The Sometimes “Craven Watchdog”: The Disparate Criminal-Civil Application of the Presumption Against Extraterritoriality

Increasingly, courts must decide whether U.S. law applies extraterritorially. Courts largely resolve questions of extraterritorial scope using tools of statutory construction. Of these tools, the presumption against extraterritoriality has been ascendant. However, this presumption is subject to two divergent lines of cases: Morrison v. National Australia Bank Ltd. affirmed the strict operation of the presumption in civil cases, but United States v. Bowman continues to govern the presumption\u27s looser role in criminal cases, thereby creating a doctrinal asymmetry. This Note furthers the argument that courts should reconcile Morrison and Bowman, by laying out three arguments for why an expansive Bowman exception is problematic and unsustainable. First, the two lines of cases create unjustified doctrinal incoherencies, given the interrelated contexts in which the presumption is applied and the rationales underlying the presumption. Second, an expansive exception to the presumption in criminal contexts undermines the smart allocation of authority between the branches of government. Finally, an expansive Bowman exception runs counter to the tradition of offering fair notice of criminal law\u27s prohibitions. This Note asserts that these arguments counsel for the abrogation or, at least, substantial narrowing of the Bowman exception, to harmonize it with Morrison\u27s stricter vision of the presumption against extraterritoriality

Recent studies on flame stabilization of premixed turbulent gases

FLAME stabilization is of importance in the practical design of ramjets and afterburners. It has been studied extensively in recent years, particularly with reference to bluff-body flame-holders. In the present survey we describe the investigations relating to flame holding by bluff bodies as well as new techniques (e.g.,. flame holding by the use of reverse jets) which may prove to be of practical importance in new engine configurations. In Section II we consider the flow field downstream of a bluff-body flame-holder which includes the recirculation zone behind the body and a region of flame spreading farther downstream. Explicit reference is made to crucial experiments which illustrate the nature and magnitude of the velocity field, the physical extent, the temperature, and the gas composition of the recirculation zone. Experimental studies and theoretical predictions of the angle of flame spreading, as well as some observations on unstable flow and the onset of blowoff, will be reviewed. The variation of blowoff velocity with flame-holder design, pressure, and mixture composition is considered briefly in Section III both for single and for adjacent bluff bodies. Also included is a summary of results for blowoff velocities obtained with a reverse-jet flame-holder and with wall recesses. Theoretical studies on the mechanism of flame stabilization form the subject of Section IV. We shall indicate the points on which various proposed models agree and disagree with experiment and attempt to formulate a composite description which is consistent with most of the currently available experimental data both for bluff-body and for reverse-jet flameholders

An evaluation of the Sycamore Tree programme: based on an analysis of Crime Pics II data

Sheffield Hallam University, in conjunction with Manchester Metropolitan University, were commissioned to undertake an evaluation of the Sycamore Tree programme by Prison Fellowship England and Wales, who have been delivering the programme across a wide range of prisons throughout England and Wales over a number of years. This current evaluation builds on a previous report published by Sheffield Hallam University in 2005 which undertook a similar analysis and identified a positive impact on prisoners who had successfully completed the programme

Crystal growing by electrodeposition from dense gaseous solutions

Single crystals and dendritic formations of silver are grown on platinum electrodes by electrodeposition from a dense gaseous solution of silver nitrate in ammonia. Process is modification of hydrothermal process, and also differs from standard electrodeposition by permitting single crystals to be grown from hydrogen-bonded solvents

Elastic and inelastic scattering of 40 eV electrons from atomic lead

Differential and integral electron impact cross sections for elastic scattering and for the excitation of the first five states in lead have been determined at 40 eV impact energy. The cross section measurements were placed on the absolute scale by normalizing to the optical f-value of the 6p7s3P1 transition which is the upper state for the 7229 Å, 4057 Å and 3639 Å laser emissions. The integral cross sections for elastic scattering (6p2 3P0) and for the excitation of the 6p2 3P1, 6p2 3P2, 6p2 1D2, and 6p7s 3P0(+6p7s3P1) states are: 44, 0.15, 1.5, 0.05 and 8.4*10^-16 cm^2 respectively

Angular Distribution of Bremsstrahlung Produced by 10-keV and 20-keV Electrons Incident on a Thick Au Target

The relative intensities of the thick-target bremsstrahlung produced by 10-keV and 20-keV electrons incident on Au at forward angles ranging from 0 degrees to 25 degrees are compared. Following corrections for photon absorption within the target, the detected radiation appears to be distributed anisotropically only for photon energies, k, that are approximately equal to the initial energy of the incident electrons, E. The results are compared to the theoretical angular distributions of Kissel et al. [At. Data Nucl. Data Tables 28, 381 (1983)]. The comparison suggests that when k/E is approximately equal to 1, the angular distribution of bremsstrahlung emitted by electrons incident on thick targets is similar to the theoretical angular distribution of bremsstrahlung emitted by electrons incident on free-atom targets.Comment: The following article has been accepted by AIP Conference Proceedings (Vol. 1525). After it is published, it will be found at http://proceedings.aip.org

Possible Aeolian megaripples on Mars

Viking orbiter image frames 442B01-10, at 8 m/pxl resolution show that valley floors are not smooth at all, but rather are covered with mounds of material interpreted as dunes. Striations oriented perpendicular to the valley axis can be seen in several locations. The striations are here interpreted to be aeolian megaripples formed from debris weathered from the yardangs. Terrestrial aeolian megaripples have wavelengths up to 25 m; it is not unreasonable that larger megaripples might form under favorable Martian conditions, given the wind speeds available and the lower Martian gravity. If the megaripple interpretation is correct, then by terrestrial analog the deposit in which they occur has a bimodal particle size distribution. One size will undergo saltation; the other, concentrated at the crests of the megaripples, is too large/and or too dense to be put into saltation. For Mars the former is sand-sized, the latter gravel-sized, provided the materials have typical densities