Striking a Balance: Privacy and National Security in Section 702 U.S. Person Queries

The transformation of U.S. foreign intelligence in recent years has led to increasing privacy concerns. The Foreign Intelligence Surveillance Act of 1978 (FISA) traditionally regulated foreign intelligence surveillance by authorizing warrant-based searches of U.S. and non-U.S. persons. Individualized court orders under traditional FISA were intended to protect U.S. persons and limit the scope of intelligence collection. In a post-9/11 world, however, the intelligence community cited concerns regarding the speed and efficiency of collection under traditional methods. The intelligence and law enforcement communities recognized the “wall” preventing information sharing between the communities as a central failure leading to the 9/11 attacks. In response, the scope and authorizations of foreign intelligence collection were expanded with numerous statutory measures, culminating in the passage of Section 702. Under Section 702, only non-U.S. persons located abroad may be surveillance targets, but no warrant is required for the intelligence collection. Since its passage, the intelligence community and privacy advocates have intensely debated the implications of incidental collection of U.S. person communications, including the use of U.S. person queries. Despite the significant expansion of surveillance authorized in the shift from traditional FISA to Section 702, minimization and targeting procedures regulated by the new statute are designed to protect U.S. persons and balance national security and privacy interests. This Comment addresses the uncomfortable question of whether the U.S. Constitution permits the minor intrusion of a few to protect national security and argues that Section 702 queries are searches under the Fourth Amendment that require a justification independent from the overall surveillance to be constitutional. Nonetheless, the Fourth Amendment protects against only unreasonable searches or seizures by the government, and U.S. person queries are reasonable searches characterized by critical foreign intelligence interests and robust safeguards that outweigh limited impacts on privacy. While the Fourth Amendment does require probable cause warrants for U.S. person queries conducted for criminal investigative purposes, such queries are rare. Striking the proper balance between privacy and security, particularly in the modern technological era, is a complex and challenging legal question. In this context, considerations must include policy and value-laden choices that weigh the statute’s own regulatory measures against the rights protected by the Fourth Amendment. Such an approach renders U.S. person queries reasonable Fourth Amendment searches, albeit subject to more stringent requirements than courts and the government have previously found

From Lucas to Palazzolo: A Case Study of Title Limitations

This Note examines what state courts and lower federal courts have found to be background principles of property and nuisance law that fit into the Lucas exception. The Note examines recent case law that applies the Lucas exception to determine how the law has developed. The Note then explains the facts of Palazzolo v. Rhode Island and discusses how the Court should rule on the issues in light of the difficulty the courts have had in applying Lucas. The Note concludes that the Court must consider the importance of the right to own property in America. The Court should take a firm stance to protect property rights-and democracy-by making sure that the government follows the Constitutional mandate to pay just compensation when it regulates property in a way that results in a taking

Controlling Listeria monocytogenes on ready-to-eat poultry products using carboxymethylcellulose film coatings containing green tea extract (GTE) combined with nisin and malic acid

The ability to control Listeria monocytogenes on ready-to-eat poultry products using carboxymethyl-cellulose film coatings containing green tea extract (GTE), malic acid (M), nisin (N), and their combinations was evaluated. The antimicrobials (GTE: 1.0%, nisin: 10,000 IU/g, malic acid: 1.0%) were incorporated alone or in combination into a carboxymethyl cellulose film coating. Pre-inoculated, fully cooked chicken pieces (~1g, 1cm x 1cm x 1cm) were coated with the film solution. The coated chicken pieces were stored at 4°C and the inhibitory activity against Listeria monocytogenes was evaluated at 0, 7, 14, 21, and 28 days. The highest inhibitory activity was found in the sample containing GTE, nisin, and malic acid in combination with a reduction of 3.3 log CFU/mL. These data demonstrate that GTE—combined with nisin and malic acid and incorporated into a carboxymethyl-cellulose film coating, multiple-hurdle technology—is effective in inhibiting L. monocytogenes growth on fully cooked chicken pieces at 4°C. Research in the area of finding natural antimicrobials to aid in the prevention of food-borne illnesses is necessary to improve safety and shelf life of products such as ready-to-eat meats. This project provides an effective combination of natural anti-microbials to control L. monocytogenes in ready-to-eat chicken pieces

Initiating Courageous Conversations about Race and Racism with Read-Alouds

This article describes a classroom activity developed by two teacher educators to support pre-service teachers in integrating culturally responsive teaching practices with reading methods instruction. The activity tasks pre-service teachers to select culturally authentic children’s texts and design read-alouds that engage elementary students in conversations around race and racism while simultaneously meeting English Language Arts standards. This reimagined classroom practice will be of interests to educators who are seeking resources on how to address culturally relevant topics, such as race and racism, in the classroom

Supporting Preservice Teacher Development of Culturally Responsive Reading Instruction Through a Cross-Course Assignment

