Evolution of the Obliquities of the Giant Planets in Encounters during   Migration
  Tsiganis et al. (2005) have proposed that the current orbital architecture of the outer solar system could have been established if it was initially compact and Jupiter and Saturn crossed the 2:1 orbital resonance by divergent migration. The crossing led to close encounters among the giant planets, but the orbital eccentricities and inclinations were damped to their current values by interactions with planetesimals. Brunini (2006) has presented widely publicized numerical results showing that the close encounters led to the current obliquities of the giant planets. We present a simple analytic argument which shows that the change in the spin direction of a planet relative to an inertial frame during an encounter between the planets is very small and that the change in the obliquity (which is measured from the orbit normal) is due to the change in the orbital inclination. Since the inclinations are damped by planetesimal interactions on timescales much shorter than the timescales on which the spins precess due to the torques from the Sun, especially for Uranus and Neptune, the obliquities should return to small values if they are small before the encounters. We have performed simulations using the symplectic integrator SyMBA, modified to include spin evolution due to the torques from the Sun and mutual planetary interactions. Our numerical results are consistent with the analytic argument for no significant remnant obliquities. 
Man Hoi Lee (UCSB), S. J. Peale (UCSB), Eric Pfahl (KITP), William R.   Ward (SwRI)