Brandeis relied.

Genetic variation in plants can influence the community structure of associated species, through both direct and indirect interactions. Herbivorous insects are known to feed on a restricted range of plants, and herbivore preference and performance can vary among host plants within a species due to genetically based traits of the plant (e.g., defensive compounds). In a natural system, we expect to find genetic variation within both plant and herbivore communities and we expect this variation to influence species interactions. Using a three‐species plant‐aphid model system, we investigated the effect of genetic diversity on genetic interactions among the community members. Our system involved a host plant (Hordeum vulgare) that was shared by an aphid (Sitobion avenae) and a hemi‐parasitic plant (Rhinanthus minor). We showed that aphids cluster more tightly in a genetically diverse host‐plant community than in a genetic monoculture, with host‐plant genetic diversity explaining up to 24% of the variation in aphid distribution. This is driven by differing preferences of the aphids to the different plant genotypes and their resulting performance on these plants. Within the two host‐plant diversity levels, aphid spatial distribution was influenced by an interaction among the aphid's own genotype, the genotype of a competing aphid, the origin of the parasitic plant population, and the host‐plant genotype. Thus, the overall outcome involves both direct (i.e., host plant to aphid) and indirect (i.e., parasitic plant to aphid) interactions across all these species. These results show that a complex genetic environment influences the distribution of herbivores among host plants. Thus, in genetically diverse systems, interspecific genetic interactions between the host plant and herbivore can influence the population dynamics of the system and could also structure local communities. We suggest that direct and indirect genotypic interactions among species can influence community structure and processes. In this study we used a three species aphid‐plant model system (aphids, host‐plant and parasitic plant) to investigate the effect of genetic diversity on genetic interactions among the community members. We showed that aphids cluster more tightly in a genetically diverse host‐plant system than in a genetic monoculture. Furthermore, within the host‐plant diversity levels, aphid distribution was influenced by higher‐order genetic interactions among all community members. Thus, a complex genetic environment influences the distribution of herbivores among host plants, suggesting that direct and indirect genotypic interactions among species can influence community structure and processes.

The new Adagio aparthotel will pay homage to the history of Beorma, named after the seventh century Anglo-Saxon founder of the settlement which Birmingham has become, by featuring the markings of the ancient city Hersum Ditch within the main public space.