This article describes design-based research undertaken by two teacher educators to support elementary preservice teachers (PSTs) in integrating culturally responsive teaching practices with reading methods. The study described was motivated by calls for teacher preparation programs to be more intentional about supporting PSTs in synthesizing their learning across courses, especially when it comes to culturally responsive reading pedagogies. This article focuses on an activity that tasked PSTs to select culturally authentic children’s texts and design interactive read-alouds that engage elementary students in conversations around social justice topics while simultaneously meeting English language arts standards. Analysis of the lesson plans revealed that PSTs made explicit connections between reading methods instruction and strategies that facilitate dialogue about critical social issues and social justice advocacy, but the connections remained shallow. PSTs showed that they understood the overall goal of the assignment but lacked depth and detail in their justifications of texts and activities. The authors conclude with a reflection on the patterns that emerged in their findings and outline their plans for future iterations of the experiment. Overall, the authors’ experiences highlight the importance of teacher preparation programs exploring more opportunities to cross-pollinate assignments or otherwise build bridges between courses to support PSTs’ integration of concepts

Support Vector Machines and Radon's Theorem

A support vector machine (SVM) is an algorithm which finds a hyperplane that optimally separates labeled data points in $\mathbb{R}^n$ into positive and negative classes. The data points on the margin of this separating hyperplane are called support vectors. We study the possible configurations of support vectors for points in general position. In particular, we connect the possible configurations to Radon's theorem, which provides guarantees for when a set of points can be divided into two classes (positive and negative) whose convex hulls intersect. If the positive and negative support vectors in a generic SVM configuration are projected to the separating hyperplane, then these projected points will form a Radon configuration. Further, with a particular type of general position, we show there are at most $n+1$ support vectors. This can be used to test the level of machine precision needed in a support vector machine implementation. We also show the projections of the convex hulls of the support vectors intersect in a single Radon point, and under a small enough perturbation, the points labeled as support vectors remain labeled as support vectors. We furthermore consider computations studying the expected number of support vectors for randomly generated data

The Impact of Trauma on Graduate Occupational Therapy Students: Trauma-Informed Implications for Educators

Recent worldwide events have led to a dramatic increase in reported levels of anxiety in college students and individuals aged 18-29. If there is currently a marked increase in anxiety and stress responses in college age students and traumatic events negatively impact an individual’s ability to participate in their education, it is reasonable to assume that the occupational disruption that students are currently experiencing negatively impacts their ability to participate adequately in their education. This study explored the impact of trauma on graduate occupational therapy students (OTS) from entry-level programs. A mixed-methods survey was utilized to gain the perspectives of graduate OTS (n=74) currently attending programs in the Northeastern portion of the United States who have experienced acute, chronic, and/or complex trauma. Participants completed an online survey consisting of 26 Likert-style, true/false, and open-ended short answer questions. Results indicate that trauma is highly impactful on all areas of occupation, including education. Additionally, students indicated that they are fearful of stigma when discussing trauma and informing educators of its impacts on education, therefore benefiting from open and communicative educators. Further, results support previous research that trauma influences many aspects of academic performance, such as attention, memory, and volition. The information gathered indicates that educators should be aware of the likelihood of students being impacted by trauma and understand how to successfully support students universally through trauma-informed strategies

From Data to Community Action: A Case Study Building on the Massachusetts Healthy Aging Community Profiles

The Healthy Aging movement is a driver in the promotion of Evidence-Based programs such as Chronic Disease Self- Management (CDSMP) programs related to falls prevention and diabetes. Such programs are critical in any recommendations for short or long term interventions to communities to address challenges to aging well

Addressing the Long-Term Influence of Neurotrauma on Self-Concept and Self-Identity Development: A Pilot Study

Background: Numerous neurotrauma survivors face lifelong disability post injury as a result of an event, yet there are limited specialized continued care services to support future outcomes, specifically self-concept, self-identity, and quality of life. To reduce health care barriers and support health promotion post injury, student researchers explored the influence of a community-based occupational therapy (OT) program for the neurotrauma population. Methods: Four participants, 37 to 58 years of age, with a history of neurotrauma, participated in a mixed methods study composed of a 6-week community-based educational OT program. Outcome measures included Activity Card Sort, Lawton Brody Scale, Pre and Post Surveys, and Semi-Structured Interviewing. Results: Data from the study support implementation of a community-based program, such as the one used in this study. This study highlighted the need for a program addressing self-concept, self-identity, and post-injury quality of life in addition to occupational engagement at a community level. Conclusion: The findings from the current study reinforce participation in a community-based OT program as an effective approach to address long-term outcomes post neurotrauma, specifically self-concept, self-identity, and quality of life. Program efficacy is supported by both quantitative and qualitative findings; however, further research is required to generalize the findings to the neurotrauma population as a whole