John Rylands Library Manchester University Library. Stella Butler, a medical historian, was Head of Special Collections from 2000 until 2009, and she moved to the University of Leeds in 2011 as University Librarian. Since 2009, Rachel Beckett has been Head of Special Collections and she was appointed as the Associate Director of The John Rylands Library in 2013. Jan Wilkinson has been the Director of The John Rylands Library, as well as University Librarian, since 2008. Acting Librarian David Miller founded the John Rylands Research Institute in 1987, to promote, fund and stimulate research on the primary material held at Deansgate. The John
Rylands v Fletcher principle, in "Losee v. Buchanan", "Brown v. Collins", and "Marshall v. Welwood" respectively. The Supreme Court of New Jersey, however, reversed "Welwood" in 1983 in "Department of Environmental Protection v. Ventron Corp". Many courts in the United States have attempted to use "Rylands" to justify absolute liability, which it was never intended to do; while absolute liability is where no defence is applicable, in "Rylands" itself Lord Cairns accepted that there were some situations where the case should not be applied. In Australia, the principles of "Rylands v Fletcher" were "killed off" by the High Court of Australia in "Burnie